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Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 1 – Meeting South Warwickshire’s Sustainable Development Requirements
a)
Housing Numbers
4.1.
The policy direction indicates that provision will be made for the delivery of 1,679 dwellings per annum (dpa), with sufficient flexibility to accommodate up to 2,188 dpa. Factoring in existing commitments and an assumed windfall allowance, it is suggested that the SWLP will need to identify land for between 15,532 to 28,257 dwellings over the plan period, to 2050.
4.2.
The 1,679 hpa figure is derived from the Housing & Economic Development Needs Assessment (HEDNA) (November 2022), which identified this as the annual housing need for South Warwickshire based on demographic data, including initial 2021 census data. It has now been over two years since the publication of the HEDNA, and the HEDNA, and the data within it, no longer represents up-to-date evidence; NPPF §32 states that plans should be underpinned by the latest available evidence and the SA recommends that the HEDNA calculation should be updated.
4.3.
This has also been recognised by Iceni, who produced the HEDNA. Further Advice on Housing & Employment Land Needs was published by Iceni in February 2024. This report reviews the projections for housing need in South Warwickshire. Notably, the concluding recommendation is for the updated 10-year migration trend projection to be taken forward, requiring the provision of 1,919 hpa.
4.4.
Further, NPPF §62 states that local housing need should be calculated using the Standard Method (SM) set out in Planning Practice Guidance (PPG). Following the publication of the updated NPPF, the Standard Method now identifies a need for 2,188 hpa in South Warwickshire (1,126 hpa in Stratford and 1,062 hpa in Warwick); the policy direction appears to suggest that this is an absolute maximum, and that no further housing will be required beyond this. However, this is inconsistent with national policy, which is clear that the Standard Method establishes the minimum number of homes, not the maximum, needed per annum – it should be considered a starting point (NPPF §62). The Further Advice on Housing & Employment Land Needs
(February 2024) suggests, in Table 1.1, that 2,808 hpa may be required in South Warwickshire in the 5-year migration scenario, and Table 6.10 indicates that at least 2,772 hpa is needed to meet the total affordable housing need. Paragraph 2A-024 of the PPG states that higher housing figures may be needed where this could help deliver the required number of affordable homes (discussed further in Section 5). Therefore, the evidence base already highlights how a greater number of dwellings than 2,188 hpa may be required.
4.5.
Moreover, these figures do not factor in any unmet need from neighbouring authorities which may have to be accommodated in South Warwickshire under the duty to cooperate (NPPF §24) to ensure a positively prepared plan. NPPF §62 comments that needs which cannot be met within neighbouring areas should be considered in establishing the number of homes to plan for. This matter is discussed in more detail in relation to Policy Direction 4, but it underlines further with regards to Policy Direction 1, how the emerging policy must not treat 2,188 hpa as a maximum figure for housing delivery in South Warwickshire to 2050.
4.6.
For the SWLP Part 1 to be found sound, the plan will need to be effective, meaning that it must be deliverable over the plan period. It is thus necessary to establish whether 2,188 hpa is achievable in South Warwickshire. The evidence on past delivery in Stratford and Warwick suggests that this is the case, as shown in Table 1 below. In fact, completions across Stratford and Warwick have exceeded 2,188 hpa six times in the past eight years, peaking at 2,685 homes in 2021/22. This suggests that the Councils could, in fact, plan for more housing growth, which will help to meet the affordable housing need within South Warwickshire. Indeed, a failure to do so would be to fail to meet the Government’s prime housing objective of significantly boosting the supply of homes (NPPF §61).
4.7.
It is considered that setting a minimum figure of 2,188 hpa, equating to 54,700 homes over the plan period, in line with the SM and the provisions of national policy, would not undermine the deliverability of the plan. It will be critical for the Councils to identify and allocate a range of deliverable sites in the SWLP Part 1, to ensure a continuing rate of completions, which meet or exceed current local housing need, can continue to consistently be met over the plan period. 4.8.
Additionally, the policy direction assumes that 9,375 homes will be provided on windfall sites over the plan period. This is around a fifth of the overall supply. The Councils acknowledge, in Footnote 3, that the windfall figures are only “estimates [which are] subject to change”. A high-level analysis of recent monitoring reports indicates that the number of homes delivered on windfall sites significantly varies year-to-year. For example, Table 11 of the Authority Monitoring Report 2022-2023 for Stratford reveals that windfall delivery since 2011 has ranged from just 30 to 933dw/yr (albeit this covered a period where the Council had no 5YLS or up to date development plan policy and the ‘presumption’ applied). Sufficient land needs to be allocated for housing to provide flexibility in case fewer windfall sites are brought forward. To avoid the risk of any shortfalls in housing delivery, the Councils should avoid overreliance on a windfall allowance.
4.9.
To summarise, with regards to housing figures, it is considered that the policy direction as drafted is not positively prepared, justified, or consistent with national policy, in relying on out-of-date evidence to suggest that 1,679 hpa would be an acceptable annual housing requirement, and incorrectly treating the Standard Method’s 2,188 hpa as a maximum figure, secondary to the ageing HEDNA. To remedy this, the emerging policy should state that provision will be made for at least
2,188 hpa, requiring a minimum of 54,700 homes over the plan period. The evidence demonstrates that this is deliverable, with in excess of 2,188 completions in six of the last eight years across South Warwickshire,. Opting for this higher figure would support the effectiveness and Strategic Objectives of the plan.
4.10.
Notwithstanding the above, planning for an even greater number of homes is encouraged and would be strongly supported. The reasons for this are to:
1)
provide sufficient flexibility to allow for higher-growth scenarios as set out in the Further Advice on Housing & Employment Land Needs report (up to 2,808 hpa),
2)
address unmet need from neighbouring authorities,
3)
address potential uncertainty in the number of homes which will be delivered on windfall sites,
4)
secure the delivery of sufficient affordable homes to meet local need (from 2,772 hpa - discussed further under Policy Direction 10), and
5)
To significantly boost the supply of housing (NPPF§61)
4.11.
Such an approach would ensure that the objectively assessed housing need for South Warwickshire can be met in full. This is supported by the SA, which concludes that providing at least 2,188 hpa will have the most positive effects compared to the reasonable alternatives in terms of housing and supporting economic growth. Planning for this number of homes will align with the aspirations of the NPPF §§61 and 63.
b)
Housing Land Supply
4.12.
It is important to review the housing land supply within South Warwickshire in considering how many homes need to be planned for. The policy direction suggests that there are 17,068 existing commitments which will form part of the supply over the plan period.
Stratford District
4.13.
Stratford District Council claim to have a 24.65-year housing land supply as of 1st April 2024, as set out in their Information Sheet dated 16th October 2024. We strongly dispute the assertion that the Council can demonstrate this level of supply at the present time. As the current Core Strategy is over five years old from adoption, the five
-year housing land supply for Stratford needs to be measured against the housing need calculated using the SM, in accordance with the PPG. The updated SM has significantly increased the annual housing requirement within Stratford, from 553 hpa to 1,126 hpa (a 103.6% increase). The latest analysis from Landstack indicates that using the new Standard Method results in a housing supply of just 2.96 years.
4.14.
Stratford District Council have undertaken a Regulation 10A review which concluded that policies did not require updating provided the housing requirement was applied without reliance upon previous over-supply, such that Footnote 41 of the NPPF requires that the housing land supply is assessed against the adopted housing requirement. However, the Council are now deducting past over-supply when calculating the housing land supply position which is inconsistent with and undermines the conclusions of their Regulation 10A review. The review found that the adopted Core Strategy did not require updating on the provision that the adopted annual housing requirement for 637hpa continued to be applied from 2020 onwards, without being adjusted for past delivery.
4.15.
Regardless of this, there is a minimum local housing need of 1,126 hpa, which equates to a need for at least 5,630 homes over the period 2024-29. The latest assessment by Stratford suggests that 3,505 homes will be delivered from 2024-2029, meaning there is a demonstrable substantial need for 2,125 homes. This goes to highlight the need to plan for as much housing as possible, regardless of the Council’s latest putative housing land supply position.
Warwick District
4.16.
Meanwhile, Warwick District Council’s latest published position as of 1st April 2023 (published in their Housing Land Supply Position Document dated October 2023) suggests that there is a housing land supply of 7.16 years within the district. However, in an appeal decision related to the Warwickshire Police Headquarters in Long Wootton (ref. APP/T3725/W/23/3319752), dated 24 May 2024, the Inspector determined that Warwick only had a 4.01-year land supply, and a shortfall of 665 homes. The appeal decision clarified that Warwick should be assuming a 45% discount on their supply which is to meet Coventry’s needs, based on the spatial strategy of the adopted Warwick District Local Plan. Taking that position into account, the Inspector concluded that Warwick’s supply was 4,914 homes. Under the new Standard Method’s minimum local housing need (1,062
hpa), based on a five-year supply of 4,914 dwellings, Warwick only has a 4.62-year housing land supply at the present time.
4.17.
It is also important to emphasise that both Stratford and Warwick’s calculations are based on a number of assumptions regarding deliverability. The housing land supply figures may reduce further if sites do not deliver as expected, permissions expire without being implemented, or fewer windfall sites come forward than expected. This is acknowledged by Stratford District Council in paragraph 11 of their Housing Land Supply Information Sheet (October 2024).
4.18.
It is critical to ensure that a sufficient amount of housing is planned for in the SWLP Part 1. When measured against the new Standard Method in the 2024 NPPF, both Stratford and Warwick lack a five-year housing land supply (2.96 years and 4.62-years respectively), and as such the presumption in favour of sustainable development will apply, which may lead to a substantial number of speculative planning applications in locations which the Councils do not consider favourable for growth under the selected spatial strategy. Any under-delivery which may occur would result in an even lower supply. Specific and deliverable sites must be allocated for housing across South Warwickshire to ensure that there can be a steady supply of housing in Stratford and Warwick over the plan period, and certainly for five years following adoption, in line with NPPF §§ 72 and 78.
c)
Spatial Growth Strategy
4.19.
The Councils have confirmed that South Warwickshire’s housing need, as defined by Policy Direction 1, will be distributed across Stratford and Warwick through the ‘Sustainable Travel and Economy’ spatial growth strategy. Three ‘priority areas’ for growth are identified.
4.20.
There is a preference expressed to concentrate growth on brownfield sites and Priority 1 areas, prior to considering development elsewhere. However, it is important to emphasise that there is insufficient previously developed land within South Warwickshire to accommodate the level of housing and employment land required. The Urban Capacity Study (October 2022) highlights that there is only capacity for 6,145 dwellings on such sites – just 11% of the minimum housing need required over the plan period (54,700 dwellings). As such, the study concludes (on page 37) that it will be “impossible to meet development needs without significant greenfield development” in Stratford and Warwick (emphasis added). This is also acknowledged, to an extent, in the
Emerging Spatial Growth Strategy Topic Paper (November 2024).
4.21.
The identification of a myriad of Priority 2 and 3 areas, where development can occur in accordance with the spatial growth strategy, is supported, to ensure that needs can be fully met. Proportionate growth directed away from brownfield sites to settlements which are comparatively smaller than Stratford, Warwick, and Leamington Spa will also support their viability and vitality, whilst providing opportunities to enhance sustainable travel options at these locations, resulting in positive impacts on transport and accessibility (SA Objective 11), as acknowledged in Appendix E of the SA, §3.1.6.
4.22.
Twenty-four Strategic Growth Locations are identified, twenty-one of which would potentially accommodate housing. It is stated that these locations (which include Green Belt sites) could accommodate development which exceeds South Warwickshire’s housing need; Table 5.1 of the SA suggests that 74,521 homes could be provided – 46,264 above the highest ‘to find’ figure set out in Policy Direction 1. Three Strategic Growth Locations are identified to solely accommodate commercial development, amounting to 532.75 hectares of employment land, according to Table 5.1. These comprise Stoneleigh Park Employment (SG02), Coventry Airport (SG03), and Wedgnock Park Farm Employment (SG07).
4.23.
It is suggested that allocations will not be made in all areas given that this exceeds their housing and employment requirements. It is agreed that allocating land for 74,521 dwellings and 532.75 hectares for employment would be excessive, and the plan must be deliverable. Notwithstanding, the Councils clearly have an opportunity to allocate additional sites which will deliver housing and employment that extend beyond the minimum local need, to absorb any unmet needs from neighbouring authorities, in line with NPPF §§ 24, 62 which will allow for higher-growth scenarios, and provide flexibility to avoid potential future shortfalls in delivery. Until the need is fully identified, the Councils should keep all locations open for potential allocation.
4.24.
The SA assesses each of the Strategic Growth Locations against the SA Framework. All will have major positive impacts on SA Objective 9 (Housing), with the majority also having minor positive impacts on SA Objective 13 (Economy). Performance against the remaining objectives varies, but all Strategic Growth Locations will result in at least some minor and major adverse impacts, which inevitably arise from development on greenfield land, such as impacts on the landscape (SA Objective 4) and natural resources (SA Objective 7). 4.25.
The SA however, undervalues the positive contribution that residential development in South Warwickshire can make towards biodiversity (SA Objective 3) in providing an uplift over and above the existing baseline. The positive contribution towards transport and accessibility (SA Objective 11) is also not recognised for any of the options, despite the SA noting elsewhere, the benefits that development can bring in this respect. Those benefits include improving public transport options, thereby allowing for reduced car use, which in turn has positive impacts on Climate Change (SA Objective 1) (see Appendix E, § 3.1.6).
4.26.
The Site falls adjacent to the ‘East of Stratford-upon-Avon’ (SG19) Strategic Growth Location, whose identification is supported. It falls within Priority Area 3, which highlights that this is a sustainable and suitable location for growth, with development here aligning with the spatial strategy for South Warwickshire. SG19 has been assessed against the SA Framework and generally performs favourably. This is discussed in greater detail in Section 11 below.
4.27.
Land at Croft Farm has obvious potential to act as an extension to the SG19 allocation and form an integral part of it, displaying as it does, many of the locational sustainability benefits, which also accrue to SG 19.