Q-H6: Please select all options which are appropriate for South Warwickshire
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Q-H2.2: The Respondent considers that a consistent approach with regards to affordable housing should be applied across both Districts. Accordingly, of the options presented, Option H2-2a is probably the most appropriate in that it would appear to give the greatest certainty to developers and avoid making some areas more attractive than others. However, whatever the option that is settled upon it is imperative that the approach is thoroughly tested in terms of its viability and is appropriately justified. Q-H3: The Respondent agrees that should the Councils wish to impose minimum space standards that they should be adopted as development plan policy. The Councils’ aspiration to raise the standard of design of new homes in South Warwickshire is understood. However, given the notable unaffordability issues within the Warwick and Stratford Districts, where house prices are around 25% higher than the rest of the HMA, the Respondent has significant reservations regarding the imposition of space standards. Specifically, the respondent is concerned about the implication that such standards could have on the viability of sites, as well as the affordability of new homes, given that properties are generally valued and sold on a £ for square ft basis. Should the Council wish to introduce the application of Nationally Described Space Standards (NDSS) or optional Building Regulations M4(2)/M4(3) then Footnote 49 of the NPPF makes clear that the need for such standards needs to be justified. Further work will therefore need to be undertaken to demonstrate an appropriate justification. For the avoidance of doubt the Respondent would strongly object to the imposition of space standards beyond NDSS. Q-H5: The Respondent has experience of providing self-build plots on developments in other parts of the Country and would caution that there is often a disparity between the number of people that register an interest in such plots and those that will make a firm commitment and complete a purchase. As the Consultation Document points out, there are people who may express an interest for a self-build property but do not want to live within or on the edge of a new housing estate. In a largely rural authority, it is considered likely that the demand for self/custom build is for single plots on the edge of small villages/hamlets or on plots within the open countryside. A case-by-case approach as per that suggested under Option H5c would therefore seem most appropriate in South Warwickshire or for specific sites on the edge of existing settlements to be allocated specifically for this purpose where there is identified demand (Option H5a). If Option 5b is to be taken forward, then there must be the flexibility to revert self-build plots back to normal build plots once they have been marketed for an appropriate amount of time. The period of marketing required to demonstrate a lack of demand should not prevent the main developer from completing the self-build plots before the construction programme finishes, since it would not be desirable for developers to be left with vacant plots or for new residents to be subjected to construction activities for a prolonged period.
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Q-H6: We neither agree with or support any of the proposed emerging Options on pages 117 and 118 of the SWLP (2023). Consistent with our earlier representations to the SWLP Draft ‘Scoping and Call for Sites Report’ (May 2021) (Regulation 18) public consultation, we have concerns about the proposed planning policy approach being taken towards gypsy and travellers and travelling showpeople accommodation needs within the South Warwickshire Region within the emerging SWLP (2023). Unsustainable levels of pitch numbers are being proposed across South Warwickshire Region which will promote inappropriate, damaging and unsustainable patterns of development within the local area, and cause significant residential amenity conflicts with the existing settled community, as well as damage sensitive rural landscapes and wildlife habitats, and place unreasonable pressures on already constrained local road networks, existing healthcare and welfare facilities and local schools. We consider that Stratford-on-Avon and Warwick District Council’s proposed planning policy approach being taken forward within the emerging SWLP (Regulation 18) (January 2023) report on this issue conflicts with the following guidance: • Paragraphs 7, 8, 10, 11 (indent a), 16 (indent a) and 35 (indent d) of the Revised NPPF (July 2021) (which all reinforce the need for LPA’s to promote sustainable patterns of development). • Paragraphs 4 (indent k),10 (indent e), 13 and 23 of the Department for Communities and Local Government (DCLG) ‘Planning policy for traveller sites’ (August 2015). The approach being taken towards Local Plan preparation within the emerging SWLP Review is failing the ‘Sustainability’ tests of Soundness for Local Plan preparation as set out in paragraph 35 (indent d) of the Revised NPPF (2021). • The scale and number of pitch requirements needs to be significantly reduced within the emerging SWLP Review (2023). Proposed pitch requirements area far too excessive and unreasonable. • We would strongly encourage the LPA’s preparing the emerging SWLP to revisit this issue and prepare a new Gypsy and Traveller Accommodation Assessment (GTAA) supporting background technical evidence base document to inform the Local Plan preparation, which contains more realistic, more appropriate and deliverable pitch numbers. The current GTAA is not fit for purpose and fails to respond effectively to the unique characteristics of South Warwickshire Region in terms of its special heavily rural countryside and historic landscapes. • This scale of growth in new high pitch numbers being proposed would appear to be more appropriate and suitable within a very large urban area rather than small, heavily rural districts. • The future expansion needs of these new pitches (those proposed gypsy and traveller sites allocations being brought forward through the emerging SWLP Review) and the worsening landscape impacts as they further expand and grow in future years within rural countryside has been given no planning policy consideration whatsoever by Stratford-on-Avon and Warwick District Council’s Planning Policy Teams. This underlines the ongoing failure and continued incompetence being taken towards this sensitive and critically important planning policy topic matter within the emerging SWLP Review. The one-size-fits-all naïve Planning Policy approach to Local Plan-preparation is causing huge levels of damage within the local area. • The sustainability implications of this huge scale of growth in new pitch numbers is highly concerning. • We have concerns about the “incapable” management and leadership approach being taken towards Local Plan-preparation by the Council’s Planning Policy Team with regards to gypsy and traveller Planning Policy matters. • The ‘level of scale of growth’ in new pitch numbers across the Districts being proposed is very concerning in terms of the impacts of this scale of growth on the District’s continued future tourism and historic environment offer, and potential for considerable adverse and damaging landscape impacts within areas of open heavily rural countryside, and areas of historic landscape. • These proposals will have long standing damaging economic impacts on the local tourism industry within the Stratford-on-Avon District during the post-COVID-19 fragile local economic recovery, at a time when the local economy is facing one of the worst economic recessions of a scale and severity not experienced for the last 300 years. The level of harm that the Council’s Planning Policy Teams policies on this matter is causing to local businesses which rely on tourism income is concerning. • The potentially considerable, adverse and highly damaging impacts of this proposed scale of growth on the Local Plan areas local distinctiveness and unique character. • Careful ongoing dialogue is required between the LPA and affected local communities within the South Warwickshire Region so this scale of growth in new pitch numbers can be more carefully considered with local communities in accordance with advice in paragraph 16 (indent c) of the Revised NPPF (2021). • The impacts of this proposed scale of growth on existing sensitive small rural village settlements which lack the range of services, facilities and highway infrastructure necessary to accommodate this proposed scale of growth in new pitch numbers. • The potentially huge, adverse and highly damaging residential amenity impacts on the existing settled community. • The damaging landscape impacts on the District’s heavily rural open countryside. • This scale of growth in new pitch numbers does not appear to be sustainable in a heavily rural area, dominated by very small rural village settlements, within areas of remote countryside. • In its current format and proposed planning policy approach, the position is perfectly clear, the emerging SWLP Issues and Options Stage Report (January 2023) is promoting inappropriate, damaging and unsustainable patterns of development within the local area, contrary to the above NPPF and DCLG guidance. • Lockley Homes particularly objects to any proposals to encourage new Gypsy and Traveller and Travelling Showpeople sites within the western part of the Stratford-on-Avon District, within areas of remote and isolated heavily rural countryside, within the vicinity of the Village of Broom and Bidford-on-Avon small village settlements. Given this areas heavily rural character, this wider location should be fully removed and excluded from the new gypsy and traveller sites search zone within the emerging SAP and SWLP Local Plan Reviews. • The Council’s Planning Policy position and stance on this matter, is having a damaging impact on the local area. The LPA appears keen and determined to promote unsustainable patterns of development across the district within the emerging SAP and SWLP Local Plan Reviews. • ‘Sustainability principles’ should underpin and form the planning policy backbone and should be at the heart of any site selection approach taken by the LPA in the both the emerging Local Plan Review (2022) and the Council’s background technical evidence being used to support Local Plan Policy, such as the GTAA. • More needs to be done to stop Stratford-on-Avon and Warwick District Council’s Planning Policy Teams from causing huge levels of environmental damage within the South Warwickshire countryside by introducing significant levels of inappropriate harmful urbanising gypsy and traveller development within areas of open countryside. Which will result in highly damaging and adverse impacts affecting the residential amenity of the existing settled community, as well as damage the area’s tourism offer and sensitive historic rural landscapes. Further comments re Q-H6: We neither agree with or support any of the proposed emerging Options on pages 117 and 118 of the SWLP (2023). Consistent with our earlier representations to the SWLP Draft ‘Scoping and Call for Sites Report’ (May 2021) (Regulation 18) public consultation, we have concerns about the proposed planning policy approach being taken towards gypsy and travellers and travelling showpeople accommodation needs within the South Warwickshire Region within the emerging SWLP (2023). We consider that Stratford-on-Avon and Warwick District Council’s proposed planning policy approach being taken forward within the emerging SWLP (Regulation 18) (January 2023) on this issue conflicts with the following guidance: • Paragraphs 7, 8, 10, 11 (indent a), 16 (indent a) and 35 (indent d) of the Revised NPPF (July 2021) - which all reinforce the need for Local Planning Authorities to promote the most sustainable patterns of development when preparing emerging Local Plan Reviews. • The scattered distribution of gypsy and traveller sites across a large area (including areas of open countryside) is promoting heavily unsustainable patterns of development, contrary to the above NPPF guidance. • The sustainability implications of this scale of growth in new pitch numbers is concerning. • Paragraphs 4 (indent k),10 (indent e), 13 and 23 of the DCLG ‘Planning policy for traveller sites’ (August 2015). • The ‘level of scale of growth’ in new pitch numbers across the South Warwickshire countryside being proposed within the emerging SWLP is very concerning in terms of the impacts of this scale of growth on the district’s historic rural landscapes, areas of natural green space, environment offer, and potential for considerable adverse and damaging landscape impacts within areas of open heavily rural countryside. • The damage to the areas local economy, such as the tourism industry. • The potentially considerable, adverse and damaging impacts of this proposed scale of growth on the Local Plan areas local distinctiveness and unique character, and sensitive rural landscapes. • We have concerns about the “incapable” management and leadership approach being taken towards Local Plan-preparation with regards to gypsy and traveller Planning Policy matters. • Careful dialogue is required between the LPA and affected local communities within the SWLP coverage area so this scale of growth in new pitch numbers can be more carefully further explored with local communities - in accordance with advice in paragraph 16 (indent c) of the Revised NPPF (2021), which reinforces that: “…Plans should (indent c) be shaped by early, proportionate and effective engagement between plan-makers and communities…” • The impacts of this proposed scale of growth on existing sensitive small rural village settlements which severely lack the range of services, facilities (schools, healthcare facilities, welfare facilities) and highway infrastructure necessary to accommodate this proposed scale of growth in new pitch numbers. • Both the emerging SWLP Local Plan (2023) and the accompanying Gypsy and Traveller supporting background technical evidence base are both promoting highly unsustainable patterns of environmentally damaging development across the South Warwickshire Region. • The potentially huge adverse and highly damaging residential amenity impacts on the settled community raises concerns has not been given sufficient material planning consideration within the emerging SWLP. • The highly damaging landscape impacts on the South Warwickshire Districts heavily rural open countryside. • The future expansion needs of these new pitches (allocated gypsy and traveller sites) and the worsening landscape impacts as they expand and grow in future years within rural countryside has all been given an insufficient level of Planning Policy consideration by the LPA’s. • This scale of growth in new ‘high pitch numbers’ being proposed would appear to be more appropriate and suitable within a large heavily urbanised area rather than a small, heavily rural Districts characteristic of South Warwickshire. • This scale of growth in new pitch numbers does not appear sustainable in a heavily rural area, dominated by small rural village settlements, within remote areas of countryside. • In its current format and proposed planning policy approach, the position is perfectly clear, the emerging SWLP (January 2023) is promoting inappropriate, damaging and unsustainable patterns of new gypsy and traveller development within the local area, contrary to the above NPPF (2021) and DCLG guidance. • ‘Sustainability principles’ should underpin and form the planning policy backbone and should be at the heart of any site selection approach taken by the LPA’s in the both the emerging SWLP Local Plan Review (2023) and the Council’s accompanying GTAA background technical evidence being used to inform and support Local Plan preparation. • More needs to be done to stop Stratford-on-Avon District Council’s Planning Policy Team from causing huge levels of environmental damage within the local area, by introducing significant levels of inappropriate harmful urbanising gypsy and traveller development within sensitive open countryside locations. Which will result in highly damaging and adverse impacts affecting the residential amenity of the existing settled community, as well as damage the area’s unique rural identity, tourism offer and historic countryside landscapes. Conclusion Unsustainable levels of pitch numbers are being proposed across South Warwickshire which will promote inappropriate, damaging and unsustainable patterns of development within the local area, and cause significant residential amenity conflicts with the existing settled community, as well as damage sensitive rural landscapes and wildlife habitats, and place unreasonable pressure loads on road infrastructure, existing healthcare and welfare facilities, and local schools. The Council’s SWLP ‘Issues and Options Stage Report’ (Regulation 18) (January 2023) is promoting both irresponsible and unsustainable patterns of development across the district’s, in direct conflict with the ‘Sustainability’ test of ‘Soundness’ for Local Plan preparation as reinforced within paragraph 35 (indents d) of the Revised NPPF (2021). Q-H7: Lockley Homes strongly objects to the Council's proposals to bring forward small and medium-sized housing sites within the proposed Stage 2 SWLP, and not Stage 1. Stage 1 is proposing to bring forward only major strategic housing site allocations. In accordance with paragraph 69 of the Revised NPPF (2021), smaller housing site allocations (smaller and medium-sized land parcels) should be brought forward as a matter of urgency, not left for many years ahead within a Stage 2 SWLP. Paragraph 69 of the Revised NPPF (2021) attaches importance to the urgent delivery of small and medium sized sites. It confirms that: “…Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. To promote the development of a good mix of sites local planning authorities should: (indent c) support the development of windfall sites through their policies and decisions – giving great weight to the benefits of using suitable sites within existing settlements for homes...” Lockley Homes maintains its view that new housing development sites coming forward within the South Warwickshire Region, within the most sustainable site locations, should be strongly encouraged and prioritised for new housing development first, before other less sustainable site locations are brought forward within the emerging Local Plan Review, and should be considered very favourably within the Local Plan Review process without unnecessary delay. In order to help meet the urgent housing needs of local communities within the South Warwickshire Region, and to help address continuing long-standing housing shortfalls present across the SWLP Local Plan area. This approach to Plan-preparation strongly accords with current Government policy which is now governed by a pro-growth National Planning Policy Framework, which gives a presumption in favour of sustainable development, and guidance in paragraph 60 of the Revised NPPF (2021), which emphasises the need for LPA’s to significantly boost the supply of new homes across the United Kingdom within the most sustainable site locations. The need for LPA’s to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews is reinforced within paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021). Competent Local Planning Authorities should already be aware of this NPPF guidance when preparing emerging Local Plan Reviews. In accordance with guidance reinforced in paragraph 79 of the Revised NPPF (2021), Lockley Homes would suggest that the Council’s preparing the emerging SWLP (2023) should consider the future housing-led growth and expansion needs of existing rural village settlements located across the South Warwickshire Region. This matter should be one of the key spatial planning policy priority areas for the emerging SWLP Local Plan Review to consider, as a matter of urgency, in order to help deliver a ‘More Positively Prepared Local Plan,’ and promote the most sustainable patterns of new housing development - consistent with guidance in paragraph 35 (indent a and d) of the Revised NPPF (2021), and to help the SWLP respond positively to requirements of paragraphs 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF discussed below. Paragraph 79 of the Revised NPPF (2021) is perfectly clear in its view that: “…To promote sustainable development in rural areas, housing should be located where it would enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive…” Paragraph 120 (indent d) of the Revised NPPF (2021) confirms that: “…Planning policies and decisions should: (indent d) promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively …” Paragraph 141 (indent a) of the Revised NPPF (2021) underlines the importance and expects LPA’s to encourage the use of under-utilised land for new housing development. Such as low-quality green space areas and derelict and under-utilised former paddock land, located both within and bordering existing rural village settlements, in order to help promote the most sustainable site locations for new housing development. It emphasises that these highly sustainable site locations should be prioritised first for new housing development, before LPA’s introduce changes to the Green Belt boundaries, and before LPA’s identify sites for new housing development within the existing designated Green Belt countryside. This spatial planning policy approach to Local Plan-preparation is required in order to help protect the Green Belt countryside from development encroachment pressures, and to help promote sustainable patterns of development as stated above. It states that: “… Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph, and whether the strategy: (indent a) makes as much use as possible of suitable brownfield sites and under-utilised land…” Further support for the Lockley Homes site is provided by paragraph 142 of the Revised NPPF (2021), which confirms that: “…When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policy-making authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport…” Highly sustainable infill site locations (within areas of under-utilised low quality green space (such as former paddock land), located outside of the designated Green Belt), which display strong physical connections to the existing village settlement core and main village High Street, characteristic of the Lockley Homes site (see robust and defendable photographic evidence in photographs 1 and 2 in Appendix B of this SWLP Representations Statement), should be prioritised first as a matter of urgency for new housing development. Before the LPA’s preparing the emerging SWLP Review select unsustainable site locations for new housing development. Located within areas of open Green Belt countryside, in free-standing new housing settlements, located far away from existing rural village settlements, and far away from existing towns. Competent Local Planning Authorities should already be aware of above various NPPF guidance, and the need to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. We have ongoing concerns about Stratford-on-Avon District Council’s Planning Policy Teams unwillingness, ongoing failure and continued refusal to wanting to promote the most sustainable patterns of new housing development across the Stratford-on-Avon District (such as the sustainably-located Lockley Homes site) within the emerging Local Plan Review. This highly obstructive planning policy approach, and ongoing failure and continued incompetence being taken towards Local Plan-preparation, means that the emerging SWLP Local Plan Review (2023), even at this very early stage in its Local Plan preparation, is already currently failing the ‘Sustainability’ test for Local Plan preparation tests of ‘Soundness’. As set out within paragraph 35 (indent d) of the Revised NPPF (2021). The emerging SWLP Plan (2023), alongside its sister document Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP), are both therefore vulnerable to future Legal challenge at the later Examination in Public (EIP) stage. Given their continued failure and ongoing refusal to promote the most sustainable patterns of new housing development across the South Warwickshire Region. As a key local stakeholder, we are just needing to highlight these critically important Local Plan ‘Soundness’ issues to try and help the Council’s Planning Policy Team improve its approach to future Local Plan making. For the reasons set out within this response, we have concerns about the “incapable” management and leadership approach being taken towards Local Plan preparation within the Stratford-on-Avon District As stated above, we have particular concerns in relation to the Planning Policy approach being taken towards Local Plan preparation within Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) (2022/ 2023). Given that the Council throughout the various SAP Plan-preparation stages is continuing to overlook more sustainable site locations for new housing development, which are located outside of the existing designated Green Belt, and which have good strong physical connections to existing rural village settlement cores. Such as the sustainably-located Lockley Homes site – supported by robust and defendable photographic evidence in Appendix B of this SWLP Representations Statement. Stratford-on-Avon District Council’s Planning Policy Team is showing a very strong level of support and notably biased favouritism towards these significantly less sustainable site locations by prioritising the delivery of new housing development sites located in isolated and very peripheral farmland locations. Distantly located away from the main existing village settlement cores, in areas of distantly located farmland countryside, on the very outer fringes and periphery of existing rural village settlements. This incompetent approach being taken towards Local Plan preparation within the Stratford-on-Avon District is in direct conflict with paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021). Which all expect LPA’s to promote the most sustainable patterns of new housing development when preparing Local Plan Reviews. This underlines the ongoing failure and continued incompetence being taken towards Local Plan preparation within the Stratford-on-Avon District by the Council’s Planning Policy Team. Our concerns on these issues are already covered in extensive detail within our earlier Representations to Stratford-on-Avon District Council’s emerging SAP. It is important that these ongoing failings discussed above are now addressed within the emerging SWLP Review, and its remaining ongoing Plan-preparation stages.
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Are there any strategic cross boundary issues that need to be addressed and/or delivered through the South Warwickshire Local Plan (SWLP)? Yes. Coventry City Council has a long history of working positively and proactively with partners, including Stratford on Avon and Warwick District Councils on a series of cross boundary issues under the statutory Duty to Co-operate. The partnership is known as the Coventry, Solihull & Warwickshire Association of Planning Officers (CSWAPO) which meets monthly and which has a series of sub-groups based upon identified strategic issues: • Growth (housing and employment) • Critical Infrastructure • Transport • Water • Environment The groups have worked together to commission and produce joint evidence (eg the HEDNA, SFRA, Green Infrastructure) and engage with wider partnerships across the region (eg looking at evidence on larger employment logistics sites). Addressing strategic growth needs is a key issue under the DtC. Coventry has long been unable to accommodate its identified needs, particularly in relation to housing and employment and has received considerable support in relation to its adopted 2017 Local Plan in accommodating a significant proportion of the unmet need. The commitment was set out in a Memorandum of Understanding for Coventry and Warwickshire (separate MoUs for Housing and for Employment). Coventry City Council has just embarked upon the process of reviewing its Local Plan which will be informed by the HEDNA. Work to assess the situation is currently underway and Coventry City Council will be consulting on Issues and Options in summer 2023. Housing and employment growth needs will need to be a key element of the DtC deliberations as the SWLP and Coventry Plan reviews progress and Statements of Common Ground will need to be prepared. Other strategic matters have been highlighted above and discussions will continue at CSWAPO as to how best to manage these, once evidence is available.
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Q-H2-2: Please select the option which is most appropriate for South Warwickshire: We consider Option H2-2b; providing a separate affordable housing requirement for Stratford-on-Avon and Warwick Districts, would be appropriate in terms of reflecting local requirements and local viability calculations. However, it is considered that the tenure and type of affordable homes sought should be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. L&Q Estates support a collaborative approach to identifying site-specific affordable housing requirements, including tenure and type of affordable homes to be provided on-site. Q-H3: Please select all options which are appropriate for South Warwickshire L&Q Estates have no objection to a requirement to meet optional Building Regulations M4(2)/M4(3) in principle (Option H3c). It is considered that this should be achieved by requiring a certain proportion of homes on sites in medium or higher value zones to meet the optional standards. However, we reserve the right to comment further at a later stage, once the specific requirements for sites have been clearly defined. Q-H5: Please select all options which are appropriate for South Warwickshire Whilst it is considered that Option H5a would enable the South Warwickshire Authorities to group this type of housing together in small sites in various locations, such an approach would be dependent on landowners putting sites forward for this type of housing. Therefore, this approach may not provide sufficient suitable development permissions to meet the identified demand in accordance with the duties under sections 2 and 2A of the Self Build and Custom Housebuilding Act 2015. We consider Option H5b is appropriate for South Warwickshire, provided it can be demonstrated that there is currently a need for self-build and custom build plots identified in the self-build and custom build register for the local authority where the site is located. The proportion of self and custom-build plots to be made available within large sites should be sufficient to match the current number on the register. Such an approach would align with the aims of Paragraph 62 of the NPPF in terms of providing opportunities for people wishing to commission or build their own homes. It is considered that any policy under Option H5b should also include a fall-back option of reverting any unsold self-build plots to the developer to build, should any of these plots not be sold after an appropriate marketing period (of, say, 12 months, for example).
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H3 There is a need for smaller housing. There are often too many large houses ( clearly the developers preferred financial option) They are often built too close together on estates with poor road access .....too narrow. Cars are forced to park outside the houses because of lack of garages and to park on the pavements thereby clogging up the roadway. A variety of different sizes and types of houses should be available. Affordable and bungalows should be incorporated into the plans. H6 The need for the location of gypsy and travellers sites will have to be looked at carefully, whether permanent or transitory. Kenilworth has sadly been adversely affected by transient gypsy encampments, namely the field where the new development of Kenilworth Gates is taking place. The actions of a few of the traveller/gypsy communities when staying on this site demonstrated a worrying increase in crime.....house and shop thefts plus local pubs/ restaurants sometimes shutting in fear of potential trouble.Kenilworth no longer has an active police station which had ramifications for monitoring and affectively policing the situation. Many residents of Kenilworth used to dread the dates when the travellers / gypsies were due to arrive. Whilst ticking the box for inclusivity the above mentioned issues should be addressed. These are real problems that must not be ignored.
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Q-H3: Whilst the provision homes of an appropriate range and size is supported, William Davis are concerned that the blanket application of Nationally Described Space Standards across South Warwickshire could significantly and negatively impact viability in areas with high levels of unaffordability. There are already substantial existing and emerging policy and building regulations requirements (e.g. biodiversity net gain and future homes standard), combined with fluctuations in the housing market and construction costs that are impacting development viability. The cumulative effects of all proposed plan policies will need to be viability tested, in accordance with national policy. The result may be a choice between policies such as minimum space standards and a lowering of the affordable housing requirement relative to existing expectations.
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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. 4.15. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified”. 4.16. Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 'Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.' 4.17. If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4.18. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan 4.19. This is discussed in answer to Question H1-1. Q-H5: Please select all options which are appropriate for South Warwickshire 4.20. As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016-20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. 4.21. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. 4.22. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. 4.23. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. 4.24. The emerging Stratford Site Allocations Plan (SAP) has identified specific sites to deliver selfbuild and custom housing through allocations. It is suggested that the South Warwickshire Local Plan should continue this approach, bring forward the allocations the SAP identified in the most recent Preferred Options document and identify similar suitable sites in Warwick District to ensure a spread across the plan area.
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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. 4.15. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified”. 4.16. Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 'Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.' 4.17. If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4.18. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan 4.19. This is discussed in answer to Question H1-1. Q-H5: Please select all options which are appropriate for South Warwickshire 4.20. As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016-20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. 4.21. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. 4.22. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. 4.23. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. 4.24. The emerging Stratford Site Allocations Plan (SAP) has identified specific sites to deliver self-build and custom housing through allocations. It is suggested that the South Warwickshire Local Plan should continue this approach, bring forward the allocations the SAP identified in the most recent Preferred Options document and identify similar suitable sites in Warwick District to ensure a spread across the plan area.
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In conclusion there are several potential growth settlements and villages appropriately categorised within the emerging local plan evidence base which can accommodate the local and wider HMA requirements, notably Stratford-on-Avon’s ability to part meet consistent under delivery within the Birmingham and Black Country HMA. A key example is Bidford-on-Avon where the settlement can support growth through its good sustainable connectivity and its local amenities and services. The South Warwickshire plan should uplift their housing targets to address this unmet demand, particularly where there is evident capability to deliver on sustainably located sites in established settlements. There remains the opportunity therefore to allocate land which would substantially increase delivery capacity, providing a range of house types and tenures, helping to bridge the affordability divide whilst simultaneously supporting job creation, leisure and retail provision.
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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. This would be dependent on being able to evidence a need for these requirements across South Warwickshire, without having an unacceptable impact on affordability of properties. It may be considered strategically important when considering the capacity of strategic sites. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified.” Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 'Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.' It is clear that the introduction of the NDSS requires a Local Plan policy which has been fully evidenced, justified and viability tested. If NDSS is subsequently justified and pursued, the policy should be sufficiently flexible to recognise that well-designed house types which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. This would be dependent on being able to evidence a need for these requirements across South Warwickshire, without having an unacceptable impact on affordability of properties. It may be considered strategically important when considering the capacity of strategic sites. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. Should the council be minded to implement a policy relating to specific delivery of accessible homes, for example through the delivery of a percentage of housing on site to meet these standards, there would need to be suitability evidence to demonstrate that there is a need. The provision of such accommodation should be taken into consideration with regards to viability and build costs. Q-H5: Please select all options which are appropriate for South Warwickshire As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016-20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. The HEDNA evidence and Self-Build Register for both authorities should form part of the evidence base that informs any emerging policies that deal the delivery of selfbuild/custom plots on applications for residential development. If the Plan is going to require a % of self-build plots this must reflect current evidence of need. Lone Star Land support the provision of larger sites providing an element of self-build and custom build sites within a percentage of development. However, from their experience and established knowledge of the South Warwickshire area, the demand for self-build and custom build sites are predominantly located within the edge of existing villages and settlements. Therefore, there will be a need for the plan to provide an appropriate proportion of custom and self-build plots in the most viable and appropriate locations which will be deliverable in the plan period. It is considered appropriate to make policy provision for smaller sites, exclusively for custom and self-build, to be delivered within or on the edge of individual settlements where appropriate. Not all Custom self-build demand is for properties on larger residential schemes, that are otherwise being delivered by national housebuilders. Further, if there is a policy requiring self/custom build on major sites then it is nevertheless submitted that it should include a mechanism to allow for such plots to come forward for market housing if demand is subsequently found to be absent. For example, if serviced plots for self-build and custom housebuilding have been made available and marketed for a set period of time at an agreed "market price" andhave not sold, plots can be used for delivery of general market housing
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Q-H1-1: This section details Kingacre’s position with regard to the scale of housing need within South Warwickshire. In determining the appropriate Housing Requirement for the South Warwickshire Plan, the discussion covers three core themes: a) the calculation of Local Housing Need, b) unmet need arising outside of South Warwickshire & the Duty-to-Cooperate, and c) the need for affordable housing. Calculating Local Housing Need 3.2 In considering ‘Issue H1: Providing the right number of new homes’, the SWLP identifies that the strategic policies contained within the emerging local plan should be informed by an assessment of Local Housing Need (‘LHN’). 3.3 After setting out the Government’s Standard Method for calculating LHN, the SWLP identifies that the calculation utilises 2014-based population projections, which are considered to be problematic for several reasons. To address these issues, the SWLP proposes to employ a revised version of the Standard Method, based on more up-to-date demographic (provided in the Census 2021 data) and market data, to calculate the housing need for the area. 3.4 In accordance with national planning practice guidance (‘PPG’), the Standard Method of calculating Local Housing Need for the Coventry and Warwickshire Housing Market Area (‘HMA’) results in an identified need of 5,554 dwellings per annum (‘dpa’). Subsequently, the SWLP identifies, at Table 9, that the LHN figure for Stratford-on-Avon district is 564 dpa, whereas for Warwick district it is 675 dpa. 3.5 However, the SWLP proposes to implement an alternative assessment of housing need, based on the recently published Housing and Economic Development Needs Assessment (‘HEDNA’) (2022), which covers the Coventry & Warwickshire Housing Market Area. Based on an assessment of demographic and market data over the previous decade, the HEDNA provides trend-based projections that identify a need for 868 dpa for Stratford-on-Avon and 811 dpa for Warwick. These are set against reductions in the assessed need for other areas within the sub-region; in particular, for Coventry. 3.6 Significantly, the ‘trend-based’ assessment of housing need derived from the HEDNA provides for an increased annual housing need figure for both districts; an additional 304 dpa in Stratford-on-Avon district and 136 dpa for Warwick district, over the plan period. This represents a significant uplift when compared with the 2014-based projections. Planning Practice Guidance (‘PPG’) provides that: Where a strategic policy-making authority can show that an alternative approach identifies a need higher than using the standard method, and that it adequately reflects current and future demographic trends and market signals, the approach can be considered sound as it will have exceeded the minimum starting point2 . 3.8 PPG confirms that the proposed departure from the 2014-based household projections represents a departure from the ‘Standard Method’. However, Kingacre considers that the approach detailed within the SWLP, consisting in the adoption of the ‘trend-based’ housing need figure derived from the HEDNA (2022), represents a sound alternative approach as per the requirements of the PPG set out above. 3.9 PPG clarifies that exceptional circumstances are required to justify an alternative approach where the approach results in a lower housing need than that identified using the standard method. However, given that the proposed approach results in a higher figure than the standard method calculation does for both individual district areas, this is not required. 3.10 In summary, Kingacre supports the proposed trend-based approach to assessing housing need within the South Warwickshire area, for the reasons set out above. Furthermore, Kingacre agree that the evidence presented within the HEDNA (2022) represents a reasonable basis for identifying future levels of housing need across South Warwickshire. Sustainability Appraisal of Alternative Policy Options 3.11 The Sustainability Appraisal (‘SA’) prepared to support the Issues and Options consultation assesses the two alternative housing numbers identified through the discussion above; namely, the 2014-based and HEDNA-based LHN figures: 1. Option 1 – Census 2021-based ‘HEDNA’ calculation: 868 dpa in Stratford-on-Avon and 811 dpa in Warwick. Combined total of 1,679 dpa. 2. Option 2 – 2014-based ‘Standard Method’ calculation: 564 dpa in Stratford-on-Avon and 675 dpa in Warwick. Combined total of 1,239 dpa. At paragraph N31, the SA concludes that: Pursuing either of the options would result in a major positive impact on SA Objective 9 (Housing) as it is expected that the proposed housing numbers would largely cater to the housing needs of residents, including delivering affordable homes, student accommodation, older persons accommodation, specialist accommodation and self and custom build housing, along with the accommodation needs of gypsy and traveller and travelling showpeople communities. 3.13 However, the SA notes that taking forward the LHN figure derived through the HEDNA should more accurately represent local housing needs than the Standard Method-derived figure, for the reasons set out previously in these representations. The SA concludes therefore that implementing Option 1 as the housing requirement for the SWLP should assist in meeting the housing needs of the local communities more successfully. 3.14 Beyond the additional benefit that Option 1 provides toward SA Objective 9 (housing), the SA concludes that the performance of either Option 1 or Option 2 is relatively indistinct in relation to the remainder of the SA objectives. Kingacre supports this conclusion.
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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. 4.15. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified”. 4.16. Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 'Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.' 4.17. If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4.18. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan 4.19. This is discussed in answer to Question H1-1. Q-H5: Please select all options which are appropriate for South Warwickshire 4.20. As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016-20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. 4.21. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. 4.22. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. 4.23. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. 4.24. The emerging Stratford Site Allocations Plan (SAP) has identified specific sites to deliver self-build and custom housing through allocations. It is suggested that the South Warwickshire Local Plan should continue this approach, bring forward the allocations the SAP identified in the most recent Preferred Options document and identify similar suitable sites in Warwick District to ensure a spread across the plan area.
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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. 4.15. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified”. 4.16. Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 'Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.' 4.17. If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4.18. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan 4.19. This is discussed in answer to Question H1-1. Q-H5: Please select all options which are appropriate for South Warwickshire 4.20. As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016-20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. 4.21. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. 4.22. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. 4.23. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. 4.24. The emerging Stratford Site Allocations Plan (SAP) has identified specific sites to deliver selfbuild and custom housing through allocations. It is suggested that the South Warwickshire Local Plan should continue this approach, bring forward the allocations the SAP identified in the most recent Preferred Options document and identify similar suitable sites in Warwick District to ensure a spread across the plan area.
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Q-H3: Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. 4.15. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified”. 4.16. Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 'Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.' 4.17. If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4.18. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H4-2: This is discussed in answer to Question H1-1. Q-H5: As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016- 20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. 4.22. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. 4.23. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. 4.24. The emerging Stratford Site Allocations Plan (SAP) has identified specific sites to deliver selfbuild and custom housing through allocations. It is suggested that the South Warwickshire Local Plan should continue this approach, bring forward the allocations the SAP identified in the most recent Preferred Options document and identify similar suitable sites in Warwick District to ensure a spread across the plan area. In addition to a percentage delivery on large sites. It is also considered appropriate to make policy provision for smaller sites, exclusively for custom and self-build, to be delivered within or on the edge of individual settlements where appropriate. Not all Custom self-build demand is for properties on larger residential schemes, that are otherwise being delivered by national housebuilders.
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Q-H2.2: Option H2-2a: A single South Warwickshire wide affordable housing requirement It would seem sensible for a common approach to be the starting point. Q-H3: Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. This should be the starting point although we do not understand what, “based on locally derived evidence means”. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. This approach would be supported but needs to be applied flexibly because of potential impacts on design and viability. Q-H5: Option H5c: Rely on a case-by-case approach whereby planning applications for self and custom build homes will be assessed against a range of criteria to determine their suitability. This would seem to be the most appropriate option with support where there is either an identified shortfall across the plan area generally or specifically where a shortfall within a specific locality.
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Q-H2.2: Option H2-2a: A single South Warwickshire wide affordable housing requirement It would seem sensible for a common approach to be the starting point. Q-H3: Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. This should be the starting point although we do not understand what, “based on locally derived evidence means”. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. This approach would be supported but needs to be applied flexibly because of potential impacts on design and viability. Q-H5: Option H5c: Rely on a case-by-case approach whereby planning applications for self and custom build homes will be assessed against a range of criteria to determine their suitability. This would seem to be the most appropriate option with support where there is either an identified shortfall across the plan area generally or specifically where a shortfall within a specific locality.
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Issue H1: Providing the right number of new homes: I do not have any faith in the methodology used to produce the claim that Coventry and Warwickshire will need 1,600 homes built every year until 2050.
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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. 4.15. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified”. 4.16. Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 'Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.' 4.17. If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4.18. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan 4.19. This is discussed in answer to Question H1-1. Q-H5: Please select all options which are appropriate for South Warwickshire 4.20. As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016-20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. 4.21. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. 4.22. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. 4.23. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. 4.24. The emerging Stratford Site Allocations Plan (SAP) has identified specific sites to deliver selfbuild and custom housing through allocations. It is suggested that the South Warwickshire Local Plan should continue this approach, bring forward the allocations the SAP identified in the most recent Preferred Options document and identify similar suitable sites in Warwick District to ensure a spread across the plan area.
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Q-H5 - Option H5a: Identify a range of specific sites within or on the edge of existing settlements of approximately 5-20 homes in size to be developed only for self and custom build homes. 66. Rosconn Strategic Land support Option H5a, and the identification of a range of sites. Stratford-on-Avon District Council has already identified suitable and sustainable sites for allocation for self and custom build homes as part of its emerging SAP, and there is no need for the Councils to undo the work already undertaken.
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Q.H.3 Please select all options which are appropriate for South Warwickshire Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. The emerging plan correctly recognises that Nationally Described Space Standards should not automatically be included within emerging plans. Footnote 49 of the NPPF advises that Nationally Described Space Standards can only be applied through policies where the need can be “justified”. The PPG provides guidance on the evidence that is required to “justify” space standards. The Draft Plan advises that at this point in the plan process the Councils have not gathered evidence on the need for and benefit of, including Locally Described Space Standards. There is, therefore, currently no evidence to support the inclusion of such a policy.
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Q.H.3 Please select all options which are appropriate for South Warwickshire Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. The emerging plan correctly recognises that Nationally Described Space Standards should not automatically be included within emerging plans. Footnote 49 of the NPPF advises that Nationally Described Space Standards can only be applied through policies where the need can be “justified”. The PPG provides guidance on the evidence that is required to “justify” space standards. The Draft Plan advises that, at this point in the plan process, the Councils have not gathered evidence on the need for and benefit of, including Locally Described Space Standards. There is, therefore, currently no evidence to support the inclusion of such a policy. In terms of introduction of M4(2) and M4(3) standards, these are building regulation requirements. It is highly likely that new building regulations will be put in place by the time the SWLP is adopted. There should not be dual regulatory control.
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Q.H.3 Please select all options which are appropriate for South Warwickshire Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. The emerging plan correctly recognises that Nationally Described Space Standards should not automatically be included within emerging plans. Footnote 49 of the NPPF advises that Nationally Described Space Standards can only be applied through policies where the need can be “justified”. The PPG provides guidance on the evidence that is required to “justify” space standards. The Draft Plan advises that, at this point in the plan process, the Councils have not gathered evidence on the need for and benefit of, including Locally Described Space Standards. There is, therefore, currently no evidence to support the inclusion of such a policy. In terms of introduction of M4(2) and M4(3) standards, these are building regulation requirements. It is highly likely that new building regulations will be put in place by the time the SWLP is adopted. There should not be dual regulatory control.
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Issue H1: Providing the right number of new homes 4.1 The Church Commissioners praises the Consultation Document for recognising that ‘England is experiencing a housing crisis’ and that there ‘has been a failure in the supply of affordable homes to achieve the Government’s target of 300,000 homes annually’. The Church Commissioners also supports and echoes issues identified through the previous consultation and summarised within the Consultation Document, including that there is an affordability issue within South Warwickshire. 4.2 The Church Commissioners iterates that this is remedied by building more homes over and above the minimum identified requirement and does not agree with the narrative presented within the Consultation Document that ‘building lots and lots of (unaffordable) market homes will not address this issue’. Whilst the construction of ‘unaffordable’ homes may not solve the issue, the construction of general market housing is the only realistic way to reduce house prices and make homes more affordable. This process accords with the concept of supply and demand, which forms the basis of modern economics (see further our response to Question H2-1). Q-H2-2: Please select the option which is most appropriate for South Warwickshire: The Church Commissioners acknowledges the need for affordable housing across South Warwickshire, but reiterates that market conditions and housing need should be taken into account by both Councils. Given that market conditions and housing need (both market and affordable) vary across South Warwickshire, it is considered that it is most appropriate for each authority to have a separate affordable housing requirement. It is important the two district’s keep their affordable housing requirements separate, as their housing figures remain separate and therefore ensures this overall figure for each district is achievable. In addition, separate affordable housing requirements takes into account items such as geographical location and therefore the difference in land values, it also provides the opportunity for each District to target their own specific affordable housing need. This is supported by Paragraph 0041 (Reference ID: 23b-004-20190901) which sets out that plan makers should consider how needs and viability may differ between site typologies. 4.16 However, regardless of the affordable housing requirements proposed, the Council need to ensure that Policy is flexible in wording, allowing for viability to be taken in account and demonstrated where required to do so. 4.17 Furthermore, the proposed affordable housing policy is a strategic policy, which should be set out by establishing and understanding the need requirement, therefore the policy should be informed by evidence. This is supported by Paragraph 0041(Reference ID: 23b-004-20190901) which sets out that planning obligations policies should be informed by evidence of infrastructure and affordable housing need, and a proportionate assessment of viability. Consequently, there is potential that the two local authorities have different needs, and therefore the Policy should be addressed in accordance. However, The Church Commissioners cannot comment on details relating to specific quantified amounts, as there is no viability evidence presented alongside this consultation at present. 4.19 Option H2-2c should not be considered as it would result in affordable housing requirements being unclear and potentially unknown, therefore introducing risk, impacting upon bringing sites forward and ultimately delivering the required housing figures. Q-H3: Please select all options which are appropriate for South Warwickshire As set out under Paragraph 1.4 of the Issues and Options Report, the purpose of Part 1 of the Local Plan is to establish a robust and flexible framework to set out where and how much development should take place across South Warwickshire. Consequently, the introduction of minimum space standards is not appropriate for Part 1 as it is not a strategic consideration, thus none of the above options are the correct or suitable approach. Consequently, Option H3a should be pursued on the basis of not including minimum space standards in a policy within Part 1 of the Local Plan. 4.21 However, if the Council wish to include this, sufficient evidence should be presented as per PPG Paragraph 0022(Reference ID: 56-002-20160519) which sets out that in order to set minimum space standards within local planning policy, local authorities need to gather evidence to determine where there is need for additional standards in that area, to justify appropriate policies. The importance of this guidance cannot be understated. It is clear that the onus is on local authorities to demonstrate why standards are needed in that area ie the absence of such standards is consistently resulting in the provision of under-sized homes within Warwick and Stratford Districts. 4.22 However, it is also worth noting that in order to achieve Minimum Space Standards, larger plots will be required and therefore appropriate densities for allocated sites and what is deemed as suitable densities will need to be considered. Overall, having a Minimum Space Standard requirement may then impact upon achieving the overall housing need, therefore The Church Commissioners suggests the local authorities allocate more sites, above the HEDNA requirement in order to take account for Minimum Space Standards, ensuring the Standards can be met without impacting upon density and housing numbers, thus deliverability. Q-H5: Please select all options which are appropriate for South Warwickshire The Church Commissioners acknowledges the need for self and custom build homes. However, the Councils need to ensure sufficient evidence is present and demonstrated to show need and demand for such properties through their respective self and custom build registers. As such, it is considered that Option 5C is most appropriate, whereby developments can respond to evidenced demand. 4.29 In addition, any Policy should include wording to state that if there is no demand for the plots after a 12-month marketing period, then the plots can be released for sale on the open market.
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QH3 The Parish Council considers this policy could be dealt with in Part 2 QH5 The Parish Council considers these options premature and should be deferred to part 2 Q-H6: The Parish Council considers these options premature and should be deferred to part 2 QH7 The Parish Council considers the problem of providing affordable homes in high land and house price areas has proved intractable nationally so that affordable and social housing numbers have declined sharply. There appear to be no proposals for social housing.
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South Warwickshire Local Plan – Issues and Options consultation This letter contains the officer response on behalf of the City of Wolverhampton Council to the Issues and Options Consultation on the South Warwickshire Local PLan. The principles which underpin the response were approved by the Council’s Cabinet at its meeting on 22nd February. In summary, the Council welcomes the progress made with the new Local Plan, and the positive approach which it takes to the Duty to Cooperate in responding to the unmet strategic housing needs arising across the West Midlands and the Black Country authorities specifically. In the context of this broad support, we have a number of points which we wish to raise on specific issues. Our detailed response is set out below. Background A Representation was submitted to the previous stage (Scoping Report) of the Plan preparation process in 2021 on behalf of the City Council through the Association of Black Country Authorities (ABCA). This representation expressed strong support for those Growth Options which provide the opportunity to meet the housing and employment land needs arising in the Greater Birmingham and Black Country HMA (GBBCHMA). As you may be aware, in September 2022 the Leader of Dudley Council announced that he wished to withdraw the Council from involvement in the Black Country Plan (BCP). The four Black Country Councils subsequently agreed to prepare individual local plans and the associated Local Development Schemes (LDSs) are in the process of being brought into effect. As a consequence of this approach, the Councils also agreed to progress Duty to Cooperate work on an individual basis rather than jointly through ABCA. The Wolverhampton Local Plan The Wolverhampton LDS was adopted by Cabinet on 22nd February 2023, confirming the commitment of the Council to continue to prepare an up to date Local Plan in a robust and timely manner. This February 2023 LDS supersedes the LDS approved in October 2022, reflecting the need for the Council to consider the implications of the final version of proposed changes to the National Planning Policy Framework published for consultation in December 2022. The LDS programmes an Issues and Preferred Options consultation on the Wolverhampton Local Plan in July 2023, followed by a Regulation 19 consultation in February 2024. The Local Plan will build on the work progressed on the BCP and subsequent evidence. Our current position on housing and employment land need and supply is as set out in the Draft BCP, published for consultation in 2021. In the case of housing, the Draft BCP identified a shortfall of some 28,000 homes to 2039 across the four Council areas. For Wolverhampton, the housing shortfall was substantial at some 7,700 homes to 2039. On the basis of the consultation version of the NPPF referred to above, the Leader of the Council has committed to excluding any sites which are currently located within the green belt as development allocations within the new Local Plan. This, will further increase the 2039 City housing shortfall to some 8,700 homes. The new Local Plan will also have a Plan period extending to 2041, which could further increase this shortfall. Turning to employment land, the National Planning Practice Guidance encourages strategic Plan-making authorities to identify needs on a Functional Economic Area (FEMA) basis. In the case of Wolverhampton, the City is located within the Black Country FEMA as identified in the Black Country Economic Development Needs Assessment (EDNA) published in 2017. Across the FEMA as a whole, the BCP identifies a shortfall of some 210ha of employment land to 2039, this being the sum of shortfalls across the four Council areas. The EDNA confirms that the Wolverhampton element of this shortfall is between 40ha to 80ha. An updated EDNA was in the course of preparation to support the BCP Regulation 19 draft, and the four Council’s agreed to complete this update to support individual Local Plan preparation. The update was published in January 2023 as supporting evidence to the Sandwell Local Plan Regulation 18 consultation (https://www.sandwell.gov.uk/info/200317/planning_policy/4990/sandwell_local_plan ). The update recommends that collectively, the employment land ‘need’ should be reduced to some 512ha, and that the corresponding shortfall is some 22.4ha after taking into account current proposed contributions from neighbouring Local Plan areas. The Report recommends that the closing of this gap should be addressed through ongoing Duty to Cooperate activity with a focus on those areas having a strong or moderate functional economic relationship with the Black Country (as defined in the 2017 EDNA), and other areas where there is evidence of a functional relationship. In the case of South Warwickshire, it is not considered that such a relationship exists. While the Council will be updating land supply as part of the preparation of the Local Plan, we do not anticipate that the work will reveal any significant sources of additional land to meet housing needs. For these reasons, we are strongly of the view that the Wolverhampton housing shortfall identified in the Draft BCP remains and could potentially rise further. The ABCA representation to the Local Plan scoping consultation identified a limited functional relationship between the Black Country and South Warwickshire housing markets, but the housing land capacity constraints in the Black Country post 2031 will create a ripple effect across the conurbation and the wider HMA. On this basis, the Council remains of the view that not only is there compelling evidence of a housing shortfall arising in Wolverhampton and the wider Black Country, but also that South Warwickshire has a role to play towards addressing this shortfall through the current Local Plan. The recently published Interim findings of the Shropshire Local Plan (https://www.shropshire.gov.uk/media/25337/id28-inspectors-interim-findings-letter-15-feb-2023.pdf ) support this approach (paras 14-15), confirming the Black Country housing land shortfall including in the light of the Council’s progressing individual Local Plans. This supports our view that the shortfall cannot be ignored. The Issues and Options consultation The Issues and Options consultation document acknowledges the relationship with the GBBCHMA and Coventry Warwickshire HMA (CWHMA) and notes that, subject to soundness, the Stratford SAD will contribute 380 dwellings up to 2031 to the former. It also notes the scale of the GBBCHMA shortfall originating from Birmingham and the Black Country authorities post 2031, and that South Warwickshire may be part of the solution and that a CWHMA shortfall may be more modest. In demonstrating support, the S(E)A has considered an initial contribution of 5-10,000 dwellings to alleviate the wider GBBCHMA shortfall. This is a significant contribution and is welcomed in principle. In noting that the constraints within the GBBCHMA are due to the West Midland Green Belt, the document correctly infers that open countryside areas beyond the Green Belt are the first port of call. However, the document recognises that there are potential Green Belt locations north of Stratford, which would meet need closer to where it arises. We recommend that all of these options set out in the document are tested through the next stages of the Plan preparation process. We also recommend that the Councils continue to engage with the work of the GBBCHMA officer group and the programme of work contained within the Statement of Common Ground as circulated by South Staffordshire Council in 2022. Clearly, as is the case with the Interim findings of the Shropshire Local Plan Examination, it is not and should not be the case that South Warwickshire is expected to meet the entirety of the GBBCHMA shortfall. A regional approach is required but the potential contribution from the South Warwickshire Local Plan has the potential to make headway into addressing the gap. We trust that these comments are helpful and will be considered by the Council as part of the preparation of the next stage of the Local Plan.
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Issue H1: Providing the right number of new homes 5.12.1 St. Modwen supports the use of evidence on affordability and housing need to ensure that SWLP delivers mixed tenure development that reduces the affordability crisis, giving access to suitable housing accommodation for all existing and future residents. 5.12.2 The use of base date projections data is necessary when assessing the future quantum of housing across a plan period, especially a plan period extended out to cover an extended period to 2050. St. Modwen would support an affordability based assessment approach where policies relating to housing need are reviewed regularly and where the aim is to maintain or improve affordability within the area. 5.12.3 The SWLP housing figure should also factor in any need from Greater Birmingham & the Black Country and from Coventry. The only way this can be done is if all authorities within the Greater West Midlands area collaborate to ensure fair and appropriate re-distribution occurs. It is our experience that this level of integrated collaborative working across authorities has not, and is not, likely to result in a consensus view of how to accommodate City overspill. 5.12.4 Given the challenges in meeting sub regional and regional overspill we would support the Council proceeding with the current levels of housing and economic growth in the SWLP as informed by the HEDNA as a minimum with additional focus being placed on maintaining or improving affordability and how to address neighbouring unmet need. Issue H3 - Providing the right size of homes 5.13.1 St. Modwen objects to the use of Table 12 page 107 HEDNA based housing mix for larger Broad Locations or New Settlement Developments. Careful consideration is needed to the approach taken on housing mix when considering different types of development. For instance, urban infill site in established towns should be viewed differently to the proposed housing mix for New Settlements. The proposed delivery of only 10% of 4+ bedroom homes on the viability and deliverability of New Towns or 2000 dwelling Broad Locations needs to be tested alongside the social policy objectives linked to balanced communities and the provision of housing for older segments of the population. Flexibility in mix is advocated in the HEDNA and we would agree with including flexibility in the SWLP on mix for large sites. 5.13.2 Consideration also needs to be given to providing smaller mix sized properties that may appeal to downsizers. Under occupancy in the HEDNA study area has been identified as a significant with over 200,000 properties currently with 1 or 2 spare bedrooms.
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We also support section H4 of the Plan which considers housing need arising from outside of South Warwickshire including from the Greater Birmingham & Black Country Housing Market Area (GBBCHMA). South Staffordshire District Council and Stratford-on-Avon District Council have been active members of the GBBCHMA Technical Officers Group since it was established in 2017 and both authorities have contributed to discussions relating to the delivery of unmet housing need within in the GBBCHMA. Both authorities are also party to the emerging 2022 GBBCHMA Development Needs Group Statement of Common Ground, which seeks to provide a programme of work and governance structure to address the housing shortfalls arising from the HMA. We therefore support the South Warwickshire Plan anticipating making provision for meeting a proportion of the shortfall from the GBBCHMA and encourage continued engagement with the GBBCHMA members. Within the Issues and Options Document, pitches and plots for gypsies, travellers and travelling showpeople are considered under Issue H6. Under this Issue the Plan states: ‘There are not enough sites across South Warwickshire for this type of accommodation and so we need to plan for more, up to date evidence is currently being prepared to identify what the need is for pitches and plots across South Warwickshire up to 2050. This may include a combination of both permanent and transit pitches and sites.’ We consider that the evidence being prepared should consider the links between South Warwickshire and South Staffordshire and we request that the South Warwickshire Local Plan considers the same steps that South Staffordshire has taken in exploring the four options for new pitches as set out in our letter dated 8th August 2022, including option for publicly run sites. As part of this we ask that you proactively explore whether any of South Staffordshire’s unmet need for pitches can be accommodated through proposals on existing or new public sites in the South Warwickshire Local Plan.
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Issue H3: Providing the right size of homes Question H3: Please select all options which are appropriate for South Warwickshire • Option H3a: Do not seek to include minimum space standards in a policy in the SWLP • Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence • Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards • Option H3d: None of these 3.36 The provision of minimum space standards for housing should be a standard requirement for new development in South Warwickshire. 3.37 However, in this instance, Option H3a is the most appropriate option for the SWLP as minimum space standards is not a strategic priority which warrants to be included in SWLP Part 1. 3.38 The requirement for minimum space standards for housing is a development management matter which can be included in SWLP Part 2 unless it is centrally prescribed by national development management policies as proposed by the Levelling Up and Regeneration Bill (LURB).
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Q-H3 Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. A number of LPAs across England have adopted the Nationally Described Space Standards (NDSS), specifically falling within large cities such as London and Birmingham where they have a significant amount of apartments. It is not considered strategically important to include this requirement within Part 1 of the Local Plan, however, each Council may find it beneficial to consider the inclusion of NDSS within their Part 2 plans.
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Issue H1: Providing the right number of new homes 4.1 Caddick Land applauds the Consultation Document for recognising that ‘England is experiencing a housing crisis’ and that there ‘has been a failure in the supply of affordable homes to achieve the Government’s target of 300,000 homes annually’. Caddick Land also supports and echoes issues identified through the previous consultation and summarised within the Consultation Document, including that there is an affordability issue within South Warwickshire. 4.2 Caddick Land submits that this is remedied by building more homes over and above the minimum identified requirement and does not agree with the narrative presented within the Consultation Document that ‘building lots and lots of (unaffordable) market homes will not address this issue’. Whilst the construction of ‘unaffordable’ homes may not solve the issue, the construction of general market housing is the only realistic way to reduce house prices and make homes more affordable. This process accords with the concept of supply and demand, which forms the basis of modern economics (see further our response to Question H2-1). Issue H3: Providing the right size of homes Table 12 of the Consultation Document presents a ‘Suggested Housing Size Mix’, which has been derived from the HEDNA. The Document does not present any questions in respect of housing mix. 4.19 Notwithstanding, Caddick Land submits that any future policy concerning housing mix should require applicants to have regard to the latest evidence in respect o f housing need, whilst also ensuring sufficient flexibility is retained within the policy to ensure developments are able to respond to any changing circumstances, such as market conditions or alternative evidenced need. Q-H3: As set out under Paragraph 1.4 of the Issues and Options Report, the purpose of Part 1 of the Local Plan is to establish a robust and flexible framework to set out where and how much development should take place across South Warwickshire. Consequently, the introduction of minimum space standards is not appropriate for Part 1 as it is not a strategic consideration, thus none of the above options are the correct or suitable approach. As a result Option H3a should be pursued on the basis of not including minimum space standards in a policy within Part 1 of the Local Plan. 4.21 However, if the Councils wish to include this, sufficient evidence should be presented as per PPG Paragraph 0026 (Reference ID: 56-002-20160519) which sets out that in order to set minimum space standards within local planning policy, local authorities need to gather evidence to determine where there is need for additional standards in that area to justify appropriate policies. The importance of this guidance cannot be understated. It is clear that the onus is on local authorities to demonstrate why standards are needed in that area i.e the absence of such standards is consistently resulting in the provision of under-sized homes within Warwick and Stratford Districts. 4.22 However, it is also worth noting that in order to achieve Minimum Space Standards, larger plots will be required and therefore appropriate densities for allocated sites and what is deemed as suitable densities will need to be considered. Overall, having a Minimum Space Standard requirement may then impact upon achieving the overall housing need, therefore Caddick Land suggests the local authorities allocate more sites, above the HEDNA requirement in order to take account for Minimum Space Standards, ensuring the Standards can be met without impacting upon density and housing numbers, thus deliverability. Q-H5: Please select all options which are appropriate for South Warwickshire Caddick Land acknowledges the need for self and custom build homes. However, the Councils need to ensure sufficient evidence is present and demonstrated to show need and demand for such properties through their respective self and custom build registers. A s such, it is considered that Option 5C is most appropriate, whereby developments can respond to evidenced demand. 4.33 In addition, any Policy should include wording to state that if there is no demand for the plots after a 12-month marketing period, then the plots can be released for sale on the open market. 4.34 Caddick Land is promoting land off Warwick Road for residential development through the Local Plan. The Concept Plan included within the Vision Document at Appendix 1 to this Representation depicts land to the north of Hill Wootton Road as being reserved for the delivery of self-build plots for the benefits of the local community. Further detail in respect of the Concept Plan is included within Chapter 11 of this Repre sentation. Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire 4.35 It is crucial that the Councils undertake more evidence, to create a wider, more detailed evidence base to inform the next stage of the South Warwickshire Local Plan. It is detrimental to the potential growth Options to not have fully evidenced reports, su ch as a Green Belt Review, review of the Call For Sites submissions, engagement with other authorities within the HMA, the creation/update of the HELAA and viability testing. Without this evidence, it is difficult to fully appreciate whether the housing ne ed for South Warwickshire can be accommodated, where it could be accommodated, what sites are physically available for development, and the viability associated with other policies in relation to the delivery of residential sites. Therefore, Caddick Land strongly advises the Council undertakes further evidence and engages further, prior to the formulation of any future iteration of the Local Plan.