Issue and Options 2023
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New search3.32 Similar to previous submissions, RPS welcomes the recognition of the link between jobs and housing, and that a boost in local employment needs to be balanced by an appropriate level of housing growth to be delivered as part of the emerging strategy. This could form part of the solution to reducing levels of commuting, in particular in-commuting, and also helping to tackle wider unaffordability of housing more generally across the SW area. 3.33 In addressing the issue of commuting, the provision of more housing to encourage people to move into the SW area closer to their place of work would help to reduce commuting levels, thus having wider benefits in terms of offering people wider choice of travel mode and reductions in fuel consumption. 3.34 RPS would also wish to reiterate the importance for the SWLP to promote innovation in employment in order to assist in a longer-term sustainable recovery across the wider region by creating a more attractive location for investment. By doing so, this would help ensure the long-term sustainability of employment and investment within the SW area. This is evident in the recent decision to locate a Gigafactory on land at Coventry Airport, which is located within the SW area and in close proximity to the Coventry Gateway West site.
3.35 The NPPF mandates the use of the 2014 subnational household projections (SNHP) in the Standard Method and following the relevant Planning Practice Guidance (PPG) the method shows a need for 5,554 dwellings per annum across the Housing Market Area (HMA). 3.36 The PPG does however allow for authorities to diverge from the Standard Method where this can be justified by exceptional circumstances; any alternative approach should reflect current and future demographic trends (which includes migration) and market signals. The HEDNA proposes an alternative ‘trend-based’ projection, which is set out at Table 9 of the I&O consultation document. RPS broadly agrees that this is justified on the evidence. For example, in South Warwickshire there is a case for higher housing provision to be made over and above the standard method starting point in order to manage cross-boundary commuting which currently shows a net-in flow into the area to access local employment. This is outlined in Issue E3 (page 81 of the consultation document), “It is important to ensure that South Warwickshire is attracting a mix of employment to the area which will help to prevent out-commuting and retain residents within South Warwickshire”. 3.37 In this regard, RPS welcomes the use of a ‘trend-based’ projection as set out in the consultation.
Q-H2-1. What is the best way to significantly increase the supply of affordable housing across South Warwickshire? 3.38 RPS consider Option H2-2a ‘a single South Warwickshire wide affordable housing requirement’ the most appropriate. 3.39 The demand for affordable housing is a significant factor that should be considered in establishing the housing requirement. Para 15.21 of the HEDNA document advises that there is a requirement for 3,833 social or affordable rented homes per annum across the HMA from households who cannot afford to meet their needs within the open market. In addition, the core analysis within the report indicates that there is a need for around 609 affordable home ownership homes per annum. 3.40 The greatest need is shown to be within South Warwickshire, with the evidence pointing to a lack of or very modest need for affordable home ownership products. It is expected that the principal way of delivering this affordable housing would be via Section 106 agreements. 3.41 In addition to ensuring a sufficient supply of affordable housing, RPS contends that housing for key workers should be considered as an option, in the context of Coventry Gateway West there is an ability for the site to provide dedicated worker accommodation for the principal employment growth around the wider Coventry Gateway site 3.42 The demand for affordable housing is a significant factor that should be considered in establishing the housing requirement for South Warwickshire. Q-H2-1. What is the best way to significantly increase the supply of affordable housing across South Warwickshire? 3.43 RPS welcomes the reference in the SWLP Issues and Options document (Table 10) to the need for a ‘net need’ of 1,386 affordable dwellings to be provided for each year up to 2050. RPS recognises that the unaffordability of housing is a function of under-supply and that improvements in affordability can be tackled through increasing the supply of market housing. 3.44 Figure 11, based on affordability data recently published by ONS2, illustrates the affordability problem in South Warwickshire currently. As can be seen, Stratford has the second highest affordability ratio in the West Midlands, only behind Malvern Hills, with Warwick sixth overall. 2 ONS Table 5c, Ratio of median house price to median gross annual (where available) workplace-based earnings by local authority district, England, and Wales, 1997 to 2020 Figure 3-1 Affordability of Housing across the West Midlands 3.45 The new housing requirement for the SWLP is calculated in part to address affordability issues through the 'affordability uplift' when calculating the local housing need figure for the area (under Step 2 of the method). The resultant increase in the demographic starting point (based on household change) would then, ultimately, feed through to the identification of additional land to help address the problem of affordability in the SW area. Nonetheless, RPS considers the affordability problem facing the SW area to be significant relative to neighbouring areas and so, on that basis, the SWLP should assess the adequacy of the affordability uplift in addressing the chronic and long-standing unaffordability of housing seen across the SW area and whether it is appropriate to consider a further adjustment to address the problem of unaffordability. This can be addressed through an appropriate adjustment to the housing figures to assist in increase the delivery of affordable housing, in line with advice in the PPG3. 3 Paragraph: 024 Reference ID: 2a-024-20190220 Revision date: 20 02 2019 3.46 RPS would also recommend that, separate to the above, that the SWAs consider at an early stage applying an adjustment to the total housing figure specifically to assist in addressing the need for affordable housing. Similarly, given that current affordable housing target is already set at 35% in the Stratford Core Strategy (under Policy CS.18), there is very little scope to increase the provision sought within the existing supply under the current policy. The likely result of this would be the need for additional land to be identified to assist in addressing the affordable housing need uplift. Such an approach was adopted by the Gloucester, Cheltenham, and Tewkesbury in 2017, where affordability is currently better compared to the SW area. Through the identification of more land, RPS argue that it would become more viable to deliver more affordable homes given the need is spread more widely, thus reducing the burden on individual sites. 3.47 We contend Option H2-2a ‘A single South Warwickshire wide affordable housing requirement’ is the best option. For the purposes of consistency across both districts which currently are different in their affordable housing requirements in the new developments. The resultant effects of this, means certainty for developers, greater certainty in anticipating their costs and greater certainty in anticipating delivery of affordable homes. 3.48 For the HMA as a whole, when considering past delivery, an affordable housing requirement of 35% would be incapable of delivering a sufficient quantum of affordable housing to meet the identified need. Based on the above, RPS supports any measure to increase the overall supply of housing in order to address housing (un) affordability of housing generally and specifically to address the need for affordable housing in the SW area. Warwick District Council reached an agreement with Coventry City Council to accommodate 94 affordable dwellings per annum towards Coventry’s affordable housing need. In total this means Warwick District needs to accommodate 374 dwellings per annum, which equates to 40% of the average annual housing requirement. Warwick District Council has only achieved this target twice in the past ten years.
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3.49 RPS welcomes the reference made in the SWLP potential requirement to meet identified housing shortfall from neighbouring authorities. The SWLP recognises that the SW area sits in the wider West Midlands region, and in preparing the SWLP it will be necessary to take into account the plans and strategies of a number of neighbouring authorities. RPS contends that this represents a key strategic matter that will need to be addressed through the SWLP as it moves forward, as part of the Duty to Cooperate obligations relevant to the SWLP, which the LPAs recognise is required (page 101). 3.50 Whilst RPS acknowledges that the Government has proposed reforms to the NPPF (with consultation running up to 2nd March 2023), looks to propose removal of the Duty to Cooperate until provisions come into effect and it be replaced with an “alignment policy” as part of a future revised NPPF. As yet, however, it is not clear what specific requirement will replace the duty. Nonetheless, there remains the requirement in national policy for strategic policies to address strategic priorities of the area, including any relevant cross-boundary issues and also the requirement to demonstrate effective and on-going joint working by documenting those relevant cross-boundary matters that are being addressed and the progress made in cooperating to address these. 3.51 Page 111 of the I&O consultation document refers to the four elements of unmet need that may have implications for South Warwickshire arising from the different Housing Market Areas. These HMAs are likely to face difficulties in meeting their own needs within their boundaries as time moves on, given that both Birmingham and Coventry are now amongst the ‘35% uplift’ authorities identified as part of the revised standard method. Birmingham City Council’s Local Plan review to 2042 has an identified housing shortfall of 78,415 homes. 3.52 Based on the information set out in Chapter 6 regarding shortfalls, the SWLP provides no clarity on how much potential housing shortfall from the surrounding HMAs that would be addressed in the SWLP, apart from highlighting two potential contributions of 5,000 and 10,000 additional homes in the Sustainability Appraisal. The SWLP should under a separate policy to make a commitment to accommodating a proportion of any identified housing shortfall from its neighbours and build this into the emerging spatial strategy for the SWLP. 3.53 There are, in addition, other local authority areas that are also likely to face their own challenges in meeting their housing need once their plans are brought forward for review. Based on current available information these are likely to include the Black Country Authorities, and potentially in neighbouring Redditch and Bromsgrove who may be requested to take some of this housing shortfall. These areas share the same housing market area with Stratford-upon-Avon. 3.54 In the Black Country, it is now apparent that there will be an identified housing shortfall post 2031 in the GBBCHMA, with the Black Country Urban Capacity Review estimated a shortfall of 29,288 dwellings4 by 2038 (paragraph 2.1.40), which it will be the primary issue for consideration through the respective emerging Local Plans (given the now defunct joint Black Country Plan). This represents a substantial level of unmet need, which does not take into account the 35% uplift that will also need to be applied to Wolverhampton’s component of the Black Country’s need, which is likely to further increase the scale of the shortfall. More recent evidence5 indicates that the shortfall in the Black Country has increased further, from 29,288 to 36,819 dwellings, an increase of over 25% on previous estimates. 4 Black Country Urban Capacity Review December 2019 3.55 RPS would recommend that a key consideration in identifying suitable locations to address these shortfalls should be to prioritise locations that are accessible and in close proximity to where the unmet need arises, thus reducing travel distances as well as offering the potential for linked service provision to meet the wider needs of the new communities. In strategic terms, this means that the re-distribution of any unmet housing need should be related to settlements on a duty to cooperate basis (in this instance South of Coventry), and which would clearly lead to an increase in the overall level of growth to be accommodated within the SWLP and the need for additional land to accommodate that growth.
3.56 The Warwick District of the Coventry and Warwickshire HMA most strongly relates to Coventry given its shared boundary and interrelationships with the city. Under the trend projection put forward in the HEDNA, the redistribution of housing resulting from this, it is likely Coventry will not be able to accommodate all of its housing needs (1,964 homes per annum), and as such a relatively modest shortfall may exist to 2050. Recognising that these shortfalls arise because of the way Coventry is constrained by the West Midlands Green Belt. However, consideration must be given to the strength of the relationship between South Warwickshire and the source of these shortfalls. RPS considers that the significant scale of the shortfalls presents exceptional circumstances that justify the release of land from the Green Belt for residential development. 3.57 The Green Belt areas in sustainable areas, in proximity to where the strength of the relationship from where shortfalls arise is strongest, areas south of Coventry are considered to be the most appropriate locations for sustainable urban extensions to accommodate this need. 3.58 This view is reaffirmed by the Council, RPS are aware that Warwick District Council, alongside partners Warwickshire County Council, Coventry City Council and the University of Warwick, are undertaking a masterplanning framework for land to the north of Kenilworth/south of Coventry area. Further information is available in the Cabinet Report from April 2022. The Cabinet Report states: 3.59 “There is considerable growth pressure in this area, and this can be seen in sites that are already being promoted in the South Warwickshire Local Plan (SWLP) being prepared jointly by Warwick and Stratford District Councils”. 5 The Black Country Urban Capacity Review Update (May 2021) Summary, page 2
Q-P1.1. Do you agree with the proposed broad content of the Part 1 plan? 3.60 Whilst we agree with the proposed broad content of the Part 1 plan, it is worth highlighting to the Council’s the implications of the transitional arrangements to new Joint Spatial Development Strategies and new style Local Plans as proposed in the LURB in the context of the SWLP progressing as separate parts. In particular, the broad content proposed at this stage does not include site specific allocations or policies, therefore it is worth flagging the potential issues of delayed plan-making. Notwithstanding this, the South of Coventry study area as set out in the Cabinet Report from April 2022 from Warwick District Council, should be considered as a strategic policy through the Part 1 plan via appropriate status without the need for it to be defined through Part 2 and this would be more fragmented and site specific. It must be clear, in terms of transparent decision making, how the SWLP authorities identify the South of Coventry study area as a potential area for future growth or not (referring to para 1.7 of the April 2022 Cabinet Report). 3.61 Whilst the approach the SWLP authorities are taking should remain unchanged, we wish to use this opportunity to remind the Councils that timescales in relation to the transitional arrangements set out by the draft NPPF changes are of consideration. 3.62 Given the SWLP is in the earlier stages of plan making (i.e., pre-Reg 18), we note the current up to date timeline indicates that the SWLP will reach submission stage by June 2025. Assuming this deadline is met, then work on a new plan will need to start by the latest January 2032. If the deadline is missed, new style plan preparation will need to begin immediately from that date (July 2025). 3.63 If the deadline is met, this has benefits in that late commencement of a new-style plan, gives the SWLP authorities more guidance, best practice, and case law to consider. 3.64 We urge the SWLP authorities to continue with preparing the local plan at the current timetable for the June 2025 submission target date, as this will ensure the timely preparation of the SWLP.
[NOTE: There are a number of figures and tables that cannot be reproduced in this text editor - see original comment in JDi] 4 SUSTAINABILITY APPRAISAL COMMENTS Q-I1. Please add any comments you wish to make about the Sustainability Appraisal, indicating clearly which element of the appraisal you are commenting on. 4.1 It is a requirement of European and UK Legislation that a Sustainability Appraisal (‘SA’) is undertaken incorporating the requirements of the Environmental Assessment of the Plans and Programmes Regulations 2004 which was derived from the Strategic Environmental Assessment (SEA) Directive. 4.2 The purpose of the SA (incorporating the requirements of the SEA Directive) us to ensure that the plan or programme (in this instance the emerging Our Future Birmingham City Plan) promotes the principles of sustainable development by assessing the potential environmental, social and economic impacts or benefits of the plan and incorporating suitable mitigation measures to decrease of increase these respectively. 4.3 The Strategic Environmental Assessment Regulations requirements checklist requires the “preparation of an environmental report that identifies describes and evaluates the likely significant effects on the environment of implementing the plan or programme and reasonable alternatives taking into account the objectives and geographical scope of the plan or programme (regulation 12(2))”. 4.4 Paragraph 32 of the NPPF states that “Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered”. 4.5 We note that the SA at this stage is identifying reasonable alternatives, these being ‘reasonable alternative broad locations’ and ‘reasonable alternative small settlement locations’, based on a set of criteria (see Figure 8). Figure 4-1 Procedure for identifying reasonable alternative Broad Locations and Small Settlement Locations 4.6 Regarding the list of alternative development locations, we note that ‘South of Coventry’ and ‘South Coventry’ has been identified to provide an alternative scale of development. Whilst we accept that the Councils identified list of 32 broad locations and 22 small settlement locations is not an exhaustive list, and which fits a number of criteria relating to accessibility and position in the settlement hierarchy, it has been arbitrarily defined. 4.7 We object to the SA on the grounds that the land further east of ‘South Coventry’ (as shown in C.17, page 117 of SA Appendices) hasn’t been considered in the SA as a reasonable location option for analysis. 4.8 We take fundamental issue with the reasonable alternative development options that could be located near existing services in the main settlements, the Main Settlements listed in paragraph 3.5.2 of the SA Report (page 46) have been divided into Broad Locations. Essentially, this has been done on the basis that the main settlements were all sufficiently large that they could each have three or more Broad Locations associated with them. We question why - given the scale of Coventry as a city - ‘South of Coventry’ has not been identified in bold font as a main settlement with reasonable alternative broad locations to the south of the city. In effect, RPS considers the whole study area set out in Warwick District Council’s April 2022 Cabinet Report should be identified as a broad location, so as to ensure it has been assessed appropriately. 4.9 Whilst the ambition is to deliver approximately 2,000 homes as part of a strategic allocation, the plan must provide options for all scales. The 1,000 homes mark is preferable given it REPORT JBB7597.C8255 | South Warwickshire Local Plan (Part 1) Issues and Options Representations | FINAL | rpsgroup.com Page 26 supports primary education provision, reducing pressure on existing services in the local area, providing a degree of self-containment, mitigating its impacts when assessed against the SA. Furthermore, RPS considers that the ‘identified’ (based on the criteria set by the Councils) sites on the edge of Coventry should be considered differently in SA terms given their ability to utilise and be accessible from many higher order services that are resultant of the proximity with Coventry. Figure 4-2 Current extent of C.17 'South Coventry', excerpt of SA Report, page 117 4.10 We contend that the Site, Coventry Gateway West presents an opportunity to provide an alternative scale of development that meets the criteria relating to key aspects of accessibility and position in the settlement hierarchy. Therefore, the extent of C.17 [South Coventry] should be drawn to a greater extent to envelope a true extension to Coventry, or present two parcels to C.17, acknowledging the planning commitments at King’s Hill coming forward and thus form a clear ‘arc’ south of Coventry as an alternative development location. A map below (Figure 3-3) highlights the possible extent of an alternative development location we contend should be assessed against the SA objectives. This extent aligns with the master planning work being undertaken by Warwick District Council, alongside partners Warwickshire County Council, Coventry City Council and the University of Warwick, for land to the north of Kenilworth/south of Coventry area. Given the scale of masterplan area, it would not be appropriate, or expected to assess all areas within it. Figure 4-3 RPS proposed extent of C.17 small settlement at South Coventry or broad location ‘South of Coventry’ 4.11 RPS’s proposed extent of SA reasonable alternative locations (above) is presented at this stage as a broad parcel area, given an in-depth assessment has not been undertaken of our (presented) additional segment enveloping the land at Coventry Gateway West. It is envisaged the area when considered as a whole or as smaller parcels (to discount constrained areas) would score as equally positive, if not more so against SA objectives, in particular access to employment opportunities (shown as employment allocation). 4.12 Chapter 7 of the SA ‘Evaluation of the Spatial Growth Options’ sets out the various spatial growth options and how they perform against each SA objective. Table 7.1 of the SA summarises the findings of these options, as replicated in Table 1. Table 1 Excerpt of SA - Summary of findings for the spatial growth options 4.13 We wish to make clear that the distinction between Options should not be too broad and wide-ranging and not to disregard mid-high growth options. In this regard the PPG states: “Reasonable alternatives are the different realistic options considered by the plan-maker in developing the policies in the plan. They need to be sufficiently distinct to highlight the different sustainability implications of each so that meaningful comparisons can be made.” 4.14 Given some of the spatial options, in the Council’s own words consist of some level of overlap, RPS consider that the finding indicates considerable overlap in the likely effects across the different options. We contend some changes are required to the scoring to assess the sites more accurately in sustainability terms. These are set out in Table 2. Table 2 RPS amendments to spatial growth option scoring 4.15 In respect of SA Objective 4 ‘Landscape’ against spatial options 3 & 4, we consider that all spatial options are likely to be located, in large part, on previously undeveloped land into the surrounding countryside. Recognising that landscape receptors at each location will determine the extent to which a landscape can accommodate change without permanent adverse effects, it is perhaps too broad brush an approach to score that overall, a significant adverse effect on the local landscape cannot be ruled out, when discussing growth at the scale envisaged by the plan. Coupled with possible emergent policy options that may require a ‘landscape-led’ development framework concept. It is possible for development of sites in the countryside to enhance the landscape character by restoration of landscape features; mitigation of potential adjacent housing and provide integration between built and rural landscapes with improved access for future residents. We therefore contend, the effects likely to landscape are positive within these spatial options and thus be scored ‘+’ or ‘0’ at a minimum. 4.16 In respect of SA Objective 7 ‘Natural Resources’ against spatial options 3 & 4, we consider that all spatial options are to be directed towards open countryside. Given that development, regardless of the type of proposal would be directed to previously undeveloped locations and would be expected to result in a permanent and irreversible net loss of ecologically and agriculturally valuable soils caused by excavation, compaction, erosion, contamination, and removal of vegetation cover. We therefore contend that the spatial options 3 & 4 should be scored as ‘0’. With respect to options 1 & 2, given they may potentially promote higher density development, this is an assumption and is dependent of forthcoming proposals, therefore a score of ‘+/-‘ would be more reflective of the possible alternatives.
