Issue and Options 2023

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Paragraph 61 of the Framework advises that in order to determine the minimum number of homes needed, strategic policies should be informed by local housing needs assessment, conducted using the Standard Method in National Planning Practice Guidance, unless exceptional circumstances justify an alternative approach which reflects current and future demographic trends and market signals. In addition to the local housing needs figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for. We note that the Standard Method housing figures for Stratford-on-Avon and Warwick Districts are 564dpa and 675dpa respectively. The trend based projection in the HEDNA suggests that 868dpa are required in Stratford-on-Avon and 811dpa in Warwick District. Therefore moving towards a trends based approach would seem appropriate. In terms of the approach for the HEDNA, it is noted that Table 8.13 – Estimated Need for Social/Affordable Rented Housing by Local Authority, identifies a net annual need for 419 affordable dwellings in Stratford-on-Avon and 582 affordable dwellings in Warwick District. This equates to 67% and 52% of the identified overall housing requirement respectively for the two authorities. In all likelihood, the principal way affordable housing will be delivered during the course of the plan period will be through planning obligations associated with residential developments. The PPG advises, at paragraph 2a-024, that the total affordable housing need can be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments. However, it is not realistic to generally expect housing allocations to deliver 67% or 52% affordable housing. There is, therefore, the possibility that there will be a shortfall of affordable housing provision during the course of the plan period. One way to overcome this would be to increase the total housing figures included in the SWLP Consideration should, therefore, be given to uplift the housing requirement to ensure that an appropriate amount of affordable housing can be provided.

The most appropriate way of “significantly increasing” the overall supply of affordable housing across South Warwickshire is to have a housing requirement that is sufficient to support the delivery of much needed affordable housing through planning obligations. This matter is addressed in response to Q-H1-1 above.

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The emerging plan will have to play a role in meeting the housing shortfall arising from the Black Country and Birmingham. The Draft Plan acknowledges that Birmingham’s Issues and Options document identifies a housing shortfall of 78,415 dwellings. No reference is made to the extent of the housing shortfall arising from the Black Country. Following the abandonment of the Black Country Plan, the four Black Country authorities are producing individual Local Plans. However, the Preferred Options version of the abandoned draft Black Country Local Plan included a housing requirement shortfall figure that can be considered a credible starting point for considering the potential housing shortfall for the Black Country; a figure of 28,239 dwellings. As a consequence, the total housing shortfall arising from the conurbations is 106,653 dwellings. The Sustainability Appraisal suggests that an additional 5,000 to 10,000 homes could be provided within South Warwickshire to support the growth requirements of the Birmingham and Black Country conurbation. This is equivalent to under 5% to 10% of the total housing shortfall. It is entirely possible that the SWLP will be required to deliver numbers near the top end of this range. In terms of the Coventry shortfall, whilst the HEDNA suggests that the housing need for Coventry should be significantly below the Standard Method housing requirement for the city, this has yet to be tested. The Draft Plan should, therefore, consider options for delivering additional housing to support for the growth of Coventry.

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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-C4.1 – Please select the building regulations requirement option that is appropriate for South Warwickshire Option C4.1a: Do not have a policy and allow new development to comply with the national building regulation requirements, which may change over time. The SWLP is being prepared to cover the period up to 2050. During the course of the plan period building regulations will change. It is appreciated that it is highly likely that there will be at least one Local Plan review within the next 5 to 10 years, however, by the time a replacement Local Plan is in place updated building regulations could have been implemented and could result in an out of date policy in the SWLP.

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Q-C9.1 – Please select a biodiversity option which is most appropriate for South Warwickshire Option C9.1b: Do not include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity It is not necessary for a SWLP to include a policy requiring new developments to incorporate measures to increase biodiversity. In November of this year it will be a statutory requirement for all development proposals to demonstrate 10% biodiversity net gain. As this is set out in the Act it does not need to be repeated in policy.

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Yes, the range of topics identified is appropriate for a strategic design policy. South Warwickshire has a large plan area, comprising large towns, a variety of villages of different size, hamlets and significant areas of countryside. It is, therefore, imperative that a design policy is flexible to recognise the different environments across the plan area, delivering high quality schemes.