Issue and Options 2023

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2.1. As set out in response to the Scoping and Call for Sites consultation, Persimmon supports Stratford-on-Avon and Warwick District Councils in the continued preparation of a Joint Local Plan. Working together provides the Councils with the opportunity to comprehensively develop the vision, strategic objectives, development requirements, spatial development strategy and policies that will shape detailed development proposals, taking into account changes to the national planning legislation, revisions to the NPPF and National Planning Practice Guidance (NPPG) that have occurred since the adoption of the Development Plans, adopted in 2016 (Stratford) and 2017 (Warwick) respectively. 2.2. Any joint Local Plan must embrace similarities between the authorities and the opportunities created (such as the provision of strategic infrastructure) whilst also recognising differences. For example, the two administrative areas at present have differing settlement hierarchies where Stratford on Avon has a much more rural population than Warwick and those differences must be taken into account in the strategic nature of spatial policies that are prepared. Notwithstanding, the Joint Plan itself provides the opportunity to set a spatial hierarchy and identification of land for development which ensures the existing character of the area as a whole is preserved and enhanced. National Requirements for Plan-Making 2.3. Paragraph 33 of the NPPF requires local planning authorities to keep policies in their Local Plans up to date by undertaking a review at least once every five years. The joint Local Plan will ensure that an up-to-date Local Plan for ‘South Warwickshire’ will be in place to support growth and meet future development needs. Persimmon supports the Councils’ proactive approach to progressing a joint Local Plan to ensure that an up-to-date policy framework exists for the ‘South Warwickshire’ area, to guide growth to 2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives 2.4. The plan’s Vision seeks to “meet South Warwickshire’s sustainable development needs to 2050” and “provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.” These representations are broadly supportive of the vision as presented, which accords with para 7 of the NPPF which states that the purpose of the planning system is “to contribute to the achievement of sustainable development.” 2.5. The five overarching principles which then set out the basis on which policies will be formed, and thus how the Vision will be delivered do not match the Vision as drafted. For example, the delivery of ‘homes and jobs’ does not appear in any of the over-arching principles accompanying the Vision. Whilst the detail of the Issues and Options consultation documents goes onto talk about the delivery of growth, an over-arching principle to underpin the Vision should be developed, from which detailed policies will flow. Such a principle would also tie in to the Strategic Objectives which follow, which do set out a number of objectives to deliver South Warwickshire’s development needs. 2.6. The Vision places significant emphasis on responding to the ‘climate emergency’. Although this principle in general is supported, and it aligns with the Government’s aspirations for achieving net zero carbon emissions, it is also important that this does not dominate the Vision and Strategic Objectives of the Plan to the detriment of delivering a balanced, sustainable strategy which achieves the delivery of development to meet identified needs. 2.7. The Vision also makes reference to ‘beauty’ stating that this will create spaces where people want to be, which respect and reflect the existing beauty and heritage of the area. This aspiration is supported in principle and it is acknowledged that national policy is pursuing ‘beauty’ in planning, however there is a concern that as a concept this is not well defined and will need to be supported by more detailed design which reflect on what beauty might mean in practice.

3.1. The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable”. 3.2. NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. 3.3. To support the Issues and Options the SA consultation has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no, new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. 3.4. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth 3.5. The significance of effects is assessed in accordance with Table 2.1 in the SA: 3.6. The principle and broad approach of the SA is supported, however it is recognised that at this stage the SA considers wide areas and therefore the assessments will not apply to each site within these areas equally. As the Plan progresses it will be necessary to undertake more fine-grained, site-based analysis. Further comments are made below and in following sections regarding the sites suitability for development when considered against the SA objectives.

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Q-I2: Please select the option which is most appropriate for South Warwickshire: 3.7. It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. 3.8. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: 3.9. It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability 3.10. The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. 3.11. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site-specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage as intimated at NPPF para 58.

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3.20. Studley is assessed as a whole for the purposes of the Settlement Design Analysis which forms part of the Council’s evidence. The land south-west of Studley is identified as parcels 8 and 9 which score a C and B for accessibility respectively. This is also the case for the other parcels assessed around Studley. It is acknowledged that there are existing Public Rights of Way (PRoW) within this area which would be considered and integrated as part of any development proposals. 3.21. The landform analysis demonstrates that the land south-west of Studley is the least constrained area around the village. It highlights the presence of existing green infrastructure to the north of the village and significant areas of flood risk to the east/south-east associated with the River Arrow. 3.22. The local facilities analysis states that both parcels are within 800m of places to meet, open space, leisure & recreation and education. Parcel 8 is within 800m of retail, jobs and economy and Parcel 9 is within 800m of healthcare. It should be noted that this analysis does not consider potential additional linkages which could be created, including between the parcels. 3.23. The adjacent residential developments are identified as having a mix of inner suburb (40-60 dph) and outer suburb (20-40 dph) densities. It is likely that this site would reflect a mix of appropriate densities across the site.

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Q-S3.2: Please select the option which is most appropriate for South Warwickshire: 3.12. It is acknowledged that national policy encourages the reuse and redevelopment of brownfield land. However, as identified by Option 2A, it is important that brownfield development should reflect the identified growth strategy in order to ensure that sustainable development is achieved. 3.13. It should be noted that the Urban Capacity Study (October 2022) established that it is unlikely to be possible to meet current development needs without significant greenfield development. Whilst the reuse of suitable brownfield land, in line with the growth strategy and/or in sustainable locations should be encouraged by planning policy, it will not avoid the need for greenfield development as part of the South Warwickshire Local Plan. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.14. Growth at existing settlements across the Joint Plan area should form part of the overall Plan strategy, as this would accord with the differing current pattern of spatial development across the two administrative areas. 3.15. Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a proportion of development as well as its main towns. 3.16. In order to develop the most sustainable pattern of development, growth at existing settlements should be in sustainable locations. It is important that appropriate levels of growth are apportioned to existing settlements in order to maintain the vitality and viability of settlements, support new and existing infrastructure requirements and provide an appropriate mix of housing for the area. 3.17. Studley is identified as one of 22 small settlements. It should be noted that the ‘small settlements’ are the only areas assessed at this stage aside from seven broad locations for developments (the largest seven settlements across the Districts) and potential new settlement locations. It should be noted that small settlements are sustainable locations for development. This site would allow for a sustainable development close to existing services and facilities. 3.18. As set out in the Sustainability Appraisal at Table 5.1, Studley scores similarly to the other small settlements assessed. It is noted that other small settlements score higher than Studley against Education and Accessibility. This is discussed in more detail in following sections however Studley has primary schools and a secondary school within the village. It should also be noted that the SA at this stage does not consider any mitigation. Growth at Studley would assist in supporting and likely enhancing the existing public transport provision which would mitigate any accessibility concerns. 3.19. It is clear that this site is located in an entirely sustainable location and should be positively considered as a location for growth. Issues S6: A Review of Green Belt boundaries 3.24. The Issues and Options consultation document does not set out any specific question on Green Belt matters, but these representations support a review of the Green Belt boundary as part of the Plan making process. 3.25. As set out in the NPPF para 136, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation of Local Plans. Moreover, strategic policies should establish the need for changes to Green Belt, and where proposed, the amended boundaries should be able to endure in the long term, i.e. Green Belt boundaries will not need to be altered at the end of the plan period. 3.26. NPPF para 137 requires exceptional circumstances to include evidence of the examination of all other reasonable options for meeting an identified need for development. Importantly, in reviewing Green Belt boundaries sustainable patterns of development should be taken into account. 3.27. The Green Belt is tightly drawn around, and indeed, washes over, a number of existing settlements across the Plan area. In proposing, assessing and review growth options, where the most sustainable form of development is likely to be around existing settlements, it is therefore imperative that the Local Plan evidence base includes a Green Belt review. The Councils’ recognition of this in relation to a number of the proposed growth options is supported. 3.28. If a Green Belt boundary review is not undertaken, development will need to ‘jump the Green Belt’ which would result in an isolated pattern of development. Studley is a settlement which is surrounded by Green Belt with limited options for growth without Green Belt release. Studley is a sustainable location for further growth and, as set out in this representation, the site represents a sustainable location for residential development and should be released from the Green Belt through the review associated with this Plan. Q-S7.2 For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: 3.29. It is noted that the Issues & Options document has reduced the previous seven growth options presented in the Scoping Consultation to five options as outlined above through refining and combining options, including Option 2 sustainable travel (combination of rail and bus corridor) and Option 3 economy (combination of socio-economic and enterprise hub options). In this consultation document, Option 4 sustainable travel and economy effectively combines Options 2 and 3. It is clear from this process that the growth option to be pursued will represent a combination of all five options outlined above. 3.30. The options now presented in the Issues and Options, apart from Option 5: Dispersed, perform broadly similarly to each other in the SA (Table 7.1) suggesting not one option may have significantly more or less impact than any of the others when considered against the SA Framework. At this stage, the SA has not considered any mitigation or site-specific options for growth within settlements identified within the ‘dispersed’ option (5). There could be significant variance in how each settlement and individual sites would perform against the SA objectives. All of the growth options could deliver sustainable development and a combination of all options will be the most appropriate option for the development of the Plan going forward. 3.31. By necessity, the strategy will need to identify areas outside existing settlement boundaries for growth/development. The Urban Capacity Study identifies capacity for 6,145 dwellings within the existing urban boundaries. If the Plan proceeds with the housing figures set out in Table 9 of the Issues and Options consultation at 1,679 dwellings per annum the Urban Capacity Study would only be able to deliver a 3.66 year supply of housing. Land from other sources will therefore be required and it is important that all options are considered in taking the Plan forward. 3.32. Combining sustainable travel (including rail) and economy will naturally direct most growth to the larger, more sustainable settlements. However, it is important that appropriate, proportionate growth is directed to smaller settlements in order to support the continued viability and vitality of these settlements going forward. This would include supporting or enhancing sustainable travel options at these locations. This needs to be positively planned for as part of the South Warwickshire Local Plan and as such an element of dispersal should form part of the final growth option. This will require a careful consideration of all of the options, including growth at existing main settlements, growth at smaller existing settlements, proximity to services and jobs, availability of infrastructure or opportunities for infrastructure delivery and a Green Belt boundary review to ensure development is not isolated beyond the defined Green Belt boundaries. Q-S8.1: For settlements falling outside the chosen growth strategy, do you think a threshold approach is appropriate, to allow more small-scale developments to come forward? Q-S8.2 For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? 3.33. The supporting text for this question confirms that the aim of this approach would be to allow for development within or adjacent to existing settlements. This provides greater scope of these settlements to accommodate growth than the current infill only approach. The proposed approach to allow for suitable development within or adjacent to existing settlements is supported and will allow for suitable growth. 3.34. An across the board threshold limit of 10 dwellings is not supported. The amount of development different settlements can accommodate will vary significantly depending on various factors, such as existing services and facilities, local need for housing and the suitability of the proposed site to accommodate a certain level of development. 3.35. In addition, developments of 10 or fewer dwellings are exempt from affordable housing. Even where a lower threshold is set, developments of this scale generally result in a commuted sum towards affordable housing elsewhere. This is due to a variety of factors, including that registered providers often will not take on a small number of dwellings in one location. It is clearly preferable to have affordable housing delivered on site wherever possible to meet local needs. Setting a more flexible threshold that would allow for a higher level of development where appropriate would support greater on-site affordable housing provision. Q-S9: Please select the option which is most appropriate for South Warwickshire 3.36. The South Warwickshire Local Plan provides the opportunity to review all settlement boundaries and ensure they will be fit for purpose across the plan period. Saving all existing settlement boundaries is unlikely to be effective in positively planning for plan-led growth across the plan period. This should apply all settlements as part of the exercise will be to assess which settlements which would benefit from a defined boundary. 3.37. To be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable location to meet the development needs of the Plan. 3.38. In addition, settlement boundaries will need to be reviewed and amended to take account of new allocations. 3.39. For example, the development boundary for Studley should be reviewed to allow for the removal of this site from the Green Belt and inclusion within the development boundary to deliver sustainable residential growth.

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4.9. There is an acute recognition in the Issues and Options consultation documents of an affordability problem across South Warwickshire Plan area, where those on low incomes and young people struggle to access the housing market. 4.10. Warwick District Council’s latest ‘Authority Monitoring Report’ (AMR) (for the period 2020-2021) indicates that against an annual requirement of 280 affordable dwellings since the beginning of the currently adopted Plan period in 2011 (within its own area), the Council have delivered 841 affordable dwellings (out of a total requirement for 2,800), 30% of the target. 4.11. Stratford-on-Avon’s latest AMR for the period 2021-2022 (published December 2022) identifies that in the current Core Strategy plan period of 2011-2031, 3,204 affordable dwellings have been provided out of a total 10,019 dwellings (net) built. This equates to 37% of all dwellings and is just above the Plan’s affordable housing policy requirement of 35% of all dwellings to be affordable. 4.12. Notwithstanding Stratford-on-Avon’s marginal reported over delivery, the HEDNA considered the affordability issue across the District further. It identifies at Table 8.45 that the estimated annual need for affordable housing (rented and affordable home ownership) across Stratford-on-Avon and Warwick is 1,386 dwellings per annum. 4.13. Whilst it is recognised that these are ‘net’ figures and not ‘newly arising need’, PPG paragraph 2a-024 makes provision to encourage local authorities to consider increasing planned housing numbers where this can help to meet the identified affordable need: “The total affordable housing need can then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probably percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the strategic plan may need to be considered where it could help deliver the required number of affordable homes.” 4.14. The Issues and Options consultation recognises that the area has an acute affordability problem and it is suggested that to address this, the Plan could consider providing housing above the ‘minimum’ need, to boost supply, and in turn deliver additional affordable housing.

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Q-H3: Please select all options which are appropriate for South Warwickshire 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 Option 5a: 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 Option 5b: Require large development of, say, over 100 homes to provide a proportion of self and custom-build homes within the overall site. Option 5c: 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 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. .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.