Issue and Options 2023
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New searchQ-S4.2: Yes, we agree that some of the existing settlements should be part of the overall strategy. The SA has explored a number of alternative options for growth at existing settlements. The importance of considering the potential for growth around the edges of existing settlements is acknowledged. Developing to the south-west of Stratford, for instance would enable future occupiers to access a range of services and facilities (healthcare, education, leisure and recreation, retail, jobs and places to meet. The growth of all existing settlements (proportionate to their size) could also assist the council to secure benefits associated with the 20-minute neighbourhood principle – the settlement analysis undertaken as part of the evidence base identifies settlements which are considered to be suitable for growth – based on connectivity, accessibility and density analysis Bellway Homes West Midlands have an interest in a site at Bordon Hill. The site has been submitted to the Call for Sites and comments on their behalf were made in relation to the Scoping Consultation. The site is located to the south-west of Stratford-on-Avon and as such the following comments relate to the analysis of that area. The connectivity analysis demonstrates that the site is served by 2 primary streets (Evesham Road and Luddington Road) and has been graded as Connectivity Grade B. The topography is considered to be “fair” and not located within a flood zone 2 or 3. It scored a total of 4 points (out of a total possible 5) in relation to local facilities within 800 m (1 point for each; places to meet; open space, leisure, recreation and wellbeing; healthcare and education). We agree with this analysis and believe that it supports our opinion that the site, which lies within the south western area of Stratford-upon-Avon should be supported within the growth strategy contained within Part 1 of the Local plan. Stratford-upon-Avon is the largest, highest ranking, and therefore the most sustainable settlement within Stratford District. The development of the site at Bordon Hill would therefore be entirely logical, particularly as it would sit opposite existing development along Luddington Road. From a sequential point of view, the site is not contained within the Green Belt or within a Landscape Sensitivity area and so as such, should be given priority for development over other sites located within sensitive locations such as those within the Green Belt to the north and east of Stratford. Further site-specific details can be considered at relevant points in the future as the development of the plan progresses.
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Affordable housing is a significant issue for the SWLP. It is firstly important to have in mind that delivering housing to meet identified needs will assist in keeping affordability ratios in check, since demand will meet need and will avoid housing prices rising due to elasticity of supply issues. Even in circumstances where housing need is being identified and met, there is an acute need for affordable housing in South Warwickshire. The public sector is unable to deal with this issue, it is therefore for the private sector to deliver necessary affordable housing provision. Exception type housing will deliver a proportion of affordable provision, this however will be very low. The most effective way of delivering affordable housing is via allocations and windfall development over the plan period, by way of an appropriate – viability tested – threshold and percentage delivery requirement. The SWLP should maximise the delivery of market housing delivery, so as to correspondingly maximise the opportunity to deliver affordable housing. This is singularly the only way in which meaningful quantities of affordable housing will come forward in the plan period.
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Q-H2-2a We consider that with a single plan for South Warwickshire, combined as a unified policy area, there should be a single South Warwickshire wide affordable housing requirement – both in terms of threshold and percentage requirement. Issue H3: Providing the right size of homes Q-H3a. We would support option H3a – which does not seek to include minimum space standards in a policy. We would agree that this is not of strategic importance across South Warwickshire and so could be considered in Part 2 of the plan, and assessed against evidence provided that it is a requirement within the District that would not impact of the affordability of properties. Issue H5: Providing custom and self-build plots Q-H5a and c The Self-build and Custom Housebuilding Act 2015 (as amended) places duty on Councils to keep a register of individuals and associations of individuals and associations of individuals who wish to acquire serviced plots of land to bring forward self-build and custom housebuilding projects. They are also required to have regard to this register and grant enough development permissions to serviced plots of land to meet the identified demand, where the demand is dictated by the number of entries on the Council’s Self-build register within each base period. The Planning Policy Guidance (PPG) states that self-build or custom builds helps to diversify the housing market and increase consumer choice. In such types of projects, the initial homeowners choose the design and layout of their home, allowing for innovative creativity. On this basis, we consider that the Council should give proper consideration to the identification of a range of specific sites on the edge of existing settlements to be developed for self and custom build homes. This is preferable to requiring large developments (over 100 dwellings) to provide a proportion within the overall site. This would not be appealing to most national house builders and difficult to implement in policy terms. Wyre Forest’s recently adopted Local Plan (SP12) includes a specific policy requiring major development schemes of 50 or more dwellings to “take into consideration the demand shown in the Self-Build and Custom- Build register and where possible provide suitable plots.” Where plots are made available and marketed for at least 12 months, and there is no demand – they may be built out by the developer.
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Q-H4-1: Do you agree with the approach of contributing to meeting the Birmingham and Black Country HMA shortfall to 2031 on the identified sites in Stratford-on-Avon? Yes. South Warwickshire is inextricably linked with three wider housing market areas; Birmingham, Coventry and the Black Country. For Birmingham, the latest evidenced position is that unmet need is in excess of 78,000 houses. This is a materially worsening position, and it is likely that the actual unmet need will be substantially greater at the point of SWLP examination and adoption. Coventry has a significant housing requirement, which it too cannot meet in full. The precise unmet need is being determined, once known this too will need to be factored in.The Black Country is a third HMA which requires the export of housing. It is complicated by the collapse of the Black Country Core Strategy Review, which means that each of the Black Country authorities will need to prepare individual development plans, albeit to some extent based upon the evidence base already prepared. The extent of export from the Back Country is likely to increase over time. Through the Solihull plan examination in 2021 and 2022 it became clear that the Black Country authorities had set a very low bar in terms of ‘sustainability’ so as to minimise the extent of export, we consider that the Black County authorities will revisit this approach and raise the ‘sustainability’ bar, and if this occurs the extent of housing export will increase, and potentially substantially so. The wider HMA issues will need to be factored in to future iterations of the SWLP. It is suggested that the current working assumption of between 5,000 to 10,000 houses (which excludes Coventry) is too low and runs the risk of the SWLP proceeding, undershooting its contribution, and having to be paused to increase the quantum of housing it is delivering. Better to test and assess a bigger contribution now, to allow the SWLP to proceed on its anticipated timeline. Q-H4-2 Please add any comments The Black Country is a HMA which requires the export of housing. It is complicated by the collapse of the Black Country Core Strategy Review, which means that each of the Black Country authorities will need to prepare individual development plans, albeit to some extent based upon the evidence base already prepared. The extent of export from the Back Country is likely to increase over time. Through the Solihull plan examination in 2021 and 2022 it became clear that the Black Country authorities had set a very low bar in terms of ‘sustainability’ so as to minimise the extent of export, we consider that the Black County authorities will revisit this approach and raise the ‘sustainability’ bar, and if this occurs the extent of housing export will increase, and potentially substantially so. The wider HMA issues will need to be factored in to future iterations of the SWLP. It is suggested that the current working assumption of between 5,000 to 10,000 houses (which excludes Coventry) is too low and runs the risk of the SWLP proceeding, undershooting its contribution, and having to be paused to increase the quantum of housing it is delivering. Better to test and assess a bigger contribution now, to allow the SWLP to proceed on its anticipated timeline.
The extent of the shortfall from the wider HMA’s is so significant that by ring fencing its delivery there risks a plan strategy which is driving by HMA issues rather than being developed in the context of sustainable development. Thus, whilst the temptation will be to accommodate housing to serve the wider HMA’s at the northern edge of the SWLP plan area, we consider that the approach should be to a) identify the overall housing requirement for the SWLP having regard to ‘internal’ housing requirements and HMA unmet need; and then b) develop a plan strategy to deliver all of this housing in full. This avoids any form of ring fencing within the SWLP area. It also avoids the complex trigger mechanisms set out in the draft SAP which are, in practice, difficult to apply in a development management context.
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