Issue and Options 2023
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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.
Q-H1-1: The latest HEDNA suggests exceptional circumstances exist to move away from the Standard Method for determining housing need as there are alleged issues with existing census data in estimating and projecting the population in Coventry. 4.4 The HEDNA has therefore modelled new demographic projections which take account of the initial 2021 Census data releases and seeks to assess how the population can be expected to change over time by applying more up-to-date assumptions about fertility, mortality and household formation rates. The HEDNA then applies these alternative projections through the framework provided by the standard method. The HEDNA suggests that, based upon the trend-based projections, whilst the housing need in Coventry City may have reduced, the housing need for Stratford-on-Avon has increased from 564 to 868 dwellings per year (304 dwellings per year / 53.9% increase). Similarly, the need for Warwick District has increased from 675 to 811 dwellings per year (136 dwelling per year / 20.1% increase). The total housing need for both Districts (and therefore South Warwickshire) has accordingly increased from 1,239 to 1,679 dwellings per year (440 dwellings per year / 35.5% increase). 4.6 The housing need across the Plan Period has therefore increased from 30,975 to 41,975. This figure represents the minimum need that should be planned for and does not includ e any unmet need from neighbouring authorities (such as Coventry or Birmingham) which may be accommodated, or any additional homes that may be planned for to meet other socio-economic objectives (such as increasing affordable housing provision – see answer to Question H2-2). 4.7 Should the authorities choose to pursue the trend-based alternative, they must accept that their housing need increases substantially and that this need must be met, as a minimum. It would not be acceptable to reduce the level of housing provided within Co ventry whilst seeking to retain the need for Stratford and Warwick suggested by the Standard Method.
Table 8.45 of the HEDNA (reproduced at Table 10 of the Consultation Document) identifies that there is a total annual affordable housing need of 547 dwellings in Stratford and 839 dwellings in Warwick (totalling 1,386 homes per year). This need is significant and, in the case of Warwick, is in excess of the trend-based alternative figure for overall housing provision that is also suggested by the HEDNA (811 dwellings per annum). 4.9 Caddick Land submits that the only way to realistically deliver affordable housing at a level that is anywhere close to the level of identified need would be for both Councils to allocate a greater number of sites to deliver market housing over and above the minimum need identified by the HEDNA (either Standard Method or trend-based alternative). Such development would include a portion of affordable housing, in line with the relevant Local Plan policy. At present, there is a policy requirement for 35% of proposed residential dwellings to be affordable homes in the Stratford District and 40% in the Warwick District. 4.11 As such, if the total trend-based alternative need figure (1,679 dwellings) was provided annually, and assuming affordable housing was provided at 40%, this would result in the provision of 671.6 affordable homes per year; 714.4 dwellings per year less than the identified annual affordable housing need. 4.12 It therefore follows that housing should be planned for in excess of twice the annual trendbased alternative need suggested by the HEDNA. 4.13 Whilst this may be unrealistic, it remains more feasible than alternatives such as relying on affordable housing exception sites, relying on the Councils to deliver ‘Council housing’, or increasing the percentage of affordable housing provided on housing sites to unviable levels. 4.14 As a result, whilst acknowledging that the full scale of the affordable housing need is unlikely to be met, it remains that both Councils are obligated to allocate sites for housing significantly in excess of the trend-based alternative figure suggested by the HEDNA (41,975 dwellings across the Plan Period) and that all options to do so have been fully explored and exhausted, including Green Belt release. Greenfield development sites have a proven track record of delivering affordable housing as are not subject to viability considerations that often lower obligations on brownfield sites. They therefore form a critical part of any strategy to increase housing affordability. Q-H2-2: Caddick Land acknowledges the need for affordable housing across South Warwickshire, but reiterates that market conditions and housing need should be taken into account by the Councils. Given that market conditions and housing need (both market and afford able) vary across South Warwickshire, it is considered that it is most appropriate for each authority to have a separate affordable housing requirement (Option H2-2b). Similar to CIL, it is important the two district’s keep their affordable housing require ments 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 0044 (Reference ID: 23b-004-20190901) which sets out that plan makers should consider how needs and viability may differ between site typologies. 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. 4.16 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 004 5 (Reference ID: 23b004-20190901) which sets out that planning obligation 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, Caddick Land cannot comment on details relating to specific quantified amounts, as there is no viability evidence presented alongside this consultation at present. 4.17 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.
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Issue H4: Accommodating housing needs arising from outside of South Warwickshire 4.23 Caddick Land supports both Councils in recognising that they have a responsibility to contribute towards meeting unmet housing needs arising from within both Birmingham and Coventry. Caddick Land also supports the recognition that, even if the trend-based alternative approach to housing need is pursued, Coventry may not be able to accommodate all of its revised housing need (1,964 homes per annum). Q-H4-2: In addition to the existing shortfalls identified for the period to 2031, Birmingham City Council has also commenced work on its Local Plan Review to 2042 and has recently published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes to 2042. Additional shortfalls may also be identified arising from the Black Country authorities, notwithstanding the cessation of the Black Country Core Strategy. 4.25 The Consultation Document identifies that, for the purposes of the accomp anying Sustainability Appraisal, Stratford and Warwick District Councils have tested the effects of an additional 5,000 and 10,000 homes. 4.26 Caddick Land broadly supports this approach, although no clear justification or rationale has been provided to justify the range of homes to be ‘tested’. 4.27 Furthermore, it is important to note that this unmet need covers the period to 2042, whereas the South Warwickshire Local Plan is proposed to run to 2050. Any contribution towards this need made within the South Warwickshire Local Plan should accordingly be capable of being delivered within the required timeframe, and not left until the end of the South Warwickshire Local Plan period.
As acknowledged within the Consultation Document, there is a strong argument that, if homes are being provided to meet needs arising in Coventry and Birmingham, then those homes should be located as close as possible to the source of those needs in order to minimise travel. 4.29 As such, sites along the railway corridors and near the M40, as well as those with good connectivity to these locations, are likely to help accommodate unmet need from Birmingham and the Black Country, whilst sites south of Coventry can be identified and serve the wider housing shortfall of Coventry. However, these locations cannot then also serve local needs. Consequently, local need should be more evenly distributed across South Warwickshire, with proportionate growth delivered adjacent to existing settlements as part of an overall wider growth strategy. 4.31 Lastly, linked with our responses to Questions S3-1 and H1-1, the meeting of additional unmet need from neighbouring authorities is likely to necessitate the development of greenfield (and Green Belt) land.
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Q-C2: Caddick Land considers that Option C2a is the appropriate Option for South Warwickshire. However the wording of Option C2a needs amending to remove the word ‘require’ and replace with ‘encourage.’ Furthermore, the size threshold needs to be specified, sup ported by relevant evidence, including viability. The NPPF states within Paragraph 155 to help increase the use and supply of renewable and low carbon energy and heat, plans should identify opportunities for development to draw its energy supply from decentralised, renewable or low carbon systems. 5.2 In addition, the Council must ensure Plan compliance with Paragraph 157 of the NPPF, whereby development should comply with any new development plan policies for decentralised energy unless it can be demonstrated by the applicant that it is not feasible or viable, thus ensure policy wording is reflective of viability concerns and allows for flexibility where these scenarios can be illustrated. Q-C3.1: A carbon offsetting approach should be introduced as part of the new Local Plan to allow for flexibility in instances where it is not feasible to achieve net carbon zero requirements on a site, whether that be due to site constraints, viability or practicality of being able to develop the site. However, it is important to consider the offsetting costs fr om a viability perspective and ensure sufficient viability testing has been conducted to support the Policy.
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The dates and thresholds should be realistic and justified, but underpinned by evidence undertaken by the Councils. The approach should correspond with Part L of the Building Regulations to ensure consistency throughout. It is important to also accord with the NPPF, which sets out within Paragraph 152 that the planning system should support the transition to a low carbon future in a changing climate, thus any proposed planning policy should be transitional, but also prepared positively, ensuring aspiration but deliverability, as per paragraph 16 of the NPPF.
Q-C4.1: Option C4.1a should be pursued by the Councils, whereby national Building Regulations will stipulate the levels required for new buildings in order to minimise emissions. The national Building Regulations will be updated, in accordance with the climate emergency and net-zero carbon agenda pursued by the Government. This will ensure that new developments align with planning policy and building regulations. Whereas, by utilising Option C4.1b, setting higher standards, will make new developments more expensive due to the additional requirements to be met in order to achieve policy compliance, which will impact upon the overall viability of the scheme, and ultimately affect obligations, in terms of the quantity of affordable housing that can be required, the infrastructure requirements and other associated financial contributions, which would have a greater negative effect, where the harm would outweigh the benefit. 5.5 Overall, Option C4.1a would ensure that new development is built in accordance with National Building Regulations, therefore ensuring that homes must produce 30% less carbon dioxide emissions than previous standards, which will increase to 75 -80% less emissions by 2025, to eventually become zero-carbon. This structure therefore clearly demonstrates the need for developments to acknowledge the need to reduce carbon emissions, which will increase gradually, achieving South Warwickshire’s desire to be carbon neutral, thus achieving sustainable developments. Q-C6.1: Caddick Land acknowledges that it is important to consider the emissions resulting from materials, construction activities and the use of a building over its lifetime. However, the Councils have not presented any evidence to justify the options presented at this stage. Therefore, at present, without viability evidence and a baseline for emissions data, it is not possible, or justified to introduce Option C6.1a as a Policy. Option C6.1a would have a detrimental impact upon the viability of developments, and would potentially impact upon delivery of sites coming forward. A Policy requiring new developments to have a target for 100% reduction in embodied emissions would negate the requirements of the Plan to deliver much needed houses and employment land, and therefore not achieve the overall Vision. 5.7 To put this Option into perspective, within London, only those developments that are referrable to the Mayor are required to produce and calculate a whole life-cycle carbon emission assessment. Furthermore, paragraph 152 of the NPPF sets out that the planning system should support the transition to a low carbon future, noting the word transition, as such the proposed 100% reduction does not accord with a transitional approach. Option C6.1b provides potential for a flexible approach, whereby developments of certain size criteria should demonstrate their calculations within a whole life-cycle carbon emission assessment, however the required reduction in embodied emissions needs to be viability tested and strongly considered, as this may negatively impact upon sites coming forward for development. The Council also need to decide their priorities in terms of what they want developments to achieve, as having a higher required reduction in embodied emissions, may then impact upon the ability to provide the policy required affordable housing percentage, or the required additional infrastructure. The Issues and Options Document sets out that ‘the SWLP must contribute to the achievement of sustainable development, and this means balancing the need for more jobs and homes against the impact on the built and natural environment.’ Consequently, the Councils need to establish the balance and levels of priority, in order to establish the requirement of this proposed policy. Caddick Land suggests further evidence is conducted by the Councils to decipher the potential requirement and to establish their balance in greater detail, followed by further stakeholder engagement on the matter. Q-C6.3: Caddick Land reiterates that the Councils need to undertake greater research to inform their evidence base in relation to reducing embodied emissions and thus whole lifecycle emissions. Caddick Land acknowledges the need to consider the carbon emissions associated with the process of developing a site, taking into account during construction and operationally, however re-emphasises the need for the Councils to consider viability of sites. The councils need to strike a balance between the deliverability of housing and employment land, to ultimately achieve sustainable development and the overall vision of the Local Plan, whilst also considering the environmental impacts and the opportunities available to minimise carbon emissions. 5.10 As per Paragraph 009 (Reference ID: 6-009-20150327), there is a requirement for local planning authorities when setting any local requirement for a building’s sustainability to do so in a way consistent with the government’s zero carbon buildings policy, ie in accordance with Part L of the National Building Regulations. The PPG continues to state that local requirements will need to be based on robust and credible evidence and pay careful attention to viability.
