Issue and Options 2023

Gladman consider the best way to significantly increase the supply of affordable housing in South Warwickshire is to allocate over and above the housing requirement so that affordable housing can be delivered on these sites. This is the approach taken in East Riding of Yorkshire, whereby the Council has opted to increase their housing requirement to ensure that affordable housing needs are met. Whilst this approach is yet to be examined, this is an approach the Councils could consider if it was found suitable. The Councils should also ensure that the affordable housing policy wording regarding the mix of affordable housing is not overly prescriptive. The mix of affordable housing should be determined by local need in the first instance and revised if this presents issues with viability. A suitable level of flexibility will ensure that affordable housing is delivered.

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Yes

Q-H4.1: Gladman agree with the approach to contributing to meeting unmet need from Birmingham and Black Country on the identified sites in Stratford-on-Avon. However, the unmet need from Birmingham has risen since the allocated sites were adopted, therefore the Councils should ensure that they are considering their contribution to the most up-to-date unmet need figure. Q-H4.2: The Councils should ensure that they are discussing the apportionment of unmet need with neighbouring authorities through the DtC in order to address the most upto-date unmet need figures. The adopted Stratford-on-Avon Plan recognises the socio-economic links between Birmingham and Stratford-on-Avon and given the early stage of this Plan, Gladman consider that this is an ideal opportunity to determine the level of unmet need to 2050 and make a meaningful contribution to the delivery of these much needed homes. The current identified shortfall for Birmingham stands at 78,415 homes based on the standard method, and though the Black Country Plan has since been abandoned, the unmet need was forecasted to be between 28,000-39,000 homes, dependent on the scale of Green Belt release. A total unmet need of circa 100,000 homes is not insignificant and Gladman urge the Councils to work closely with neighbouring authorities and collaborate with developers to identify the most sustainable and appropriate for these unmet needs to be met. The Councils may be aware that the Inspectors for the Shropshire Examination in Public have issued interim findings regarding a number of matters raised in the Stage 1 Hearing Sessions in July last year. Of utmost importance are the comments regarding the breakdown of the Black Country Joint Plan, whereby the Inspectors state, ‘Despite this new plan making context, there is no reason before us to find that the identified unmet needs in the Black Country area will disappear’ and that ‘it remains an important strategic cross boundary matter that should not be deferred.’ This makes clear that the unmet housing needs of the HMA have not and will not simply fall away and the Councils should continue to take a pragmatic approach to this strategic cross boundary issues.

Gladman considers that the Council should seek to provide land to meet their housing need and an appropriate level of unmet need from Birmingham and Black Country and Coventry. This is likely to mean that all options need to be explored. Gladman would support the Council in considering the Green Belt boundaries once all suitable land has been considered, and identifying exceptional circumstances to ensure that the housing need is met through an appropriate spatial strategy.

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Q-T1: Please select all options which are appropriate for South Warwickshire with regard to 20-minute neighbourhoods. Gladman supports the general aim of these options to ensure that new residential developments fulfil the principles of 20-minute neighbourhoods. However, whilst recognising that it is a useful tool, it should not be used as a tool to arbitrarily restrict development, therefore Gladman suggest that Option T1a or Option T1b would be the most suitable approach as they don’t make the 20-minute neighbourhood a policy requirement but recognise the principles. Residential development in sustainable locations that do not meet the principles of the 20 minute neighbourhood could help a smaller settlement, or cluster of settlements remain viable. It is important to consider existing services and facilities in a settlement when assessing their suitability for accommodating new growth. Daily needs are particularly important with a primary school, shop and access to public transport being the key considerations. It must be recognised that it may be possible, through new development, to improve some of these services and facilities, particularly access to public transport, that should be considered in any settlement hierarchy exercise as well as the role that new development can play in ensuring these facilities are maintained and are not lost because of a lack of support or meeting the 20 -minute neighbourhood principles.

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Q-B1: Please select the option which is most appropriate for South Warwickshire with regard to Areas of Restraint. Gladman consider that the Areas of Restraint should be removed from the South Warwickshire Local Plan as they have the potential to arbitrarily restrict development. However, should the Councils consider it most suitable to keep and/or introduce Areas of Restraint, the policy wording as adopted in the Stratford-upon-Avon Core Strategy which states that ‘planning permission for a large scale form of development in an Area of Restraint will only be granted where a scheme would have demonstrable community benefits and contribute significantly to meeting an objective of the Core Strategy.’ This flexibility ensures that the policy does not stop suitable and sustainable development sites from coming forward as and when required. Q-B3: Please select the option which is most appropriate for South Warwickshire with regard to Special Landscape Areas. Gladman consider that Option B3c: Discard Special Landscape Areas and bolster general landscape policy. A general landscape policy would ensure that development is not overly restricted on landscape grounds and would allow landscape impacts associated with development to be considered in a planning balance exercise. Q-B4: Please select the option which is most appropriate for South Warwickshire with regard to the AONB. Gladman do not consider Option B4b to amend the current AONB policy to include a buffer to be appropriate and consider Option B4a to be the most appropriate. This will ensure that the Cotswold AONB maintains the current level of protection afforded by national planning policy. Q-B8.1: Any policy concerning the development of best and most versatile (BMV) agricultural land should be consistent with the requirements of the NPPF which makes clear at footnote 53 that where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality.

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