Issue and Options 2023
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New searchQ-S1: Please select the option which is most appropriate for South Warwickshire Crest Nicholson supports option S1a. The Councils should identify at the earliest possible stage in the development of this Local Plan which assets it wishes to protect, along with a clear rationale and justification for the selection. This should ensure that the preferred development options are not unduly constrained or compromised at a later date and thereby reduce delays to progression of the Local Plan. Q-S2: Please select all options which are appropriate for South Warwickshire Chapter 11 of the NPPF encourages effective use of land, including: taking into consideration the need for different types of housing; the desirability of maintaining an area’s prevailing character and setting; and the use of minimum density standards for city and town centres and other locations that are well served by public transport. Crest Nicholson therefore recognises that there is role for the intensification of development in certain areas of the Local Plan area as part of the wider strategy. However, development site character and context will vary significantly across the Local Plan area, both within town centres and outside of the town centres. Planning policies will need to be sufficiently flexible to be able to accommodate this. Accordingly Crest Nicholson supports option S2b, to enable the well-planned best use of available land, incorporating intensification where appropriate but without prejudicing the need to reflect context and character on a site-by-site basis, particularly on the rural fringes of settlements. Q-S3.2: Please select the option which is most appropriate for South Warwickshire Paragraph 119 of the NPPF is clear that planning policies should make effective use of land, including as much use as possible of previously-developed or “brownfield” land. Furthermore, NPPF paragraph 120 states that planning policies should give substantial weight to the value of using suitable brownfield land. Nevertheless this should be viewed in the context of NPPF paragraph 73, which identifies that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as extensions to existing villages and towns, provided that they are well located. Although significant encouragement is given to the development of brownfield land, it is still necessary to provide an adequate justification for the use of brownfield land in accordance with the strategy for the sustainable distribution of growth within the Local Plan area. It should not the case that brownfield land should be considered over all other options if the specific sites are not suitable, viable, deliverable or sustainable locations for housing in line with the Council’s strategy. In particular, the deliverability of development on brownfield land can be significantly impacted by existing ground conditions and the necessary associated site clearance and mitigation works. This can result in delays to delivery and greatly increase development costs, thus negatively impacting on scheme viability and wider housing delivery across the plan period. To ensure a plan led approach, the Council’s strategy should be to follow a clear locational strategy that promotes sustainable development, which includes the optimisation of brownfield land where appropriate, whilst also acknowledging the role that greenfield land should play. This approach is considered to be a variation of option S3.2a. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? As included in response to QS3.2, NPPF paragraph 73 identifies that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as extensions to existing villages and towns, provided that they are well located. The growth of existing settlements, to take account of the existing services, facilities and infrastructure that is already in place, therefore needs to be part of the overall strategy. Crest Nicholson supports the existing main settlements being part of the overall Local Plan strategy and the preferred Spatial Growth Option. As set out in Option F (Main Urban Areas) of the Scoping for the South Warwickshire Local Plan (2021) there is a significant benefit arising from delivering new homes and jobs in and around the five main urban areas in South Warwickshire, as well as the edges of the adjacent urban areas of Coventry and Redditch. Crest Nicholson contends that whilst Coventry is not within the Local Plan area, it is immediately adjacent to the Local Plan area, and is connected to this area both in terms of infrastructure and commuting patterns. The consideration of land on the edge of Coventry is also important at this stage of the process given that there is a recognition that the Local Plan area may need to play a role in accommodating the sustainable growth of and / or the unmet need from Coventry. It is noted that ‘Evolving the Spatial Growth Options – The Story So Far’ Topic Paper (August 2022), concluded that Option F should not be taken forward as a stand-alone scenario but ‘urban areas however remain a component of all the other growth scenarios’ (Appendix 2). As such it is maintained that all of the Growth Options set out in the Issues and Options document should include growth along the boundary with Coventry, as shown in the adjacent figure extract from Option F. Option F can be combined with any of the Growth Options (albeit has particular synergy with Growth Option 4: Sustainable Travel and Economy), given the ability to locate homes close to, or on public transport links to, existing jobs and potential new job locations. As set out in the Issues and Options consultation document a ‘growth option where jobs and homes are co-located means that more people are given the option of living close to their place of work’ (page 96). Crest Nicholson is keen to highlight that its site to the South of Westwood Heath Road, which is predominantly within the ‘South Coventry’ area has the potential to deliver additional housing within this area, as a modest extension to its existing committed housing development. Further details of this are set out in the accompanying Vision Document. Q-S5.2: Do you think new settlements should be part of the overall strategy? The delivery of new settlements should be taken into consideration as part of the wider strategy, given the potential that they offer to make a significant contribution to new housing delivery. It should however be recognised that the delivery from large strategic sites can be slow in the early stages of the new Local Plan period. As set out in the Lichfields ‘Start to Finish Report’ (Feb 2020) the average time from the validation of first application to completion of the first dwelling for a scheme of 2,000+ dwellings is 8.4 years. As such it is crucial that a sufficient number of smaller sites are identified to address the first 10 years of the plan period, and to complement the delivery of larger strategic sites and / or new settlements throughout the Local Plan period. Q-S5.3: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? In relation to the location of new development in general, and not just limited to the locations of new settlements, and as identified in the response to Q-S7.2, Crest Nicholson is supportive of the opportunities arising from locating new development close to public transport corridors, including rail corridors. The South Warwickshire authorities benefit from a large number of railway stations which provide links to a multitude of locations across both HMAs and the wider region. Issue S6: A review of Green Belt Boundaries Whilst a question is not posed for Issue S6 (Green Belt), Crest Nicholson would support the undertaking of a review of the Green Belt in order to inform the assessment of the most suitable and sustainable sites for release from the Green Belt within South Warwickshire. The planning system must make land available in the right places and for the right form of development. The undertaking of a Green Belt Review is an essential part of the process of making developable land available in the most sustainable locations. NPPF paragraph 142 highlights that when drawing up or reviewing Green Belt boundaries the need to promote sustainable patterns of development should be taken into account. National policy currently identifies that Green Belt boundaries can only be altered in exceptional circumstances through the preparation of Local Plans, and this provision is expected to remain through the current review of the NPPF, along with the Sustainability Appraisal requirement for LPAs to review and assess reasonable alternatives. In establishing the housing requirements for an area, particularly if affordability concerns are to be addressed at larger settlements surrounded by Green Belt, Green Belt cannot currently be used as: the sole justification to direct development elsewhere; or as the sole justification to artificially suppress housing delivery; or the rationale for distributing housing to less sustainable locations. The 300,000 homes a year target set by the Government, and the subsequent response to the consultation on housing numbers in December 2020, identifies Coventry and Birmingham as being two key areas for housing growth to meet the target. South Warwickshire is adjacent to the Coventry City Council administrative area. Whilst the evidence base to underpin the new Coventry Local Plan is not yet available it is expected that Coventry City Council will be unable to meet its housing needs in full and this unmet need should be considered as a key part of the strategy for the South Warwickshire Local Plan from the start of the Local Plan-making process. A Green Belt Review should form part of the evidence base to inform the Local Plan. The delivery on Crest Nicholson’s existing housing commitment immediately to the south of Westwood Heath Road is on land previously removed from the Green Belt on the edge of Coventry, and will contribute to the housing needs of Coventry City. The current planning permission (W/22/0055) relates to most, but not all, of the existing Warwick Local Plan allocation H42. There is still land in the southern part of H42 which has been removed from the Green Belt for development which has not yet been subject to approval for residential development. Crest Nicholson has undertaken a further review of environmental and technical considerations relating to the remaining area of allocation H42 and considers that the additional vehicular traffic movements that might arise from further development in this location can be accommodated within the capacity of the local highway network and that the landscape and heritage impacts of development in this location can be mitigated and accommodated to avoid significant harm arising. This is set out further in a Vision Document that has been submitted in support of these representations. Crest Nicholson considers that it is important that the South Warwickshire Councils give full consideration to maximising the capacity of land already removed from the Green Belt for development within existing Local Plan allocations as part of the development plan strategy, along with the potential to remove further land from the Green Belt in sustainable locations in order to meet the development needs arising. Q-S9: Please select the option which is most appropriate for South Warwickshire There will be a need for Part 1 Local Plan policies to be applied in a consistent way across the whole of the Local Plan area. If policy provisions seek to control what development can occur within and outside of settlement boundaries then there would be logic to ensuring that the approach to setting settlement boundaries is also consistent across the Local Plan area. There is an opportunity for this consistency to be achieved in the first instance through the Part 1 Local Plan. This approach will however need to acknowledge that the South Warwickshire Councils are currently not planning to identify all of the allocations needed to meet the development requirements for the Local Plan period through the Part 1 Local Plan and that some of these will need to be met through the Part 2 Local Plan and / or through Neighbourhood Development Plans. As set out in the response to Q-I2, such an approach is seen to be counter-intuitive, but if this is carried forward then the Part 1 policies will need to ensure that it is made clear that any settlement boundaries shown within the Part 1 Local Plan can be subject to review through the Part 2 Local Plan and Neighbourhood Development Plans in order to accommodate the additional site allocations deemed necessary to meet the housing needs of the Local Plan period.
Crest Nicholson welcomes the fact that the Issues and Options consultation document recognises the affordability of housing across South Warwickshire as a key issue, particularly for younger people and others who work in the area on lower incomes. The need for a greater focus on affordability, tenure type, and mix of housing to be delivered in the South Warwickshire is an important aspect of delivering sustainable communities. Housing stock is the most appropriate indicator of housing supply and housing need. Where past housing delivery has not met housing need, this results in suppressed household formation in younger age cohorts and an imbalance between housing supply and housing demand. In turn, this has influenced the increasing gap between average incomes and average house prices. Getting this mix of homes right will maximise the beneficial impact that the delivery of more homes can bring. For example, planning for the right size homes can help address affordability and planning for specialist housing such as older peoples’ housing in the right locations through allocations can have the knock-on effect of freeing up much needed family homes. It is essential that a mix is not prescriptive and is flexible and it should be recognised that not doing so will result in a mix that becomes redundant over time and harm the social outcomes it was designed to achieve. This will especially be the case over a long plan period, where flexibility will enable the mix to be best tailored to the needs of new communities across South Warwickshire. In addition, planning for more routes into home ownership, such as First Homes and Shared Ownership, will help younger people make that important first step onto the housing ladder. This objective is important to develop and sustain a mixed community to support economic activity and growth. The South Warwickshire Local Plan, and any associated CIL charging also needs to reflect the fact that the contributions and provisions expected from development arising from planning policy requirements should not cumulatively undermine the deliverability of the Local Plan. Robust regard should be given to this through the Local Plan viability assessment work when this is carried out. The unintended consequence of overloading development with additional technical, design and financial requirements could be that the amount of affordable housing being delivered ends up being reduced in order to make a development viable. Furthermore, as identified in response to Q-H2-1, the supply of affordable housing, and the affordability of housing in general, is also influenced by the overall supply of housing coming forward. The South Warwickshire Plan should accordingly be seeking to plan for the delivery of more than the minimum number of homes identified by the HEDNA to assist with this. It is important the solutions for addressing the affordability gap are addressed at the earliest stages of policy-making and through undertaking site assessments for allocations.
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Planning for a range of types and sizes homes in suitable locations, as well as homes that are capable of adaptation to respond to changing requirements, can help address affordability and provide opportunities for the housing needs of older people to be met
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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 District? The shortfall being planned for through the emerging Stratford on Avon Site Allocations document to meet a previously-identified unmet need arising from the Birmingham and Black Country HMA is separate (in terms of scope, area and documentation) to the considerations underway for the South Warwickshire Local Plan. This current consultation should focus on what the appropriate strategy should be for the combined area, in the context of the wider relationships with different HMAs for the Plan period up to 2050, and should be based on the latest housing data. 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 The housing need within the Greater Birmingham and Black Country HMA is still under review, following the halting of the joint Black Country Local Plan. The Black Country authorities are currently reconsidering their housing needs and how this will impact on the wider HMA. In light of this, the significant housing shortfall identified by Birmingham City Council, and the likelihood that Coventry City Council will not be able to accommodate all of its housing needs (even at the reduced trend-based level of 1,964 homes per annum), the South Warwickshire authorities will need to consider how additional unmet need from these areas could be accommodated within the Local Plan area. It is noted that page 109 of the Issues and Options consultation document highlights that 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. Crest Nicholson contends that areas should be being considered from the start of the Local Plan review process which are / could be able to accommodate unmet need. This includes established residential locations on the edge of Coventry City. There is a need for the South Warwickshire Councils to continue to monitor the housing capacity studies being undertaken in the Birmingham and Black Country HMA and by Coventry City Council to assist with identifying what appropriate contributions it might need to make to assist with meeting the unmet need.
The links with Coventry City arise through commuting patterns, as well as the physical location of Warwick District on the edge of the Coventry built up area. The relationship with the Birmingham and Black Country HMA is intrinsically linked to the migration / commuting patterns. Good connectivity with the primary transport infrastructure in both instances is important, notably in relation to the sustainable travel infrastructure to provide access to the relevant, employment, leisure and community facilities, both within this external HMA and within the South Warwickshire Local Plan area. Sites for housing development should be located where this can be achieved. As identified in response to Issue 6 (Green Belt) and in response to the identified spatial growth options, a spatial distribution strategy which capitalises on opportunities provided by the existing sustainable transport network, as well as providing good connectivity between homes and employment opportunities in main towns is important. Locations that can achieve this through existing sustainability credentials, or can be made more sustainable through additional development, should be considered for allocation. This should include appropriately located land in the Green Belt or land that has already been removed from the Green Belt in order to meet development needs. In the case of meeting some of the housing need for Coventry, and in the context of locating development in close proximity to sustainable travel routes to Birmingham, the expansion of the committed Crest Nicholson housing site to the south of Westwood Heath Road can make an important contribution. This site is considered to be capable of providing c.50-150 additional homes over and above the current allocation for 425 units, which is currently being built out. Further details are set out in the Vision Document accompanying these representations.
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Q-H1-1: The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014-based household projections towards a trend-based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? The NPPF (paragraph 61) identifies that in order to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method, unless exceptional circumstances justify the use of an alternative approach. Such an alternative approach should reflect current and future demographic trends. It is acknowledged that the ONS has highlighted that the 2014-based household projections gave rise to inconsistencies with the resultant housing need figure for Coventry. The South Warwickshire Councils are in a Housing Market Area (HMA) with Coventry. In this context this current Local Plan review process provides an opportunity to consider what the need for Stratford on Avon and Warwick District Councils might be if more up to date household formation figures are taken into account within the HMA. It is understood that the approach followed through the HEDNA seeks to achieve this. Whilst the output from the HEDNA results in a slight lowering of the overall HMA need on a dwelling per annum basis, it is noted that the trend-based figures identified for Warwick and Stratford-on Avon Districts represent an increase over and above the standard method based equivalents. This is influenced by the high levels of net migration projected for these Districts within the HEDNA. It is accordingly considered to be a sensible and robust approach for the South Warwickshire Local Plan to be planning for, and identifying allocations to meet, this higher figure in order to ensure that there is a sufficient supply of homes coming forward in this area, as a minimum. Due regard should also be given through the Local Plan process to the opportunity to increase provision against this figure to both ensure that there is a sufficient supply and variety of housing sites to enable the Government’s aim of significantly boosting the supply of housing (NPPF paragraph 60) to be met, but to also ensure that the issue of housing affordability within this area is also appropriately addressed. It should also be recognised that the unmet need arising from Coventry will not be crystallised until further evidence base reporting is published by Coventry City Council on the capacity of land within its administrative boundaries. There may therefore be a need for the South Warwickshire Local Plan to allocate additional land to assist with meeting any unmet need for Coventry, with appropriate regard given to the opportunity provided by land on the southern edge of Coventry (south of Westwood Heath Road) to assist with achieving this. Q-H2-2: Please select the option which is most appropriate for South Warwickshire: Crest Nicholson considers that the market dynamics and demand within the South Warwickshire area should be taken into consideration when setting the affordable housing approach. This should give regard to the data included within the HEDNA, as well as the scenario testing and analysis undertaken through the viability assessment work when this is undertaken. This may highlight that particular areas, sizes of site or types of site should be assigned a lower affordable housing figure or may show that a Local Plan wide area based approach works or that a LPA area based approach works. There is not considered to be sufficient information available in the public domain at present to be able to provide a firm answer to this question. Further evidence needs to be made available, notably with respect to viability. Q-H3: Please select all options which are appropriate for South Warwickshire It should be noted that across South Warwickshire there is a strong demand for new homes and these sell, despite the adopted Local Plan not including policy requirements which bring in these additional Technical Standards. There is therefore not considered to be a need to introduce such standards in order to deliver homes that meet market demand. It would be for the South Warwickshire Councils to demonstrate through an appropriate evidence base that the imposition of additional Technical Standards. NPPF footnote 49 states that policies may also make use of the nationally described space standard (NDSS), where the need for an internal space standard can be justified. In relation to the NDSS the PPG (Paragraph: 020 Reference ID: 56-020-20150327) identifies that LPAs need to take account of need, viability and timing. In relation to the M4(2) and M4(3) standards the PPG (Paragraph: 007 Reference ID: 56-007-20150327) states that there is a need for LPAs to give regard to: the likely future need for housing for older and disabled people (including wheelchair user dwellings); size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes); the accessibility and adaptability of existing housing stock; how needs vary across different housing tenures; and the overall impact on viability. This evidence base has not been made available to provide clear justification to support the inclusion of these additional technical standards alongside the Issues and Options consultation. Therefore as it stands Option H3d would represent the current position. Q-H5: Please select all options which are appropriate for South Warwickshire Crest Nicholson considers that Option H5c is appropriate for meeting any identified requirement arising during the Local Plan period. The requirement for custom and self-build housing plots need to be determined on a case by case basis. The very nature of self and custom build housing means that it is difficult to plan for precise locations of delivery. Such requirements should be based on local evidence such as the self and custom build register and local eligibility test (See PPG Reference: Paragraph: 025 Reference ID: 57-025-20210508). Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire No further comment at this stage. There will be a need to review the position relating to the delivery of homes in South Warwickshire when more evidence is made available to inform the needs and strategy for this area.
Q-C3.1: Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site? It is important that new planning policy requirements are soundly based and include flexibility to enable them to respond to the specific circumstances faced by individual sites / developments in terms of development type, physical characteristics and local market economics. A carbon offsetting approach would provide an opportunity for developments to mitigate their impact against any evidenced policy requiring zero carbon development where the requirements cannot be met on site. However any approach relating to carbon offsetting would need to be supported by a mechanism setting out how this would be applied in practice, identification of receptor sites / schemes for the funds paid and a demonstration through the local plan viability work that this would not adversely impact on the viability and deliverability of development (as recognised by NPPF paragraph 34).
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