Issue and Options 2023
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New searchQ-S9: Please select the option which is most appropriate for South Warwickshire Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. 2.44. Of the options presented the Respondent considers that a consistent approach across Stratford-on-Avon and Warwick District is most appropriate and would therefore lean towards Option S9b as being the most appropriate option for South Warwickshire. 2.45. The Consultation Document notes that one disadvantage of this option is that some non-strategic land allocations will likely not be made until Part 2 comes forward and that it would be difficult to make appropriate revisions to boundaries in advance of these non-strategic allocations being made. The Respondent does not disagree and considers this to be one of a number of disadvantages in proceeding with a two-tier plan rather than a single one as discussed under Q-P1.2.
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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? Y/N/DK 2.46. Yes. Overall, the Respondent considers that the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, it should be noted that the level of future housing need stated in the HEDNA is a floor figure and does not include any unmet housing needs that may arise from other local authorities, which still needs to be established under the duty to cooperate. 2.47. In setting a housing requirement for the plan area it is suggested that the Councils look to allocate significantly more sites than may be required to meet the minimum housing need identified in the HEDNA to increase the supply of affordable housing and attempt to address the issue of affordability in both districts (discussed further under Question Q-H2-1 below). This could be reasonably achieved through the application of a reasonable buffer on top of the minimum housing need identified, which the Urban Capacity Study would also appear to recommend.
2.48. Fundamentally, the best way to increase the supply of affordable housing across South Warwickshire is to allocate more land for market housing (a proportion of which would be delivered as affordable). 2.49. The principal barrier to a housing development’s ability to deliver affordable housing is viability, which is particularly less assured on brownfield sites and in new settlement allocations hence why affordable housing provision is inevitably reduced on such sites. The Councils therefore need to carefully consider the impact of their preferred strategy, along with the financial implications that other policy requirements may have on the provision of affordable housing, for affordable housing provision to remain viable throughout the plan period and to boost supply. 2.50. While it is appreciated that building more houses does not necessarily bring the value of homes down, ensuring that more than enough land has been allocated to meet housing needs will greatly assist in the timely delivery of market housing which, assuming that other policy requirements are pitched correctly, will translate to the timely delivery of an increased quantum and range of affordable housing product.
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Q-H2-2: Please select the option which is most appropriate for South Warwickshire: Option H2-2a: A single South Warwickshire wide affordable housing requirement 2.51. The Respondent considers that a consistent approach with regards to affordable housing should be applied across both Districts. Accordingly, of the options presented, Option H2-2a is probably the most appropriate in that it would appear to give the greatest certainty to developers and avoid making some areas more attractive than others. However, whatever the option that is settled upon it is imperative that the approach is thoroughly tested in terms of its viability and is appropriately justified.
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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. 2.52. The Respondent agrees that should the Councils wish to impose minimum space standards that they should be adopted as development plan policy. 2.53. The Councils’ aspiration to raise the standard of design of new homes in South Warwickshire is understood. However, given the notable unaffordability issues within the Warwick and Stratford Districts where house prices are around 25% higher than the rest of the HMA, the Respondent has significant reservations regarding the imposition of space standards. Specifically, the respondent is concerned about the implication that such standards could have on the viability of sites, as well as the affordability of new homes given that properties are generally valued and sold on a £ for square ft basis. 2.54. Should the Council wish to introduce the application of Nationally Described Space Standards (NDSS) or optional Building Regulations M4(2)/M4(3) then Footnote 49 of the NPPF makes clear that the need for such standards needs to be justified. Further work will therefore need to be undertaken to demonstrate an appropriate justification. 2.55. For the avoidance of doubt the Respondent would strongly object to the imposition of space standards beyond NDSS.
2.57. Birmingham City Council has identified a shortfall of 78,415 homes in its Local Plan Review 2042 Issues and Options Consultation Document, which equates to approximately 55% of the City’s total housing need (based on the latest HELAA). Under the current adopted Birmingham Local Plan the shortfall is 38,000 homes to 2031, which the Greater Birmingham and Black Country Strategic Housing Needs Study indicated would largely need to be met on greenfield sites, including green belt land outside Birmingham’s administrative area. Options, including urban extensions and growth around railway stations, were also identified as possible ways of addressing the shortfall.” (Black Country Plan Issues and Options, Paragraph 3.11). 2.58. The SWLP Consultation Document suggests that additional shortfalls could also arise from the Black Country authorities. The magnitude of the shortfall that the SWLP might need to accommodate up to 2050 therefore has the potential to be quite significant. On which basis it is imperative that the relevant Councils engage fully as a matter of urgency in the duty to co-operate process to establish what percentage of the identified shortfall the SWLP plan area will be responsible for.
2.59. The Respondent considers that if shortfalls from outside of South Warwickshire need to be meet then these would be best accommodated close to the source of those needs and/or locations that are proximate in terms of sustainable transport connections, and particularly rail services, which benefit from a reasonable commute. Such locations are likely to reside in the Green Belt. 2.60. For the reasons explained under Q-S5.2, the Respondent would caution the Councils against the development of a growth strategy that is overly reliant on the delivery of new settlements and should also look to maximise opportunities adjacent to existing settlements with sustainable transport connections and particularly rail.
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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? Y/N/DK 2.56. Yes broadly. The Respondent agrees that there is a strong argument that the homes needed to contribute to the Birmingham and Black Country HMA shortfall to 2031 should be located close to the source of those needs. However, the Respondent considers that locations that are proximate in terms of sustainable transport connections, and particularly rail services, which benefit from a reasonable commute to sources of need should also not be ruled out.
