Issue and Options 2023
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New searchDLPDS consider that the proposed Vision is appropriate in general terms. However, the proposed Vision refers to meeting unmet need from neighbouring authorities, whereas it would be more appropriate to reference meeting unmet needs from the wider Housing Market Areas. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they are part of the same Housing Market Area, and should not be excluded.
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The marketing undertaken for the DLPDS land at Abbey Park suggests that there is low demand for offices at this particular location. The HEDNA recognises that office floorspace needs are focussed on Coventry and Warwick, which are the main office markets in the sub-region, followed by Stratford-on-Avon. It also recognises that office floorspace delivery has increased in Coventry in recent years, as a result of the Friargate development. It is important that the HEDNA reflect trends in office utilisation and occupation trends following the Covid-19 pandemic. The HEDNA (published in November 2022) recognises that it is too early to identify clearly how increased levels of homeworking and a move towards hybrid working models will affect the requirement for office floorspace. The HEDNA acknowledges, however, that a reduction in office requirement is likely. The 30% reduction applied to the initial analysis for office based requirements will need to be kept under review as of the Local Plan progresses. The trend for lower utilisation and businesses consolidating operations needs to be monitored carefully to ensure that there is not an overprovision of office space. Given the changes being experienced, it is important that the Local Plan support the repurposing of office buildings and land where a lack of demand is evidenced.
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DLPDS agree that the Local Plan policies should provide flexibility that allows land for commercial uses that are unviable to be put to alternative uses. This will help to secure the most efficient use of land in ensuring the development needs of South Warwickshire are met. Existing employment land should not be protected for its own sake. It is appropriate that evidence is required to demonstrate the current use is not viable, or that there is a sufficient supply of employment land. Whilst this should not be onerous, it is appropriate that it include a period of marketing to show that an existing use is not viable.
The HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. The NPPF sets out that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the Standard Method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals” . National policy is therefore supportive of the approach that South Warwickshire Councils are seeking to implement, and as such utilising the HEDNA to inform the local housing need for South Warwickshire is supported. It is important, however, to remember that the local housing need is not the same as the housing requirement within the Plan. The UCS suggests that the SWLP housing need equates to 30,750 dwellings, however this figure does not reflect the latest evidence within the HEDNA and needs updating. In addition, the UCS assumes a Plan period which commences in 2025, however this does not align with the base date of the HEDNA and as such a Plan period from 2022 is considered more appropriate to align with the evidence base. Based on the above, we consider a more appropriate local housing need for the SWLP is 47,012 dwellings over a 28 year plan period. In line with the NPPF , it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national guidance ; for example in order to address a significant affordable housing shortfall, support economic development, or address strategic infrastructure requirements which are likely to increase the number of homes needed. Further consideration will also need to be given to unmet needs within the Housing Market Area.
It is imperative that that SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire, to ensure compliance with the Duty to Cooperate and so the SWLP can demonstrate adherence with the positively prepared test of soundness set out in the NPPF . The two likely sources of unmet needs are from Birmingham and Black Country and Coventry and Warwickshire. The level of unmet need in Birmingham and the Black Country is circa 78,415 dwellings and there are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA. Coventry is highly constrained by a tightly drawn administrative boundary with potential for brownfield redevelopment but limited opportunity for greenfield development. It is highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Given the functional relationship that exists, the Councils should engage with the relevant local authorities to determine an appropriate level of unmet needs to be directed to South Warwickshire.
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The Councils propose that the SWLP will take the form of a Part 1 Plan to deal with the Vision and Strategic Objectives, Growth Strategy and Strategic Policies, followed up by a Part 2 Plan setting out detailed policies (in one or more Development Plan Documents) and Area Actions Plans. However, this approach is unnecessary and will lead to greater uncertainty for local communities, landowners and developers, possibly delaying the positive planning of new development allocations and supporting infrastructure. The implication of this is the potential for housing and employment growth in South Warwickshire to be inhibited, particularly as the SWLP is proposing to include the majority of strategic and non-strategic site allocations in the Part 2 Local Plan with only certain strategic site allocations and broad locations to be identified in the Part 1 Local Plan. A single consolidated SWLP should therefore be produced. This may result in the respective Councils not being able to demonstrate a positive Five Year Housing Land Supply position. The SWLP should be mindful to provide sufficient allocations to mitigate any slippage or unexpected change in circumstances.
Q-S3.2: Please select the option which is most appropriate for South Warwickshire: DLPDS support the redevelopment of previously developed (brownfield) land and recognise that the majority of these sites will be located in urban areas. However, the Local Plan must also recognise that previously developed land exists outside of existing settlements and the future growth options, and can be developed sensitivelyand without adverse impacts having regard to the location and site context. A combination of the options set out in ‘Option S3.2a’ and ‘S3.2b’ is therefore required. The redevelopment of previously developed land, including the DLPDS land at Abbey Park, has a number of benefits. These include making good use of existing infrastructure; reducing the need to release greenfield land to meet the development needs of South Warwickshire; and reducing the amount of best and most versatile agricultural land that would be developed. NPPF Paragraph 119 is clear that planning policies should promote the effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies are required to set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously developed or brownfield land. In our view, a strategy that does not consider previously developed sites outside of urban areas does not meet the requirements of NPPF Paragraph 119. Local planning policies have previously recognised the special status of the DLPDS land at Abbey Park as previously developed land in the Green Belt. The previous Warwick District Local Plan 1996-2011 identified it as a ‘Major Developed Site in the Green Belt’, reflecting the national policy of the time. This facilitated a grant of outline planning permission to redevelop the site as a Business Park. Although the consented development of 7no. office buildings has been heavily marketed, only 3no. of the approved buildings have been constructed to date. An alternative mix of employment buildings was granted planning permission later, but low demand for office development at this location means that no buildings have been constructed since 2005. The current Warwick District Local Plan 2011-2029 (adopted in 2017), identifies the land at Abbey Park as a ‘Major Employment Commitment’. Although not fully developed, given the planning permissions and investment to date, the as yet undeveloped brownfield land at Abbey Park will not be returned to its original preBusiness Park function, as part of the Stoneleigh Deer Park. The consultation options presented focus on the requirement that the redevelopment of previously developed land have ‘a positive impact on the sustainability of the area’. However, this is out of step with the emphasis within Framework para. 119 which simply requires that the redevelopment of such land ‘safeguard and improve the environment’. The focus of the Local Plan should be adjusted so as not to prevent potential benefits of redeveloping brownfield land from being secured. The DLPDS land at Abbey Park would deliver such benefits, as part of a Registered Park and Garden (Grade II*), and facilitate tree planting and works to restore original features of the Park and Garden. This potential gain has been acknowledged in the officer reports for the Business Park permissions granted to date, which accepted that this part of the Park and Garden was substantially altered to construct the WWII Military Hospital. The redevelopment of previously developed land can be carried out in a way that protects existing assets and ensures safe and healthy living conditions, in accordancewith the Framework. For example, there are no listed buildings on the Abbey Park land, the nearest listed building being circa 100m from the southern boundary, beyond Stareton Lane (Grade II). A residential development can be carried out in a way that respects the setting of the listed building. Previous ground investigations have found the DLPDS land to be generally free of contamination. Although some remediation work is required for the promoted, the level of contamination is not an 'in principle' constraint to development. The development would secure its remediation. There are no statutory ecological designations directly affecting the site or within 1km. Some of the trees present are subject to Tree Preservation Orders and can be integrated into the redevelopment of the site. The land is mostly Flood Zone 1, which is the lowest possible risk of flooding. Although a small part of the site is affected by Flood Zone 3, this is outside of the area that would accommodate development, such that there are no constraints in flood risk terms. The existing employment uses at Abbey Park are already served by public transport, with a dedicated bus stop and shelter within the site. The stop is served by bus service 539, operatingMonday to Saturday between Coventry and Kenilworth, via Stoneleigh. When taking account of the information above, Abbey Park is an appropriate location and residential development would make best use of previously developed land.
