Issue and Options 2023

No

CPRE Warwickshire believes that the Plan Plan Period should not attempt to plan as far ahead as 2050. The detailed report on Housing and Employment Need submitted with our responses to the consultation questions sets out why planning so far ahead should be replaced by a shorter period. CPRE considers a plan period between 15-20 years would be appropriate in line with other local plans and the NPPF requirements. This would reduce the need to allocate green field sites (Including potentially Green Belt sites) now for needs which will not arise within a reasonable timescale. It will also allow monitoring of the delivery of windfall sites from which a major element of new housing comes in Warwick and Stratford Districts, and thus to ensure that countryside is not lost to development. CPRE opposes planning through the SWLP to meet claimed unmet housing need from other planning authority areas. Attached to the report from our consultant are reports commissioned by CPRE West Midlands Region (CPRE WM) on the housing requirement calculations prepared for the Birmingham Plan Review (Nov 2022) and the earlier Black Country Plan Reg 18 publication (2021) and submitted to those aquthorities. As set out in those appraisals, the claimed levels of unmet need in Birmingham and the Black Country are much higher than current data suggested, and they may not arise atr all, Any figures for unmet need in the City of Coventry results from miscalculations of its population which the 2021 Census has confirmed. Legislation before Parliament (the LUR Bill) is expected to remove the 'duty to cooperate'. If this ceases to apply, there will be much less requirement on local planning authorities, such as those in the SWLP, to accept housing from other authorities, particularly where it requires the removal of Green Belt. The Vision and Objectives do not as drafted refer to key concerns of wide public interest: 1. landscape and countryside, 2. the protection of Green Belt and 3. protection of ecological sites. They include the aim to address biodiversity and environmental resilience, but not show an objective of ensuring development does not impact on ecological sites. This lack of reference to constraints should be corrected. National planning policy does recognise them: see NPPF Para 11 (b)(ii), read with its footnote 7. This lists a range of constraints which can justify not meeting the 'objectively assessed need' figure for new housing. It needs to include these. CPRE supports the tenor of the five over-arching principles but would warn that the scle of development proposed in some of the growth options could undermine them.

CPRE has submitted our detailed report on Housing and Employment Need which examines the justification for the level of new housing allocations and new employment land that the Issues & Options consultation is proposing as the basis for the Growth Options. The current draft of the Sustainability Appraisal is of limited value because it is using figures for population growth, new housing and employment land need that our report shows are too high and should be significantly lower. Please refer to CPRE's responses to Consultation Questions E1.1, E1.2, H1.1, H1.2, H4.1, H4.2 and H4.3. Should these requirements be less, as we submit, the SA will need be revised. A further important response we wish to make is here is that the Issues & Options states that the HEDNA 'trend' housing projections are more suitable in delivering housing need objectives than the ONS2014 figures because the HEDNA covers the whole of Warwickshire and Coventry. Any conclusion can only be drawn when it is known whether Coventry in its Local Plan Review will drastically reduce its housing requirement figure in line with the HEDNA. The Issues & Options refers to unmet housing need from Coventry. This risks double-counting; there may be no unmet need requirement from Coventry once its Local Plan Review appears, using data from the 2021 Census. The SA is including assumptions about an unmet need from Coventry which is not substantiated. The report submitted with our consultation responses examines this subject.

Yes

The consultation states, "In light of the new growth required across South Warwickshire up to 2050, a review of infrastructure needs is required so that measures can be put in place to ensure that this new growth is supported by appropriate and timely infrastructure". CPRE considers that the scale of new growth outside existing urban areas proposed is higher than is going to take place since the population and household growth projections are too high, and the capacity of existing urban areas to accommodate more housing is greater than the Issues & Options assumes. Our submitted report explains the reasons for this. Of the infrastructure safeguarding listed: CPRE supports: Stratford to Honeybourne former railway – safeguarding the route of the former railway south of Stratford-upon-Avon to Honeybourne to facilitate re-opening. CPRE opposes safeguarding the Stratford South Western Relief Road proposal; this is a costly and undelierable scheme which was inserted into the Stratford District Core Strategy at a very late stage and as a safeguarded alignment in that Plan was never subject to public consultation in the normal way.

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Detailed comments on the Urban Capacity Study are set out in CPRE's submitted report on Housing and Employment Land Need . We consider this useful evidence, although we note that it comes without detailed site information as a SHELAA would include. This should be further refined, and inform a SHELAA, for the next iteration of the plan. The UCS does suggest further elements of supply that should be included in the next iteration of the plan. This includes some modest increase in density and inclusion of previous over-supply. However, most significantly the evidence presented in the Urban Capacity Study supports higher and more realistic assumptions about annual windfall housing. It shows that the windfall allowance in the Plan should be a figure somewhere between 450 and 901 dwellings per annum (dpa), that is to say, somewhere above half the historic annual rate over the decade 2011-2021, which has been 901 completions each year . This is supported by practical evidence on reductions in office requirements (a reduction of 30% in B1 use class floorspace across Warwickshire and Coventry, included in the HEDNA) and by well-known trends in future retail floorspace requirements, which are declining or at best have little market for expansion. This would be consistent both with the evidence of actual windfall supply (as opposed to plan figures) in Warwick and Stratford Districts and with the NPPF definition of windfalls, which does not limit the size of windfalls, but relies only on ‘compelling evidence’ as set out in Para 71. We note that the proposed figure of 4840 houses provided by windfalls, which is 220 dpa from 2028 to 2050, is not even the correct figure for small windfalls which would be 242 dpa. And projections of windfalls should start from 2025, not 2028, allowing 3 years from the date of the calculation. This alone would provide 6050 new houses dwellings (up to the Plan end date of 2050) from small windfall sites alone. Only when a more up-to-date calculation is made would it be appropriate to advance the start date for future windfall estimates, as early windfalls became actual permissions. The impact of increasing the Windfall allowance is set out in tabulated form in the report submitted by CPRE, based on the housing requirement included in the Plan (for end-years of the Plan of 2040; 2045; and 2050 as alternatives). below, based on the housing assumption in the Plan. It can be seen that the level of shortfall would significantly reduce, protecting the countryside and Green Belt from unnecessary encroachment. (PLEASE NOTE - the formatting of this on-line response does not permit presentation of these tables here) There is also consideration of additional supply by redeveloping or building over car parks in the urban areas. The UCS suggests a range of between 800 additional residential units (low) and 3400 (high) is feasible, depending on how many car parks are replaced by residential development or have development built over them. This would require further work but could be significant. The Councils should commission a more detailed study on whether car parks could or should be used to accommodate additional housing before the next iteration of the plan.

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No

Detailed comments on Employment Needs are set out in CPRE's submitted report on Housing and Employment Land Needs. In the case of offices (B1 use class) we consider the need should be reduced to reflect the lower office requirements observed since the COVID pandemic with estimates suggesting a 30% reduction in floorspace requirements. This would be in line with sensitivity work within the HEDNA. In the case of Industrial Land, the need is largely driven by past completions. The HEDNA assesses these across the whole Functional Economic Market Area (FEMA) which comprises the same area as the HMA - Coventry and all 5 Districts of Warwickshire. It then breaks it down into local authorities. As a result, previous large developments can skew the results, and this may explain why Stratford-on-Avon in particular has such a high calculated need. Further work should be undertaken with other authorities in Warwickshire to consider whether this distribution should be adjusted and whether it matches supply across the FEMA. Allied to the comments about Industrial Land the HEDNA identifies a very large level of large scale (B8) Logistics Provision across the FEMA. This is based on analysis which is liable to accentuate the need, for example, double counting road and rail, adding large amounts of contingency. Most importantly it assumes a high replacement rate of existing sites, some of which will not remain as logistics provision. While this may not directly impact on the SWLP area, which has relatively little B8 floorspace (compared to Rugby and North Warwickshire) it creates additional (potentially double-counted) supply which may help address industrial land needs (B2 use class) across the FEMA and so reduce pressure on the SWLP area. It should finally be noted that the current Issues and Options paper does not include any breakdown of existing supply (as opposed to allocations in the existing plans) so CPRE is not in a position at this stage to say whether, and to what extent, the current over-estimate of need is significant as we do not know how easily it can be met on existing allocations or new non-controversial sites.

No

This is set out in our attached report on Housing and Employment Need. The HEDNA approach relies on trend-based provision of future housing which are overwhelmingly the result of migration patterns into the SWLP area over the last decade and which have resulted in large part from faulty calculations of population and housing growth, particularly in Coventry. The result for the SWLP area can be seen in the table below. TABLE (See in CPRE's submitted report): ONS SNPP: Population Growth 2018-2028 (using 2018 MYE) Total: Warwick 9,451, Stratford 17,810 Natural change: Warwick 2,250 (births greater than deaths) Stratford -3,355 (deaths greater than births) Net inward migration: (UK and international) Warwick 7,218 Stratford 21,085 Net in-migration as a % of population growth: Warwick 76% Stratford 118%. This has led to a trend which works against sustainable development and which encourages higher housing need in more expensive areas around Coventry, leading to an undesirable loop,with further more in-migration.. The trend-based projections in the HEDNA would perpetuate this. Not only would they drastically increase housing provision in the SWLP area themselves, but there would be no guarantee that Coventry would adopt the lower figures in the HEDNA report. Indeed, that would, as it stands, be contrary to the NPPF, unless they could find exceptional circumstances to do so. Even if they did accept the HEDNA figures they would still be adding both the affordability add-on and 35% to their housing need. In all cases, if they then declared an unmet need based on inflated housing numbers, the SWLP area might end up with additional housing, both from its own approach and from a contradictory approach by Coventry. Given that both districts have extensive Green Belt and other constraints and given the aim of the Government to encourage urban regeneration, this seems a perverse outcome. The level of need is likely to be further exaggerated by the assumption in the HEDNA of a return to previous Household Representative Rates; that is to say in line with the ONS2014 figures. CPRE's submitted report explains that such a return to old HRRs should be regarded now as unrealistic and that many changes which have slowed down the historic trend of a reduction in household size are systemic. The Issues & Options says: ‘An added disadvantage of using the 2014-based projection would be that the South Warwickshire Local Plan was predicated on figures based on erroneous assumptions that have been proven to be wrong.’ However, it appears that despite this statement, the approach suggested would in fact perpetuate those past mistakes both technically and practically. Finally, the calculation in the HEDNA (and in the Plan) is based on the Standard Methodology which includes an affordability adjustment which is particularly high in the SWLP area because it is an attractive area but also because house prices rose significantly in 2021, so the adjustment may fall in the next few years. The Median House Price/Earnings Ratio for 2021 in Warwick is 10.73 and in Stratford 10.62, which in the SM case raises the requirement from 874 dpa raises to 1239 under ONS2014 adjustment, a 42% uplift on the need in the two districts. We also note that Table 9 refers to both the ONS2014 Standard Methodology requirement and the HEDNA trend-based calculations as measures of housing ‘need’. We consider this to be both incorrect and misleading. Both tables include an ‘affordability’ uplift and the 35% addition for Coventry. This is a table of ‘the requirement under the policy’ not ‘need’.