Issue and Options 2023

The following comments are made in respect of the SA for Wellesbourne. The SSL for Wellesbourne (as with other settlements) covers a large area of land around all sides of the edge of the village. Some edges of the settlement will have more adverse impacts than others due to their different characteristics. For example, land to the west is constrained by the Airfield, and land to the south by the proximity to the Ancient Woodland ‘Wellesbourne Wood’. Assessing the settlement edge as a whole does not allow for any distinction to be made between different areas for growth. It is difficult therefore to draw conclusions as to the appropriateness of the settlement to accommodate growth from this exercise alone. However, it is clear from Table 5.1 that the only major adverse impacts identified relate to landscape sensitivity and agricultural land classification. Landscape sensitivity will of course vary between areas, and can be mitigated by sensitive design. Agricultural land classification will of course be a factor that needs to be taken into consideration, but is not an overriding constraint upon development of a site. The SA demonstrates therefore that there are no in principle impediments to growth at Wellesbourne, and this is a suitable location for growth. The Councils will also be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations in due course.

No

Countryside Properties consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and Countryside Properties consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Housing Market Area and therefore should not be excluded.

selected

selected

selected

The production of an Urban Capacity Study (UCS, October 2022) to support identification of brownfield land to help deliver the growth needs of South Warwickshire is in accordance with the NPPF. The following points are made in relation to how the UCS considers housing supply in the urban areas. However, it should be noted that the UCS also discusses the SWLP housing requirement and representations are made on those points under Q-H1-1 & 2. In relation to housing allocations from the adopted Local Plans, Countryside Properties consider that a comprehensive review of all outstanding allocations without planning permission is required to ensure that such sites still meet the definition of developable as set out in the NPPF. In particular, evidence will be required to demonstrate why the UCS suggests the capacity of some of the allocations will increase beyond what is included within the adopted Local Plan. That review and evidence must be published prior to the next iteration of the Plan to demonstrate the capacity from the allocations can be relied upon to meet the housing need. The UCS also includes within the supply 795 dwellings on sites which have been submitted to the SWLP Call for Sites process in the urban areas, and are considered to be potentially suitable. As no formal assessment of these submissions has taken place, their inclusion will need to be reviewed once the Housing and Economic Land Availability Assessment (HELAA) is published. Any allowance for such sites must be deducted from the windfall allowance. The UCS identifies an additional five sites on vacant land in the urban areas which have not yet been submitted to the Call for Sites process, but are considered potentially suitable for 328 dwellings. There is no certainty around the availability and deliverability of these sites to include them at this stage. Further, on assessment of these sites there are some serious concerns around their suitability in any case. The UCS also identifies two additional sites on brownfield land within the urban areas, at Talisman Square, Kenilworth (65 dwellings) and Westgate House, Warwick (39 dwellings). As above, these sites have not yet been submitted to the Call for Sites process and so there is no certainty around delivery. Finally, the UCS includes an assessment of the potential windfall supply with reference to the level of windfall delivery across South Warwickshire in the period 2011/12 to 2020/21. However, it is considered that this assessment is limited as it does not detail the sources of windfall supply, nor consider how the planning policy landscape in South Warwickshire may impact future windfall delivery. Whilst a windfall allowance is likely to be acceptable in principle in the SWLP, it should be calculated on the basis of compelling evidence as required by the NPPF.

Yes

No answer given

Nothing chosen

The following comments are made in respect of Countryside Properties site west of Newbold Road, which is referenced as Area 3 within the Wellesbourne area. In respect of Connectivity, the site has been assessed as ‘C’. This is defined as having barriers that may be overcome. The commentary in the Analysis states that the floodplain acts as a barrier between the site and houses to the south, and therefore unlikely to connect to existing cul-de-sacs. That is correct for vehicular traffic, however the flood plain does not prohibit active travel routes connecting the two areas and enabling residents to walk or cycle into the settlement. The Masterplan submitted to the Councils with these representations demonstrates how this would be achieved, and how vehicular access to Newbold Road would be provided. As Newbold Road is capable of accommodating all modes of transport, there are no significant barriers to connectivity to the settlement and this should be rectified in the next iteration of the Analysis to a score of (A). In respect of Landforms, Flood Zones 2 and 3 are noted on the southern boundary and would be retained. It should be noted that a particular aspiration of the Neighbourhood Plan is to secure such areas for open space to address a deficit in this area. In respect of local facilities within 800m, it is noted that the report highlights the absence of Healthcare for Area 3. However, Hastings House Medical Centre is within 800m of the site and therefore this should be rectified in the next iteration of the Analysis. When taking account of the evidence above, Area 3 is a suitable location to accommodate development as there are no barriers to connectivity to the village and all facilities are available within 800m. The Heritage Assessment is also noted which confirms there is scope for carefully considered development in the north east area between the A429 and Wellesbourne Road. In conclusion, Area 3 (land west of Newbold Road) is a suitable location for a strategic allocation for the growth of Wellesbourne. The site is unconstrained, well connected to the settlement, and can deliver up to 500 homes and a sizeable area of open space that addresses a local deficiency in the area. The vision for the site is articulated within the Vision Document submitted separately. Further, when considered against the reasonable alternatives, the land to the north of Wellesbourne represents the best performing option to accommodate a strategic allocation.

Neutral

Appropriate strategy

Appropriate strategy

Appropriate strategy

Appropriate strategy

selected

selected

selected

selected

No

Yes, the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, Countryside Properties reserve its position in respect of whether this approach is reasonable for other authorities in Coventry and 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. On the basis of 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 in line with the Duty to Cooperate and the positively prepared test of soundness , which is explored in further detail in response to Issue H4 below. Bringing together comments on the UCS and Unmet Needs under Q-H4.2, Countryside Properties consider that the SWLP will need to plan for a level of housing growth in the order of at least 43,000 dwellings.

Nothing chosen

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 . It is recognised that national planning policy and law has the potential to change during the course of the preparation of the SWLP, including in relation to the Duty to Cooperate and replacement with an ‘alignment policy’, however there is no suggestion the requirement for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Birmingham and Black Country and Coventry and Warwickshire. Birmingham and Black Country There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. Birmingham published a New Local Plan Issues and Options consultation document in October 2022. This identifies an overall housing need in Birmingham to 2042 (derived from the Standard Method) of some 149,286 dwellings, with total housing supply equating to just 70,871 – leaving a shortfall of some 78,415 dwellings. There are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities due to lack of available land in the Black Country and significant Green Belt coverage in the Black Country and elsewhere (Bromsgrove, Solihull, North Warwickshire, and Lichfield). This was evident in the work undertaken in the now abandoned Black Country Local Plan Review, which was subject to Regulation 18 consultation in 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. There are strong functional relationships between Birmingham and South Warwickshire, in terms of transport connections and commuting patterns, and development in South Warwickshire can contribute towards meeting unmet needs. The Councils clearly need to engage with Birmingham and the Black Country authorities and others to determine an appropriate level of unmet needs to be directed to South Warwickshire. That process needs to be transparent in accordance with paragraph 27 of the NPPF, and effective in accordance with paragraph 35 c) of the NPPF. The lack of any published Statement of Common Ground showing progress made so far by the Councils is a concern that needs to be addressed before the next round of consultation. The Councils need to properly grapple with this issue, and not allow the failings of the last round of Local Plans to be repeated. It is noted that the SA has tested the effects of an additional 5,000 to 10,000 dwellings to accommodate Birmingham’s unmet needs, however given the numbers discussed above Countryside Properties consider 5,000 dwellings to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process and in advance of those discussions, as a working assumption for the level of unmet need to be accommodated, the figure should be an additional 10,000 dwellings. Coventry and Warwickshire Although the question does not address Coventry’s unmet needs, this cannot be ignored. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA, with a housing need calculation derived from the Standard Method of some 3,188 dwellings per annum, adjusted in the HEDNA trend-based approach to 1,964 dwellings per annum. Applying the housing need calculated in the HEDNA to the proposed SWLP Plan period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development. This was reflected in the adopted Coventry Local Plan (December 2017), where the local housing need in Coventry in the period 2011 to 2031 was calculated at 42,400. The Coventry Local Plan set a housing requirement of just 24,600 (some 60% of its local housing need), leaving a shortfall of some 17,800 dwellings to be met elsewhere. It is therefore highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Even assuming that Coventry can accommodate a proportion of its local housing need consistent with that set out in the adopted Coventry Local Plan (i.e. 60%), which is itself a challenge, Coventry could only accommodate 33,000 dwellings to 2050 leaving a shortfall of some 22,000 dwellings to be met elsewhere. Given South Warwickshire’s functional relationship with Coventry, and as South Warwickshire makes up around half of the population of Warwickshire according to the 2021 Census data early releases , an assumption that around 50% of this shortfall will be directed to South Warwickshire is considered appropriate. This equates to approximately 11,000 dwellings and should be taken into consideration at this stage of the process as a working assumption for the level of unmet need to be accommodated.

With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, Wellesbourne was recognised within the Greater Birmingham HMA Strategic Growth Study (2018) as a sustainable settlement free from significant statutory constraints, and capable of accommodating further growth. Countryside Properties therefore support Wellesbourne contributing towards meeting unmet needs from the Greater Birmingham HMA.