Issue and Options 2023
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New searchYes. 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. 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.
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). 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. 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: 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. Q-H3: The Respondent agrees that should the Councils wish to impose minimum space standards that they should be adopted as development plan policy. 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. 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. For the avoidance of doubt the Respondent would strongly object to the imposition of space standards beyond NDSS. Q-H5: The Respondent has experience of providing self-build plots on developments in other parts of the Country and would caution that there is often a disparity between the number of people that register an interest in such plots and those that will make a firm commitment and complete a purchase. As the Consultation Document points out, there are people who may express an interest for a self-build property but do not want to live within or on the edge of a new housing estate. In a largely rural authority, it is considered likely that the demand for self/custom build is for single plots on the edge of small villages/hamlets or on plots within the open countryside. A case-by-case approach as per that suggested under Option H5c would therefore seem most appropriate in South Warwickshire or for specific sites on the edge of existing settlements to be allocated specifically for this purpose where there is identified demand (Option H5a). If Option 5b is to be taken forward, then there must be the flexibility to revert self-build plots back to normal build plots once they have been marketed for an appropriate amount of time. The period of marketing required to demonstrate a lack of demand should not prevent the main developer from completing the self-build plots before the construction programme finishes, since it would not be desirable for developers to be left with vacant plots or for new residents to be subjected to construction activities for a prolonged period.
Q-H4.1: 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. Q-H4.2: Birmingham City Council has identified a shortfall in housing 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). The SWLP Consultation Document suggests that additional shortfalls could also arise from the other 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.
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. For the reasons explained under Q-S5.2, the Respondent would caution the Council 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-C3.1: Don’t know. As recognised in the Consultation Document, some developments may not be able to completely neutralise their carbon emissions on site and in these cases a carbon off-setting approach would seem reasonable. However, it will be imperative that the SWLP provides an appropriate mechanism for carbon offsetting. The Consultation Document suggests that in addition to natural solutions such as tree planting that a fund could be created through the pooling of financial contributions from developers which will enable the existing housing stock to be retrofitted with measures to help reduce carbon emissions. However, it is not clear how such a scheme would operate in practice (i.e., how will financial contributions be calculated and who would be responsible for administrating, delivering and monitoring such a scheme?) or if it would meet the tests of Regulation 122 of the CIL Regulations 2010 (as amended). Without more information it is therefore very difficult to comment. Accordingly, the Respondent reserves their right to comment once more information is made available in this regard. Q-C3.3: The integration of renewable energy and carbon sequestration within new developments could both be feasible options in helping to achieve net zero carbon development but, as stated elsewhere in this Statement, anything above standard requirements will need to be carefully considered in the context of other policy requirements to ensure that any approach adopted by the Councils is justified, viable and deliverable. In the Respondent’s view, significantly more information needs to be provided before developers can provide any sort of meaningful comments on the suggested approach to renewable energy generation or carbon sequestration in South Warwickshire. The Respondent therefore reserves their right to make further comments once more information is made available in this regard.
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If the decision is made to proceed with a policy that seeks reductions in embodied emissions, then a phased approach should be adopted. However, it is difficult to advise where this threshold should be set without more information being provided regarding the potential implications of such a policy. The Councils should therefore look to test the various options and present this work as part of a preferred strategy which can be commented on in due course.
Q-C4.1: The Respondent considers it superfluous to include a policy requiring new development to comply with national building regulation requirements given that developers will need to comply with Building Regulations in any event. While the Councils’ aspirations to raise the standard of design and achieve net zero carbon is understood, and to some extent supported, achieving this will come at a significant cost to development which, given the time frames involved, is unlikely to be easily absorbed and therefore has the potential to put at risk the delivery of sites and, in turn, the timely delivery of market and affordable homes. Considering these concerns, Option 4.1a is considered to be most appropriate. If, however, the Councils are minded to set a higher local standard, then it is advised that realistic transitional arrangements are allowed for to enable the development industry time to respond. In the Respondent’s view, the timeframe indicated in Option C4.1c is the minimum that should be adopted. In imposing standards caution also needs to be shown to ensure that redundant technology is not prescribed and that developers can make an appropriate choice of systems at the time houses are being delivered. In addition, the Plan will have to be supported by evidence demonstrating that the viability both technical and financial has been taken into account. Q-C6.1: While the Councils’ aspiration to raise standards and seek greater reductions in embodied emissions is appreciated, the Respondent has significant concerns regarding the additional cost to the development industry, which cannot be easily absorbed.
