Issue and Options 2023
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4.8 We consider Option H2-2b; providing a separate affordable housing requirement for Stratford-on-Avon and Warwick Districts, would be appropriate in terms of reflecting local requirements and local viability calculations. However, it is considered that the tenure and type of affordable homes sought should be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. L&Q Estates support a collaborative approach to identifying site-specific affordable housing requirements, including tenure and type of affordable homes to be provided on-site.
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Q-H3: Please select all options which are appropriate for South Warwickshire 4.9 L&Q Estates have no objection to a requirement to meet optional Building Regulations M4(2)/M4(3) in principle (Option H3c). It is considered that this should be achieved by requiring a certain proportion of homes on sites in medium or higher value zones to meet the optional standards. However, we reserve the right to comment further at a later stage, once the specific requirements for sites have been clearly defined.
4.10 Birmingham City Council has commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes. 4.11 Issue H1 above sets out the approach to needs arising within Coventry and Warwickshire. Even under the redistribution of housing resulting from the trend-based projection, Coventry may not be able to accommodate all of its housing needs (1,964 homes per annum), and as such a relatively modest shortfall may exist to 2050. 4.12 South Warwickshire sits most fully within the Coventry and Warwickshire HMA, with Warwick District most strongly related to Coventry given its shared boundary and interrelationships with the city. South Warwickshire is also within the Birmingham and Black Country HMA owing to Stratford-on-Avon District’s shared boundaries and interrelationships with Solihull and Redditch boroughs and Bromsgrove district. Through the Duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs. 4.13 Given the size of South Warwickshire, it is considered that any additional needs can be accommodated outside of any protected areas (e.g. Cotswolds National Landscape/AONB). One exception could be areas designated as Green Belt, particularly if such locations are deliverable, available and suitable for release from the Green Belt to deliver high quality residential developments. Locations for additional growth should be sustainable in close proximity to where people want to live. 4.14 In light of the above considerations, we 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.
4.15 Housing needs that cannot be met within neighbouring areas must be as close as possible to those areas, or within areas where sustainable transport connections can easily be made to those areas. 4.16 South Warwickshire sits most fully within the Coventry and Warwickshire HMA, with Warwick District most strongly related to Coventry given its shared boundary and interrelationships with the city. 4.17 Southam is situated approximately 13.5 miles (21.7 km) to the south of Coventry and benefits from a direct vehicular connection to the city via the A423, which connects to the A45 and Coventry Bypass. As such, the town is ideally located to accommodate any housing shortfalls from outside of South Warwickshire, particularly Coventry. 4.18 In accordance with the guidance contained within the Framework, development should be focussed in the most sustainable locations in terms of availability of shops, facilities and services, as well as access by modes of transport other than the private car. In addition, it is considered that development should be distributed over a range of settlements rather than in single settlements in order to ensure their vitality and viability in accordance with the principles of sustainable development set out in the Framework. 4.19 L&Q Estates consider any housing shortfalls from outside of South Warwickshire should be directed to sustainable locations in accordance with the distribution of development established in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy. 4.20 Southam is identified as one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Stratford-on-Avon district. It offers a large range of shops, commercial activities such as banks, local services and facilities and pubs. Other services in the town include primary and secondary schools, a leisure centre, library, medical centres, police station and post office. There are good public transport services to the towns of Leamington Spa and Rugby, as well as community transport services that connect the town with nearby villages. 4.21 The promotion site [land east of Banbury Road, Southam] immediately adjoins the built-up area boundary of Southam and would constitute sustainable development. Indeed, it is considered that the new homes at land east of Banbury Road will comply with the 20-minute neighbourhood concept, owing to the close proximity of the site to Southam’s services and facilities. Within a 10 minute walk of the site the following facilities are available: • Southam town centre (includes pubs, restaurants, bank, shops, coffee shops, takeaways, library and post office); • Petrol Station; • Tesco Superstore; • Southam Cricket Club; • Southam Football Club; • Happy Days Nursery; and • Bus Stops on Banbury Road 4.22 Primary, secondary and further education establishments and Southam Leisure Centre are all also available within a 19 minute walk. 4.23 Given the pressing need for additional housing within the Stratford-on-Avon District, in addition to meeting the housing shortfalls from outside of South Warwickshire, Southam is clearly a sustainable location to accommodate additional housing growth. The Site at land east of Banbury Road, Southam has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the town and will enhance its vitality in line with national planning policy. Accordingly, it is considered that the Site would be an appropriate location to accommodate a residential development to meet housing shortfalls from outside of South Warwickshire.
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Q-H5: Please select all options which are appropriate for South Warwickshire 4.24 Whilst it is considered that Option H5a would enable the South Warwickshire Authorities to group this type of housing together in small sites in various locations, such an approach would be dependent on landowners putting sites forward for this type of housing. Therefore, this approach may not provide sufficient suitable development permissions to meet the identified demand in accordance with the duties under sections 2 and 2A of the Self Build and Custom Housebuilding Act 2015. 4.25 We consider Option H5b is appropriate for South Warwickshire, provided it can be demonstrated that there is currently a need for self-build and custom build plots identified in the self-build and custom build register for the local authority where the site is located. The proportion of self and custom-build plots to be made available within large sites should be sufficient to match the current number on the register. Such an approach would align with the aims of Paragraph 62 of the NPPF in terms of providing opportunities for people wishing to commission or build their own homes. 4.26 It is considered that any policy under Option H5b should also include a fall-back option of reverting any unsold self-build plots to the developer to build, should any of these plots not be sold after an appropriate marketing period (of, say, 12 months, for example).
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Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1 We are generally supportive of Option C4.1c – a phased approach to net zero carbon - setting a future date by which all new development will need to achieve net zero standards. L&Q Estates are committed to responding to the climate crisis and are actively looking to deliver housing to standards above those set out in current building regulations in response to this challenge. Indeed, their most recent Corporate Strategy includes a commitment to setting an L&Q design standard in response to the emerging Future Homes Standard, as well as more broad investment in modern methods of construction. However, it is important to note that renewable and low carbon energy dwellings may not always be practicable or viable in new developments. Therefore, we are supportive of Option C4.1c insofar as this option allows time for the cost of achieving these standards to come down, and may mean that more affordable housing and community benefits can be secured from development.
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5.2 NPPF Paragraph 32 advises that local plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Further, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including establishing coherent ecological network that are more resilient to current and future pressures. 5.3 L&Q Estates are supportive of Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity. The Site [land east of Banbury Road, Southam] will seek to deliver a minimum 10% in biodiversity net gain, alongside other on-site habitat provision and enhancement, through the retention and enhancement of the onsite hedgerow network, ponds, and semi-improved grassland fields. The site masterplan seeks to maintain wildlife corridors between these valuable ecological habitats, both within the site and the wider landscape.
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