Issue and Options 2023

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Q-H4-1: Do you agree with the approach of contributing to meeting the Birmingham and Black Country HMA shortfall to 2031 on the identified sites in Stratford-onAvon District? No The SOADC Site Allocation Plan (SAP) identifies reserve housing sites and the mechanisms for their release, should they be required. Policy SAP. 1 sets out four purposes for identifying reserve sites, with purpose (d) being: “To contribute to meeting any housing needs arising outside the Coventry and Warwickshire HMA that is accepted through co-operation between the relevant councils as needing to be met within the HMA and most appropriately being met within the District.” 2.82 Policy SAP.1 goes on to establish that reserve housing sites will be released in accordance with the mechanisms set out in Policy SAP.3 (Releasing Reserve Housing Sites). St Philips support the Council’s approach to purpose (d), which when read with the proposed Policy SAP.4 (Releasing Reserve Housing Sites for Purpose D), would release sites with immediate effect to help address unmet housing needs in the Birmingham HMA. In this context, Policy SAP.4 identifies the following sites to be released to help meet the unmet need of the GBBCHMA: • STR.A – North of Evesham Road, Stratford-upon-Avon; • STR.B – East of Shipston Road, Stratford-upon-Avon; • STR.C – South of Alcester Road, Stratford-upon-Avon; • MAPP.A – West of Birmingham Road (south), Mappleborough Green; • STR.D – East of Banbury Road, Stratford-upon-Avon. 2.83 In total, these sites have the capacity to deliver approximately 530 homes. Whilst it is welcome that these sites would be released immediately, St Philips considers that the proposed allocations do not sufficiently reflect the scale of the unmet need within the GBBCHMA. In this regard, the SAP Preferred Options asserts that “the housing shortfall in the Greater Birmingham & Black Country Housing Market Area (GBBCHMA) that cannot be met within its boundaries is identified as being 6,302 homes up to 2031” (paragraph 2.4.1). However, there are several shortcomings with this position as set out elsewhere by Lichfields in its blog10 “All the West-laid Plans: The unmet housing needs of the Greater Birmingham and Black Country Housing Market Area”. Lichfields’ critique suggests that whilst Birmingham’s unmet housing need has probably reduced from the original 37,900 in 2017, there remains a likely – and at present, unaccounted – shortfall of between c.11,479-15,479 dwellings up to 2031. This is because several of the ‘banked’ housing contributions from other HMA districts are earmarked to help meet the Black Country’s needs. In this context, St Philips consider that the proposed allocations within the SAP do not sufficiently address the scale of the shortfall arising within the GBBCHMA. 2.85 St Philips is also concerned that the approach taken by SOADC unduly restricts the release of Green Belt sites. In this context, St Philips welcomes that the IO has taken a ‘blind’ approach towards whether potential sites are within the Green Belt. St Philips supports this approach as it ensures that the South Warwickshire Authorities do not limit the release of sites for residential purposes that would otherwise be sustainable and suitable.

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Q-C4.1 Please select all options which are appropriate forSouth Warwickshire. The Government’s proposals set out in both part 1 of its Future Home Standards Consultation and the 10 points for a green industrial revolution have set a target for homes to be ‘zero carbon ready’ from 2025 rather than necessarily achieving ‘zero carbon’ from 2025. St Philips supports the government’s proposal to achieve ‘Zero Carbon Ready’ homes by 2025 and the overall vision for a net zero economy by 2050. 2.16 As acknowledged within the Issues and Options document: “Buildings are a major source of emissions for South Warwickshire and so the need to minimise those that are generated from new development is critical in achieving the climate emergency ambitions.” 2.17 St Philips supports the movement towards net zero and acknowledges that without a policy requirement set out within the Local Plan, new development would have to meet the national minimum requirements. New developments would have to progress in-line with the national minimum requirements without having the ability to deviate even when justification is provided by the Council. 2.18 The Planning and Energy Act 2008 gives local planning authorities the ability to set energy efficiency standards in their development plan policies that exceed the energy efficiency requirements of the most recent Part L Building Regulations. 2.19 In this instance, St Philips supports the aspiration of emerging policies seeking to achieve climate friendly and net-zero development via the use of sustainable measures. However, it is recommended that any policy adopted in regard to building regulations must have a degree of flexibility and should factor in a viability appraisal. 2.20 St Philips would support the inclusion of a policy seeking to reduce carbon emissions on new developments. However, until Future Home Standards and the supporting SAP software are finalised and adopted as legislation (Government due to consult in 2023), the industry will be unable to confirm the building specification and the carbon reduction rates. Therefore the proposed policy should be flexible to allow developers to utilise the most appropriate technology available at that time. The Government’s approach “remains technology-neutral and designers will retain the flexibility they need to use the materials and technologies that suit the circumstances of a site and their business”. (Ministry of Housing Communities and Local Government (MHCLG) Summary Response to the FHS (2019 Consultation Changes to Part L and F). 2.21 St Philips acknowledges that during the 2021 Scoping Options consultation, concerns were raised about viability and that the standards must be proportionate to the scale of development, justified and not overly prescriptive. St Philips considers that the approach should be flexible to ensure that schemes do not become unviable. 2.22 In consideration, St Philips recommends that consideration should be given to those matters that are yet to be finalised by the Government. Whilst the Government’s response to the FHS (2019 Consultation Changes to Part L and F) states that local planning authorities will retain powers to set local energy efficiency standards for new homes, it also states “as we move to ever higher levels of energy efficiency standards for new homes with the 2021 Part L uplift and Future Homes Standard, it is less likely that local authorities will need to set local energy efficiency standards in order to achieve our shared net zero goal”. 2.23 Importantly, the Building regulations (Part L) have recently changed in order to deliver the Government’s ‘Future Homes Standard’ which meant from 15 June 2022, homes will have to achieve a 31% reduction in carbon emissions when compared to previous standards14 . This is a step towards achieving zero carbon ready homes by 2025. 2.24 St Philips supports the proposed direction of travel in terms of achieving net carbon zero development. However, unless evidence is presented to support the departure from the latest changes to the building regulations (Part L), St Philips considers that a suitable strategy would be to adopt the national standards. The District’s departure from the national standards could have damaging impacts on market viability without the support of evidence, and should therefore aim to achieve a nationally shared net zero goal. This would ensure that the Local Plan can be found to be legally sound in accordance with NPPF paragraph 31 which states that: “The preparation and review of all policies should be underpinned by relevant and up-todate evidence.” 2.25 Without sufficient justification, the departure from the minimum national requirements could be at the cost of the development industry as new development may become an unviable option for developers. Subsequently, this may result in less affordable housing being built and may reduce other social and community developments being created in order to offset the costs of achieving net zero. 2.26 In consideration, St Philips recommends that Option C4.1a should be adopted to ensure that the Local Plan can be found to be legally compliant. Q-C4.2: What scale of development should the requirements apply to? St Philips considers that the requirements should be applied to all new development, but recommends that any requirement adopted within the Local Plan should be justified by evidence as discussed above. 2.28 The goal of achieving a climate natural area must be a collective approach as outlined within the Issues and Options document. Therefore, the adopted standards must be applied to all new development where achievable.

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Against the background set by the Environment Act 2021, a Biodiversity Net Gain requirement of 10% is a factor which will need to be addressed as part of any application. 2.30 The NPPF is clear that the purpose of the planning system is to contribute to the achievement of sustainable development (Para 7), and that sustainable development comprises three overarching objectives: economic, social and environmental (Para 8). Whilst the NPPF emphasises the importance of making sufficient provision for housing and employment land (Para 20a), the NPPF is also clear planning should support “strong, vibrant and healthy communities” (Para 8b) and that strategic policies should make sufficient provisions for: “d) conservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation.” 2.31 Paragraph 118a of the NPPF goes on to state that planning policies should: “encourage multiple benefits from both urban and rural land, including through mixeduse schemes and taking opportunities to achieve net environmental gains – such as developments that would enable new habitat creation or improve public access to the countryside…” 2.32 It would also be appropriate given that the SWAs have declared climate emergencies, and would align with WDC’s ‘Climate Emergency Action Programme’ and SOADC’s ‘Council Plan 2019-2023’, to secure environmentally sustainable development and improve the natural ‘green’ environment by improving the area’s biodiversity through tree planting and the creation of new habitat areas. In essence, St Philips agrees with the SWAs that the provision of green and blue infrastructure within development sites, alongside habitat improvements, are critical elements of ensuring development is sustainable, can enhance habitats and can help respond to the ongoing climate emergency. 2.33 In this context, St Philips supports the inclusion of compensatory measures, including biodiversity offsetting (i.e. Biodiversity Net Gain [BNG]). Although, St Philips does not consider that a policy requirement is needed in regard to BNG as the Environment Act 2021 has already been approved as part of national legislation. Although, it is acknowledged that the Council could deviate from the Environment Act 2021 where evidence justifies a higher requirement as per NPPF paragraph 31. However, it is important to note that any proposed policy requirement would have to be considered and assessed within a viability assessment before being adopted through the Local Plan Review.

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Q-T1: Please select all options which are appropriate for South Warwickshire. Whilst St Philips in principle welcomes the concept of the 20-minute neighbourhood, St Philips considers that a bespoke policy may inhibit growth within certain settlements. The NPPF is clear that: “Planning policies and decisions should play an active role in guiding development towards sustainable solutions, but in doing so should take local circumstances into account, to reflect the character, needs and opportunities of each area.” (Para 9). 2.35 In this regard, whilst St Philips considers that whilst the principles of the 20-minute neighbourhood align with the aims of the NPPF, the individual circumstances of local areas require flexibility. The South Warwickshire Settlement Analysis (January 2023) acknowledges that: “Across South Warwickshire therefore there are likely to be variations to how this [20- minute neighbourhoods] might be implemented. For example, the expectations in a larger town, will vary compared with smaller rural settlements” (Para 1.2). 2.36 St Philips therefore considers that a singular approach is not appropriate and could restrict growth in locations where it may not be possible or indeed necessary to adhere strictly to the policy. On this basis, St Philips considers that Option T1b is the most appropriate approach to the 20-minute neighbourhood. This would “raise the profile” of the 20-minute neighbourhood, whilst also allowing for more consideration of local circumstances in line with the NPPF (Para 9).

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Q-B5: Please select the option which is most appropriatefor South Warwickshire. Option B5c: None of these. St Philips supports the movement towards achieving environmental sustainability and encouraging environmental net gain in regard to new development. However, it is important to note NPPF paragraph 31 which states that “The preparation and review of all policies should be underpinned by relevant and up-todate evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.” 2.38 Without the support of evidence and an agreed method, a policy requirement is not considered to be justified and therefore would not be found to be legally compliant in accordance with the NPPF. Although St Philips supports the movement towards achieving an environmental net gain, it is considered that, at this moment in time, a policy requirement would be unjustified. In terms of an agreed method, the Issues and Options document states that: “Should this approach be taken, further work will be required to determine how environmental net gain will work in practice.” In consideration, St Philips considers that the environmental net gain concept and the method of application is currently not supported by sufficient evidence. Therefore, a policy requirement would not be justified in this moment in time unless further work is completed. 2.40 Overall, an environmental net gain policy requirement would provide developers with greater flexibility and the freedom to concentrate on the most relevant aspects that can be improved on-site. Importantly, and as already stated, St Philips urges South Warwickshire to compile sufficient evidence to ensure an appropriate method and requirement is adopted. Although an environmental net gain policy would provide greater flexibility, it is imperative that a negative ‘trade-off’ is prevented between ecosystem services. Therefore, until sufficient evidence is gathered, St Philips considers that an environmental net gain policy would be unjustified. Furthermore, a proposed policy approach would have to be assessed within a viability assessment before being adopted.

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Subsequent to the 2021 Scoping Options consultation, St Philips supports the changes to the overarching vision in regard to making clearer the role of housing and jobs within South Warwickshire. St Philips also welcomes the acknowledgement of the need to accommodate the unmet needs of surrounding authorities as stated within the vision. This is considered to be legally compliant in accordance with National Planning Policy Framework [NPPF] paragraph 24 which states: “Local planning authorities and county councils (in two-tier areas) are under a duty to cooperate with each other, and with other prescribed bodies, on strategic matters that cross administrative boundaries.” 2.3 As discussed in detail below, there is a large quantum of development required throughout South Warwickshire in order to meet both the social and economic needs of the administrative area as well as the neighbouring authorities, such as Coventry and Birmingham. Therefore, St Philips recommends that a suitable quantity of land should be assessed to ensure that the development needs can be met in the most sustainable locations. This would accord with NPPF paragraph 8b in terms of achieving the social objective of sustainable development, which states the following: “to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being”. 2.4 Additionally, in terms of the presumption in favour of sustainable development, NPPF paragraph 11b states that: “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas” 2.5 In consideration, St Philips also supports the strategic objective that seeks to deliver the right quantity of homes in order to “meet the needs of all of our communities” (IO, page 23). With regard to the Duty to Cooperate and the unmet needs identified within Birmingham and Coventry, St Philips considers that reference should also be made within this strategic objective to meeting the unmet needs of neighbouring authorities. Although, it has been acknowledged and welcomed that the overarching vision makes reference to meeting the unmet needs within surrounding authorities.

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