Issue and Options 2023

Q-S3.2 Please select the option which is most appropriate for South Warwickshire. Option S3.2c: None of these 2.6 St Philips considers that the SWAs priority should be to direct development to the most sustainable locations. St Philips recognises that the NPPF places emphasis on the need to make as much use of brownfield land as possible, with paragraph 119 stating that: “Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land.” 2.7 Paragraph 120 of the NPPF continues by stating that “Planning policies and decisions should: • give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land; and • promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively.” 2.8 However, it should be noted that whilst the use of brownfield sites is emphasised, there is a need to consider the NPPF as a whole. Paragraph 11a of the NPPF is clear that “all plans should promote a sustainable pattern of development”. In this regard, whilst suitable brownfield sites will often naturally emerge as sustainable locations for development, it is possible for greenfield land to provide a more sustainable location for development than unsuitable brownfield land. 2.9 St Philips also notes that the SWLP ‘Urban Capacity Study (October 2022)’ has established that South Warwickshire is unlikely to be able to meet its development needs solely through the use of previously developed land1.Therefore, regardless of the approach taken by the SWLP, there will still be a need to identify significant amounts of suitable greenfield land for development. In this context, St Philips believes the Councils approach should emphasise sustainability, rather than arbitrarily prioritising brownfield sites over more sustainable greenfield locations. St Philips would therefore support the effective reuse of brownfield land alongside the release of greenfield land in sustainable locations as directed by the Settlement Hierarchy or through the delivery of a new settlement (subject to consideration of the delivery of core facilities and accessibility). Q-S5.2 Do you think new settlements should be part of the overall strategy? Yes. As stated, the NPPF is clear that the supply of large numbers of new homes can often be best achieved through planning for larger-scale developments (Para 73). Importantly, it is also clear that plans should be prepared positively, in a way that is aspirational but deliverable (Para 16b), and should identify specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan (Para 68b). However, for a plan to be found ‘sound’, it must set out an appropriate strategy, taking account of reasonable alternatives, and be based on proportionate evidence (Para 35b). In this regard, it is also important to note that the NPPF shifts the need to consider viability to the plan-making stage, requiring authorities to identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability (Para 68). The Planning Practice Guidance [PPG] provides further clarity for new settlements, stating that LPAs should demonstrate that there is a reasonable prospect that large scale developments can come forward. In particular, this should include a realistic assessment about the prospect of sites being developed and should engage with infrastructure providers to ensure that the infrastructure requirements are not beyond what could reasonably be considered to be achievable within the planned timescales. St Philips therefore does not consider that new settlements are the panacea for housing delivery. Whilst the proposed SWLP plan period would extend up to 2050, and conceivably enable sufficient time for a new settlement to fully deliver, there are still legitimate issues regarding this type of housing delivery and the evidence required to successfully underpin a proposed allocation – notwithstanding that SOADC secured the allocation of Long Marston Airfield. In this regard, St Philips welcomes the IOs recognition that whilst new settlements can be an effective way of delivering housing growth, further detailed assessment of the identified potential new settlement locations is required. The IO rightly acknowledges that “there is the possibility once these detailed assessments have taken place and in light of any comments received to the Issues and Options consultation, none of the potential locations are deemed suitable” (IO, page 49). It is particularly important that, where new settlements are intended to be a large proportion of areas housing needs, there should be a robust – and proportionate – evidence base demonstrating that the site is deliverable. In the absence of this, there is a very real risk that a Local Plan could be found ‘unsound’ at examination. Indeed, the examination of the North Essex Authorities’ [NEA] Section 1 Local Plan highlights the above issues. In particular, to meet housing needs over the 2013-2033 plan period, it proposed the allocation of three garden communities. However, the Inspector concluded that two of these proposed settlements should be deleted in order for the plan to proceed as they weren’t deliverable, on viability and infrastructure grounds. Furthermore, at the examination of Hart District Council’s ‘Hart Local Plan (Strategy and Sites) 2032’, the Inspector’s concern was that the new settlement was being advanced as a long-term solution, but no alternatives to that option had been considered or properly tested in preparing the plan. The Inspector also noted that “there is little evidence to demonstrate that a site can actually be delivered in terms of infrastructure, viability and landownership” [IR63]. In any event, the NPPF is clear that “to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed” (Para 60). As discussed, the NPPF emphasizes the importance of small-medium sites, stating that small and medium-sized sites can make an important contribution to meeting the housing requirement of an area, and are built out relatively quickly (Para 69). In this context, notwithstanding St Philips position on issues associated with pursuing New Settlements, the SWLP will need to allocate a variety of small-medium sized sites to deliver housing in the first 5-15 years of the plan period. Q-S7.2 For each growth option, please indicate whetheryou feel it is an appropriate strategy for South Warwickshire: The IO sets out five spatial Growth Options, comprising: a Option 1: Rail Corridors b Option 2: Sustainable Travel c Option 3: Economy d Option 4: Sustainable Travel and Economy e Option 5: Dispersed For each growth option an indicative list of settlements is provided. In this regard, St Philips is promoting land for residential development on the edge of Stockton, which is identified as a Category 2 Local Service Village within the Core Strategy. In the context of St Philip’s site, it is welcome that Stockton is identified as a potential location within Growth Option 5 (Dispersed). However, St Philips considers that Stockton should also be featured in Growth Option 2 (Sustainable Travel) and Growth Option 4 (Sustainable Travel and Economy). In regard to sustainable travel, Stockton is well connected to existing bus networks, with services 63 and 64 connecting the village to Leamington-Spa and Rugby respectively. St Philips also considers that growth at Stockton would contribute to the vitality of the settlement by supporting existing services. In this regard, St Philips notes that Growth Option 4 (Sustainable Travel and Economy) would provide “a balance of growth at existing main settlements…and more modest growth in smaller settlements, which can contribute to enhancing the viability of village centres and provide affordable housing” (page 69). St Philips therefore considers that Stockton should not be disregarded from inclusion in Growth Options 2 and 4. Some of the spatial growth options have been brought forward from the Scoping Consultation, whilst others are hybrids of the previous options. St Philips considers that the current options should, in theory, allow the Issues and Options Consultation to consider how South Warwickshire could accommodate housing growth to meet its own housing needs, and a proportion of the C&WHMA and GBBHCMA’s unmet housing needs. However, St Philips believes that a mixed growth strategy, which combines several growth options, will prove to be the best growth strategy for South Warwickshire. In this regard, St Philips notes that the Sustainability Appraisal evaluates the 5 spatial growth options and concludes the following: “An overall best performing option is hard to identify. Option 5 is the worst performing option whilst Option 2 is likely to align most closely with development that will ultimately seek the most effective mitigation against climate change” (Para 7.15.2). The SA goes on to acknowledge that different options perform better for certain SA Objectives than others. It also cautions that the results are only a guide and the potential for mitigation has not been factored into the performance of the growth options (Para 7.15.1). The IO further notes that “that detailed locational information is not available and the ability to identify effects with precision is challenging” (Page 59). St Philips therefore considers that the SA is inconclusive regarding which option performs best. In this context, St Philips believes that the spatial strategy should not entail one particular growth option (i.e. developing in close proximity of rail corridors). It is considered that the five growth options interconnect, and in order to achieve the development needs within and beyond South Warwickshire up until 2050 a mixed strategy should be adopted. This would ensure a flexible and robust approach that would disperse the benefits of growth between all settlements within the South Warwickshire. Regardless of which growth strategy is pursued, St Philips considers that some development will need to be dispersed to ensure that the entirety of South Warwickshire benefits from housing growth. This is acknowledged within the Evolving the Spatial Growth Options Topic Paper (August 2022) which sets out how the 7 high level spatial growth options presented in the Scoping Consultation evolved into the 5 options presented within the IO. The Topic Paper acknowledges in relation to Option 5 that “even if this option were not taken forward, some limited growth might still need to occur in some smaller settlements to support the overall sustainability of these places” (Appendix 2). Therefore, although Option 5 does not perform comparatively well within the SA and Estimation of Emissions Study, St Philips considers that it will be necessary to disperse some growth to support the sustainability of smaller settlements. On this basis, St Philips considers that a mix of the Growth Options will promote sustainable patterns of development across the area and aligns with the sustainability aspirations that are set out in the NPPF. Whilst greater levels of development may need to be focussed around sustainable transport corridors, due to the level of infrastructure and services already present, it will also be necessary to direct growth to other settlements to ensure that the benefits of housing growth can be delivered in other parts of South Warwickshire. In particular, St Philips consider that there are several benefits to a mixed approach to the distribution of development: 1 It would support the well-being of those settlements that have the capacity to accommodate growth; 2 By concentrating development around existing and proposed new infrastructure it would also ensure that it benefits from a sustainable location with good access. Such an approach would allow the Council to capitalise on opportunities presented by existing or planned infrastructure when considering options for large scale new residential developments, in accordance with paragraph 73a of the NPPF; 3 When having regard to the need to release Green Belt land, such an approach would also be consistent with paragraphs 141 and 142 of the NPPF: Where amendments to Green Belt boundaries are required, the promotion of sustainable patterns of development should be considered, alongside giving first consideration to land which is (inter alia) well-served by public transport (Paragraph 142); 4 It can ensure that a sufficient supply of homes, within close proximity to existing and future employment opportunities, contributes to an efficiently functioning economy. This can also aid in minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions); and 5 It would enable growth to meet the needs of neighbouring authorities to be located in an area close in proximity to where these needs arise. Similar to the above, this also has the added benefit of minimising housing market pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions). Land at Jubilee Fields, Stockton: As set out in Section 1.0 of these representations, St Philips is promoting Land at Jubilee Fields, Stockton for residential development. The Site, encompassing an area of c. 1.57ha, is formed of a singular greenfield parcel and comprises arable agricultural land. The Site is rectangular in shape and is bounded by existing residential development to the north-west, a cemetery to the north-east and agricultural land to the south-east and south-west. It is well contained and is enclosed by established mature hedgerows and trees, except for the north-west boundary which borders residential properties. The Site is located on the southern edge of Stockton, a Category 2 Local Service Village, which is located approximately 2 miles north-east of Southam and 8 miles south-west of Rugby. Coventry, Daventry Leamington Spa and Warwick are located to the north, east, west and further west respectively. Bus services 63 and 64 connect the village to Leamington-Spa and Rugby. The Land at Jubilee Fields was included within the 2018 and 2020 Strategic Housing Land Availability Assessments [SHLAA] (Site Ref: STOC.08). Both SHLAAs concluded that the Site overall was ‘amber’, or ‘likely to be deliverable’. In essence, there are no known constraints on the site that would preclude development, subject to appropriate mitigation measures being put in place where required. The Site was also identified as a Reserve Housing Site within SOADC’s SAP Preferred Options Consultation (October 2020). This was subsequently followed by the SAP Revised Preferred Options Consultation (June 2022), where the site was no longer proposed for allocation. The most significant change to the revised document was the Council’s approach to reserved sites. Notably, given that work has commenced on the South Warwickshire Local Plan, the Council considers it is justified in focusing on identifying reserve sites that would be appropriate and deliverable to meet any housing needs that are identified in the short term. The site could provide approximately 1.57 ha of residential development, equating to approximately 35 new homes. The Vision Document, submitted in support of these representations, demonstrates that the Site could deliver a residential development in a sustainable location. The Site is surrounded by strong defensible boundaries, including existing residential development to the north-west and mature hedgerows to the south-east and south-west. St Philips consider that the Site presents an excellent location to deliver up to 35 dwellings, including 13 affordable dwellings. The scheme would be responsive to its surrounding, working with the Sites mature landscape features and protecting the rural character of the village. It is, therefore, a highly sustainable location for growth.

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St Philips considers that the growth of existing settlements should form an important part of the SWLP overall strategy. The NPPF emphasises importance “on the need to support economic growth and productivity” (Para 81) and St Philips is concerned that overlooking existing settlements would constrain economic growth in these locations. The growth of existing settlements would support local services and facilities and would also direct development to sustainable locations in line with the NPPF (Para 11a). Existing settlements often have access to education, healthcare, retail, jobs, and public transport, and should therefore be considered as ideal locations for growth. In this context, St Philips is promoting the Land at Jubilee Fields on the edge of Stockton for residential development. Within the Core Strategy, Stockton is identified as a Category 2 Local Service Village, with the ranked position based upon the provision of services available within the village. In this regard, Stockton offers facilities such as a post office, primary school, restaurants, and a sports ground. A bus service connects the village to settlements such as Rugby and Leamington Spa. It is therefore ideally positioned to support small scale housing growth which would be highly sustainable and would support existing services within the village. In this regard, the NPPF is clear that: “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services” (Para 79). St Philips therefore welcomes that the IO recognises the importance of considering the potential for growth around the edges of existing settlements, alongside or in combination with options such as new settlements. In this regard, the NPPF recognises that “the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements” (Para 73). However, the NPPF is equally clear that small-medium sized sites can make a valuable contribution to meeting the housing requirement of an area (Para 69). Therefore, regardless of whether a new settlement is pursued, the SWLP will be required to allocate a variety of small-medium sized sites. St Philips considers that sites on the edges of settlements could play a key role in meeting this need.

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Q-H1-1 The NPPF is clear 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” (Para 11b). It also states 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…” (Para 61). In this context, it is noted that the 2021 Scoping Consultation set out the housing need context for the SWLP, highlighting that the SWLP housing requirement is underpinned by the Local Housing Need [LHN] figure generated by the Standard Method. For the SWLP area, on the whole, the Scoping Consultation stated that the SWLP will need to deliver a minimum of 1,230 new homes each year, or c.35,000 dwellings over the 30-year plan period. St Philips considers that the Council’s proposed strategy is acceptable in principle and that the deviation from the Standard Method is enabled by the NPPF and PPG. As acknowledged above, NPPF paragraph 61 states that the local housing need figure determines the minimum number of homes needed. Therefore, an uplift can be applied when supported by evidence. As acknowledged within the Issues and Options document, subsequent to the release of the 2014-based projection, based on more up-to-date assumptions about fertility, mortality and household formation rates, the Housing and Economic Development Needs Assessment [HEDNA] applied alternative projections through the framework provided by the standard method. St Philips considers this deviation to be acceptable in principle. Based off of the trend based projections as presented within the HEDNA, the overall housing need within South Warwickshire has increased when compared to the 2014-based projection from 1,239 dwellings per annum [dpa] to 1,679 dpa. In this instance, South Warwickshire will have to provide a greater supply of deliverable sites in order to meet this greater housing need. St Philips considers that the identification of a variety of suitable sites would accord with paragraph 60 of the NPPF which clearly states that: “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.” As stated above, the use of the HEDNA and the Council’s deviation from the Standard Method is acceptable in principle. As recognised by the Issues and Options Consultation, the standard method framework is the starting point for assessing the housing need. Both the NPPF3 and PPG4 are clear that the LHN figure generated by the standard method is a minimum starting point (i.e. actual housing need may be higher than this figure). Moreover, elsewhere in the guidance, the PPG differentiates between the minimum figure arrived at through the standard method and ‘actual’ housing need which can be higher. Although the HEDNA deviates from the LHN, it is highly likely that an additional uplift will be required as discussed within the response to question H4 below. It is ‘actual’ housing need that represents the objectively assessed need to which the tests in paragraph 11 of the NPPF apply, and there is also a requirement for the Council to test reasonable alternatives5 . Therefore, the Council should actively identify whether there are reasons for testing higher figures as estimates of housing need. Fundamentally, this is because the standard method does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour, nor considers local factors, policy and aspiration which might legitimately mean the Council should seek to plan for more homes than the minimum. The PPG goes on to state that it would be appropriate for a higher figure to be adopted on the basis of employment, infrastructure, affordable housing or unmet housing needs. In this regard, St Philips recommends that the SWLP should seek to deliver a greater number of dwellings over and above the housing need figure set out by the HEDNA. As discussed below, the substantial level of demand for affordable housing within South Warwickshire justifies an uplift to the objectively assessed need figure identified within the HEDNA in order to address the worsening affordability within the area. In the context of affordable housing, whilst the Standard Method includes an adjustment to take account of the median affordability ratio, the PPG7is clear that an increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes. In addition to addressing the affordable housing requirement within South Warwickshire, the scale of the unmet housing needs emerging from within the C&WHMA and GBBCHMA (c.78,000 dwellings) are likely to require an uplift to the housing need figure for South Warwickshire as identified by the HEDNA. The requirement to accommodate these needs is set out below within the response to question H4. Q-H3: The Issues and Options document states that the Council has acknowledged, through public engagement, the request for minimum internal space standards to be applied through a local plan policy. In addition, St Philips notes that it was agreed in response to a Notice of Motion to Council in Warwick District, that the principle of incorporating Nationally Described Space Standards within the SWLP would be considered (see Cabinet meeting for 29 September 2022, Item 09). It is stated within the Issues and Options document that this would be considered as part of the Local Plan Review process. St Philips recognises the importance of including design-based policies within the Local Plan Review in order to enhance the existing character of the District and provide a good quality of life for current and future residents. It is important to note Footnote 49 of NPPF paragraph 130(f), which states that policies may “make use of the nationally described space standard, where the need for an internal space standard can be justified.” Furthermore, NPPF paragraph 31 states that all policies should be “underpinned by relevant and up-to-date evidence”. In addition, the PPG[1] sets out: “Where a need for internal space standards is identified, the authority should provide justification for requiring internal space policies. Local planning authorities should take account of need, viability and timing” In consideration of the above, St Philips advises South Warwickshire that, should a policy approach that requires the delivery of dwellings to the NDSS be adopted, the Council should provide a local assessment evidencing the case for the District in accordance with the NPPF and PPG. Therefore, it is recommended that the Council should complete further evidence gathering prior to including a policy. Additionally, it is important to note that any policy requirement would also need to be considered and tested through a viability assessment before adoption. This would ensure that the approach is supported and justified by up to date evidence and that the approach can be found to be legally compliant with both the NPPF and the PPG. Q-H4-1: The SOADC 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.” 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. 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 Greater Birmingham and Black Country Housing Market Area [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 blog9 “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. 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 SWAs do not limit the release of sites for residential purposes that would otherwise be sustainable and suitable.

The NPPF is clear that: “the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to, those who require affordable housing…)” (Para 62). In this regard, the HEDNA sets out new trend-based projections for the sub-region. The HEDNA finds that Stratford-on-Avon will need to deliver a minimum of 868 dpa over the plan period, whilst Warwick will need to deliver 811 dpa. In relation to affordable housing, the HEDNA identifies a total affordable housing need of 547 dpa for Stratford-on-Avon and 839 dpa for Warwick (HEDNA, Table 8.45). The HEDNA is clear that the affordable housing figures should be used for reference purposes and that decisions about an appropriate mix for an individual area will be informed by viability and local priorities. Issues regarding affordability are particularly acute within South Warwickshire, with the HEDNA noting “that the areas where the need for AHO [Affordable Home Ownership] is highest (notably Warwick and Stratford-on-Avon) also show a high need for rented affordable housing” (HEDNA, para 8.98). In light of this identified need, St Philips considers that an uplift to the LHN figure should be considered. The PPG8 is clear that an increase in the total housing figures included in the plan could help address the affordability of homes, through the delivery of an increased number of affordable homes. It is likely that there will be a substantial level of demand for affordable housing within the area and that an uplift to the LHN figure to help deliver affordable housing would likely be justified, and necessary to addressing worsening affordability. St Philips therefore considers that this is the best approach to increasing the supply of affordable housing in South Warwickshire. In regard to the approaches set out by the IO document, St Philips has no preference between Options H2-2a and H2-2b, however considers that Option HS-2c is not an appropriate response. Paragraph 34 of the NPPF is clear that: “Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure… Such policies should not undermine the deliverability of the plan.” As the IO recognises, localised affordable housing requirements can create uncertainty, making it more difficult for developers to predict their costs and harder for Councils to predict delivery of affordable houses. This could undermine the SWLPs ability to deliver on affordable housing targets. St Philips therefore considers that Option Hs-2c should not be considered as it would not significantly increase the supply of affordable housing within South Warwickshire, and indeed, could negatively affect its provision.

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St Philips welcomes South Warwickshire’s acknowledgement of the need to help meet the unmet needs of the Coventry and Warwickshire Housing Market Area [C&WHMA] and the GBBCHMA. The IO states: “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. However, South Warwickshire is also within the Birmingham and Black Country HMA… Through the duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs” (Page 111). In this regard, St Philips notes that within the GBBCHMA there is emerging evidence of an acute level of unmet housing needs. Birmingham City Councils New Local Plan 2020-2042-Issues and Options [BCCIO] has recently confirmed that, as of March 2022, Birmingham’s LHN figure is 7,136 dpa (Para 4.7). This includes an additional 35% for the top 20 largest cities in the UK. Cumulatively, this would equate to a housing need figure of 149,286 dwellings for the 22- year plan period (2022 to 2042). The BCCIO states that the Council can currently demonstrate a supply of 70,871 dwellings, which includes completions between 2020/21- 2021/22 of 6,624 dwellings. The BCCIO concludes that, at present, there is a shortfall of around 78,415 dwellings to be found through the preparation of the BDP Review (Para 4.15). Alongside Birmingham’s emerging unmet needs (c.78,000), another significant source of potential unmet needs is from within the Black Country. It is important to note that the Black Country Plan is no longer being jointly prepared and thus the Black Country Authorities will now prepare individual Local Plans; however, it is highly likely that the unmet need for housing c.28,000 dwellings still remains in the Black Country; albeit, now disaggregated amongst the four Black Country Authorities. As such, the level of unmet housing needs in the GBBCHMA is likely to be severe. St Philips acknowledges that Coventry’s need has been reduced from 3,188 dpa as per the 2014-based projection to 1,964 dpa as per the trend-based projection. Although, it is important to note that an updated housing trajectory has not yet been released for Coventry meaning that the unmet need is yet to be calculated. It is highly likely that South Warwickshire will need to accommodate part of this unmet housing need. Given that Coventry has a very small amount of land that is outside of the urban area and free from constraints (equating to c.2% of the authority’s area) St Philips consider that it is extremely likely that Coventry will require further assistance in meeting its housing needs post-2031. In this context, paragraph 11b of the NPPF is clear that: “b) 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, unless: the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole” In this regard, the IO recognises that “given the size of South Warwickshire it is considered that any additional needs can be accommodated outside of any protected areas” (Page 109). The exception to this is noted to be areas within the Green Belt, however these sites would only be considered if suitable, appropriate, and necessary. St Philips considers that areas like South Warwickshire with such a large quantum of available land have a duty to support housing growth and not only address its housing need, but also the shortfall of housing provision within surrounding authority areas. Whilst St Philips acknowledges that it is not for South Warwickshire to address these unmet needs in full, given the scale of the shortfall arising from the GBBCHMA, St Philips considers that South Warwickshire must play a significant role. It is important that South Warwickshire makes it clear that it will help address the acute unmet need and should, where possible, be specific in the exact proportion of the unmet need that the upcoming Local Plan can accommodate. Indeed, this is particularly pertinent, given the Inspector’s recent findings10 in respect of the Sevenoaks Local Plan where problems of unmet need were not adequately addressed through the duty to cooperate process, resulting in a terminal failure of legal compliance. Unless a proportionate contribution towards the unmet needs identified is accommodated, South Warwickshire risks not fulfilling its ‘duty to cooperate’ with neighbouring authorities, as required by paragraph 24 of the NPPF. St Philips supports South Warwickshire’s acknowledgement of the Duty to Cooperate but also recommends that a proportionate contribution should be made to ensure that the emerging Local Plan can pass the test of soundness. St Philips consider that a functional relationship approach is a suitable strategy and refers to Lichfields’ ‘The Black Country’s next top model’. Lichfields’ model drew on the precedent set in the C&WHMA/North Warwickshire and has been again supported by the emerging approach in the Leicester and Leicestershire HMA. Both Stafford Borough Council and South Staffordshire Council reflected on Lichfields’ model in the latest sustainability appraisals for the current consultations, St Philips therefore encourages South Warwickshire to adopt Lichfield’s model in order to sustainably distribute Birmingham’s and Coventry’s unmet housing need. The model calculates the proportion of housing that can be sustainably redistributed towards surrounding authorities based on the functional relationship between the administrative areas. Such a model takes account of the below trends within the HMA and between authorities with a functional relationship: 1 Migration patterns between authorities; 2 Commuting linkages between authorities; 3 Opportunities to capitalise on sustainable transport links; 4 Affordability pressures; and 5 The degree of environmental and physical constraints. The objective should be to create an agreed position with regard to the spatial distribution of housing that is justified based upon technical evidence and which can be used to underpin the preparation of Local Plans. This would ensure that as and when a spatial distribution methodology is agreed, South Warwickshire will have in place a sufficient supply of sites which have been tested through an acceptable model and other evidence base documents.

As set out above, St Philips considers that it is imperative that the SWLP assists with meeting the acute housing needs of neighbouring authorities. St Philips notes that the ‘SWLP Urban Capacity Study (October 2022)’ has established that South Warwickshire is unlikely to be able to meet its (or neighbouring authorities) development needs solely through the use of previously developed land.11 Therefore, regardless of whether the SWLP prioritises brownfield land, there will still be a need to identify suitable greenfield land for development. In this regard, sites such as Land at Jubilee Fields offer a sustainable location for housing growth. As discussed, St Philips considers that there is a need to disperse some growth to smaller settlements throughout the District. The Site is located on the edge of Stockton which offers a range of facilities and services such as a primary school, post office, restaurants, and a sports ground. It is located c.2 miles north-east of Southam and 8 miles south-west of Rugby. The village is connected to Leamington-Spa and Rugby by bus services 63 and 64. Small scale growth at Stockton would therefore benefit local services and support the overall sustainability of Stockton. The Site could therefore contribute to helping meet the needs of South Warwickshire and its neighbours.

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Q-C4.1 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. 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.” 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. 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. 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. 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”. (MHCLG Summary Response to the FHS (2019 Consultation Changes to Part L and F). 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. 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”. 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 standards.This is a step towards achieving zero carbon ready homes by 2025. 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.” 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. 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: 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. 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 [BNG] requirement of 10% is a factor which will need to be addressed as part of any application. 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.” 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…” 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. In this context, St Philips supports the inclusion of compensatory measures, including biodiversity offsetting (i.e. Biodiversity Net Gain). 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.