Issue and Options 2023
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Q-T1: Option T1b: Include reference to the principles of a 20-minute neighbourhood or other similar design approach (e.g. Building for a Healthy Life) within a broader overarching policy. 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). 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).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: 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.” 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. 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.
Q-V3.1 Do you agree that the Vision and Strategic Objectives are appropriate? 2.2 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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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 land.1 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. 2.10 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). 2.16 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). 2.17 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. 2.18 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). 2.19 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. 2.20 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. 2.21 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]. 2.22 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 requirements 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 whether you feel it is an appropriate strategy for South Warwickshire: 2.23 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 2.24 For each growth option an indicative list of settlements is provided. It is noted that many locations feature in more than one option. In this regard, St Philips is promoting land on the edge of Studley for residential development. In the context of St Philip’s site, it is noted that Studley is identified as a potential location in Growth Options 2 (Sustainable Travel), Option 4 (Sustainable Travel and Economy) and Option 5 (Dispersed). St Philips welcomes the inclusion of Studley in several Growth Options. 2.25 Some of the proposed 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. 2.26 Nevertheless, St Philips considers 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 SA evaluates the 5 spatial growth options and concludes the following: South Warwickshire Local Plan: Regulation 18 Issues and Options Consultation : Representations on Behalf of St Philips Pg 8 “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). 2.27 The SA goes on to acknowledge that different options perform better for certain SA objectives than others. St Philips also notes that the SA does not consider the potential for mitigation when evaluating the growth options, and that the scores are “strictly a guide and do not represent a diagnostic analysis” (Para 7.15.1). St Philips therefore considers that the SA is inconclusive regarding which of the growth options performs best. In this context, St Philips believes that the spatial strategy should not entail one particular growth option. 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. 2.28 Regardless of which growth strategy the Council pursues, St Philips considers that some development will likely 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 (Dispersed) 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. 2.29 On this basis, St Philips considers that a mix of the Growth Options will promote sustainable patterns of development across South Warwickshire 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 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 (Para 142); South Warwickshire Local Plan: Regulation 18 Issues and Options Consultation : Representations on Behalf of St Philips Pg 9 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 Brickyard Lane, Studley 2.30 As set out in Section 1.0 of these representations, St Philips is promoting Land at Brickyard Lane, Studley for residential development. The site, encompassing an area of c.1.78 ha, is formed of a singular field of grassland which fronts the A448 and Brickyard Lane and is enclosed to the east and west by residential housing and the Renshaw Industrial Estate. The site is well contained with established vegetation along the site boundaries and a category A tree situated to the north-west corner of the site. It is rectangular in shape and generally flat. 2.31 The Site is situated on the western edge of Studley, in the Green Belt. Studley is located approximately 12 miles north-west of Stratford-upon- Avon, 5 miles south of Redditch and 20 miles south of Birmingham. A regular bus service also runs through the village providing connections to Studley and Redditch. Redditch Railway Station provides regular train services into Birmingham New Street. 2.32 The land has previously been promoted through the Call for Sites process, culminating in its inclusion within the 2018 and 2020 Strategic Housing Land Availability Assessments [SHLAA] (Site Ref: STUD.22). 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. However, the Site was excluded from the Council’s process as it fell within the Green Belt. 2.33 St Philips wishes to reaffirm the site’s status as being ‘suitable, available and achievable’. The Site could provide approximately 1.3 ha of residential development, equating to approximately 50 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 dwellings to the east and west, and has an enclosed landscape setting. 2.34 St Philips consider that the Site presents an excellent location to deliver up to 50 dwellings, including up to 18 affordable dwellings. The scheme would be responsive to its surroundings, including through the protection and enhancement of the strong Green Infrastructure network. Connectivity through the Site and to the village and surroundings would be emphasised to encourage sustainable travel.
Q-S4.1 St Philips considers that the growth of existing settlements should form an important part of the 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. 2.12 In this context, St Philips is promoting the land at Brickyard Lane on the edge of Studley for residential development. Within the existing Core Strategy, Studley is identified as a Main Rural Centre [MRC]. MRCs provide “a good range of shops, facilities and jobs compared with smaller villages. They also tend to have more frequent public transport services than most of the District’s smaller settlements” (Core Strategy, para 5.1.8). Studley offers facilities such as supermarkets, butchers, a chemist, primary and secondary schools and various community facilities. It is also one of the largest villages within the District and is identified as suitable location for housing and business development and the provision of local services in SOADC’s Core Strategy. Indeed, the ‘Sustainability Appraisal of the South Warwickshire Local Plan November 2022’ [SA] finds that Studley is one of the better performing options against Sustainability Appraisal Objectives such as Health, Economy and Accessibility. 2.13 Allocations that support the growth of Studley would therefore be highly sustainable and would support local services. 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). 2.14 St Philips 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. Whilst 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), it 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 need to allocate a variety of small-medium sized sites. St Philips considers that the proportionate growth of existing settlements will play a key role in fulfilling this requirement.
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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). 2.36 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). 2.37 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. 2.38 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. 2.39 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. 2.40 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. 2.42 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. 2.43 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.6 2.44 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. 2.45 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. 2.46 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
