Issue and Options 2023

47 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). 2.48 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. 2.49 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. 2.50 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. 2.51 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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Q-H3 - Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. 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. 2.54 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. 2.55 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”. 2.56 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” 2.57 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: 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 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.” 2.59 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. 2.60 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 blog “All the West-laid Plans: The unmet housing needs of the Greater Birmingham and Black Country Housing Market Area”. 2.61 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. 2.62 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 thisapproach as it ensures that the SWAs do not limit the release of sites for residential purposes that would otherwise be sustainable and suitable.

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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). 2.64 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. 2.65 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). 2.66 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. 2.67 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. 2.68 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: (i) 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 (ii) 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” 2.1 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. 2.2 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. 2.3 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. 2.4 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. 2.5 The model calculates the proportion of housing that can be sustainably redistributed towards surrounding authorities based on the functional relationship between the administrative areas. 2.6 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. 2.7 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. 2.8 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 South Warwickshire’s neighbouring authorities. Given the scale of the unmet need, St Philips considers that there is a need to review the Green Belt within the district. In this context, St Philips welcomes the IO’s recognition that: “A review of the Green Belt across South Warwickshire is an important piece of evidence to underpin the approach taken in the Local Plan. It would consider whether there are any areas which no longer meet all five of the Green Belt purposes and could be removed to allow for the most sustainable development to come forward, including the provision of affordable housing and employment opportunities.” (IO, page 57). 2.10 St Philips is highly supportive that the IOs approach has been ‘blind’ to whether a particular location or corridor is in the Green Belt. This approach ensures that sustainable locations within the Green Belt are not prematurely excluded from consideration. The IO recognises that: “The location and spread of the Green Belt in South Warwickshire may mean that limiting growth to locations outside of the existing Green Belt designation may not be the most sustainable or climate friendly option as it pushes development away from areas that are well connected with good infrastructure and better access to facilities and services towards areas with more limited infrastructure and where further travel would be necessitated” (page 56). 2.11 Notwithstanding the above, St Philips acknowledges that the NPPF is clear of the weight attached to the Green Belt by the Government, and that “once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans.” (Para 140). The NPPF sets out that prior to considering whether “exceptional circumstances” exist, local planning authorities should have “demonstrated that it has examined fully all other reasonable options for meeting its identified need for development” and goes onto provide a set of criteria that should be satisfied prior to establishing exceptional circumstances (e.g. a sequential approach of sorts) (Para 141). These include (inter alia) the optimisation of brownfield land, densities and discussions with neighbouring authorities. 2.12 In this regard, the Urban Capacity Study (October 2022) “has established that it is unlikely to be possible to meet currently development needs without significant greenfield development” (Urban Capacity Study, Page 1). There is also a significant, and persistent level of unmet housing need across the GBBCHMA and many of the Council’s neighbouring authorities are already unable to meet their own needs within existing urban areas. 2.13 In establishing the “exceptional circumstances” required to review the Green Belt, St Philips consider that the Council should also have regard to the acuteness of the unmet housing needs within the GBBCHMA, which might reasonably be considered an ‘exceptional circumstance’. Indeed, in the Calverton Parish Council v Nottingham City Council High Court Judgment11, the Judge pointed to the acuteness of the objectively assessed housing needs when considering whether housing need should be considered an exceptional circumstance (Para 51).12 2.14 As such, St Philips considers that the acuteness of the unmet housing need arising from the Birmingham HMA can, and in this instance, should, constitute exceptional circumstances, as established in the Calverton case. It is therefore entirely reasonable, and indeed necessary, for the Council to review the Green Belt within the District, to help meet the needs of South Warwickshire and its surrounding neighbouring authorities. Land at Brickyard Lane 2.15 As stated, St Philips is promoting Land at Brickyard Lane, Studley for residential development. As noted, the Site falls within the Green Belt. St Philips welcomes that the IO recognises that a review of the Green Belt is an important piece of evidence that should underpin the approach taken in the SWLP. 2.16 In this context, the NPPF is clear that the assessment of whether a site should be removed from the Green Belt is subject to a site's performance against the five purposes of the Green Belt (Para 143). The Coventry & Warwickshire Joint Green Belt Study – Stage 2 Final Report (April 2016) (“the Stage 2 Report”) considers the Green Belt land of six West Midlands councils including the area within the District. The purpose of the Stage 2 Report was to assess the identified Land Parcels against the five purposes of Green Belt as set out in the NPPF. The Site is located within the south-western corner of Parcel RE3, forming just under 3% of the 62ha of the large parcel. 2.17 The Stage 2 Report concluded that Parcel RE3 was a High-Performing parcel scoring 14 out of 20 across the five Purposes of the Green Belt Policy. However, whilst Parcel RE3 scored highly against Purpose 1, 2 and 3, the site does not possess the qualities of the larger parcel. This is because the parcel sizes used in the Stage 2 Report are overly large and it is considered the Site’s contribution to all the purposes would significantly reduce if the parcel was reduced in size or subdivided. However, owing to the fact that the Council has not yet undertaken a Gren Belt review, it is necessary to consider the Site’s performance against the five Green Belt purposes set out in the NPPF, independent of the broader parcel (RE2). As such, and to inform the Vision Document, St Philips has undertaken this analysis. The Vision Document demonstrates the Site’s performance: 2.18 Purpose 1: to check the unrestricted sprawl of large built-up areas – The site is located between Renshaw Industrial Estate to the west and residential dwellings of Studley to the east, with ribbon development already along the A448. The release of the land would not cause unrestricted sprawl towards Redditch or cause westward sprawl. The site would therefore not make a major contribution to Purpose 1; 2.19 Purpose 2: to prevent neighbouring towns merging into one another – The Green Belt would be approximately 0.2km deep between Redditch and Studley, and the release of the Site would not cause Studley to merge with Redditch; and 2.20 Purpose 3: to assist in safeguarding the countryside from encroachment – The neighbouring Renshaw Industrial Estate and residential housing provide urban influences on the site and provide clear and easily recognisable boundaries that would prevent encroachment of the countryside. As such, the new and proposed Green Belt boundary would not cause significant encroachment into the countryside. 2.21 In summary, the Site is a lower performing area of Green Belt land that does not significantly contribute to the purposes of the Green Belt. A new Green Belt boundary could be established that would follow existing physical features to provide a more resilient Green Belt boundary along Brickyard Lane and would rationalise the Green Belt on the west side of Studley. As such, St Philips consider that the release of the Site from the Green Belt would be suitable and would accord with the NPPF. 2.22 In addition to the above, St Philips note that the NPPF does not require only the release of sites which perform the worst against the Green Belt purposes (i.e. low Green Belt harm). There is a need to consider the broader Green Belt policies in the NPPF as a whole. As such, regard to should be had to the promotion of sustainable patterns of development, access to public transport, whether compensatory improvements could offset the harm from removal (Para 142), and consistency of the Green Belt with the emerging Local Plan strategy. It is, therefore, an essential part of the exceptional circumstances test that Green Belt land that fulfils poor to moderate Green Belt purposes can be released if it is consistent with the Local Plan strategy for meeting requirements for sustainable development, for example, to secure more sustainable patterns of development. 2.23 In this regard, the Site is located on the edge of Studley, a MRC which provides a range of services and facilities, including three supermarkets, a butchers, a chemist, primary and secondary schools and various community facilities. Studley is one of the largest villages in the District and is also identified as a suitable location for housing and business development and the provision of local services in the Core Strategy (Policy CS.15). It is also located c.5 miles south of Redditch with a regular bus service running through the village providing connections Redditch. The Site is situated between the existing urban edge of Studley and the Renshaw Industrial Estate with access to both Brickyard Lane and the A448. 2.24 As a part of the development proposals, new public open spaces are proposed in the northern and southern areas of the site, which will be multifunctional and accommodate areas for recreation, informal footpath routes, tree planting (new and existing), attenuation and ecological enhancement. 2.25 It is, therefore, a highly sustainable location for growth, with access to services and facilities and public transport. It is also well placed to meet Birmingham’s unmet needs in close proximity to where they arise. The delivery of environmental enhancements on-site, which would be achieved as part of the development, would ensure that any harm arising as a result of the removal of the Site from the Green Belt could be offset.

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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.” 2.28 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. 2.29 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. 2.30 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. 2.31 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). 2.32 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. 2.33 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”. 2.34 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 standards13. 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.” 2.36 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. 2.37 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. 2.39 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.” 2.42 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…” 2.43 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. 2.44 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.

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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). 2.46 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). 2.47 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 profile14” 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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