Issue and Options 2023

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Form ID: 80220
Respondent: Acres Land & Planning

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Issue H3. Sizes of homes. In an ‘ideal’ world, people might choose the size of their home to fit their ‘requirements’, but that is not how the market works. People buy homes which suit their aspirations, both now and in the future. They judge whether to have a family, to accommodate visitors and guests or how many rooms they need to enable them to work from home. Their decisions are governed by choice, location, surroundings, environment and affordability. Any suggestion that market housing should be controlled by size would be fundamentally flawed. For the affordable sector, it is widely assumed that ‘square pegs ought to fit square holes’ and so a closer match is expected. Any guidance on this issue can only be advisory. More active policies to incentivise elderly people to down-size may be more worthwhile – but again, moving in one’s later years is often disruptive and so may not necessarily be feasible. A better policy approach would be to encourage builders to provide elderly persons accommodation and provide offices and spare rooms within new housing to promote home working which would in turn reduce the need for additional affordable housing and propensity to travel. Issue H5. Providing Self-build and custom-build plots: The Government has set a duty within the Self-build and Custom-building Act for authorities to deliver self-build/custom build plots. Stratford on Avon (although not having a self-build policy in their Core Strategy) has taken a pro-active approach by allocating specific small sites within their Site Allocations Plan. Other authorities have taken a less pro-active approach and have adopted a quota-based approach by seeking self-build plots as a proportion of larger sites. This is the opposite of what both self-builders or builders want, in view of their polarised objectives. I would recommend that the Councils allocate smallish sites and supplement this with informal self-build plots in smaller settlements. This conforms to Options H5a and H5c. We would not favour H5b.

Form ID: 80221
Respondent: Acres Land & Planning

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Issue H4: Accommodating needs from elsewhere. Birmingham and Coventry cannot guarantee to accommodate all their own housing needs, although the planning reform proposals floated by Government have ‘muddied the waters’ in this respect. Strategic planning is the natural solution to this but sadly the Planning reform proposals are confusing on the scope for cross boundary working. Furthermore the West Midlands mayor has absolved any responsibility for sub-regional planning through the Combined Authority (although it has not stopped him commenting on planning and green belt matters!). The solution to this issue must therefore be resolved through the Duty to Co-operate (or the alignment policy – once the Government has decided what this means).

It is logical that any notional housing needs attributed to Birmingham and Coventry should be provided reasonably close to their boundaries. This would tend to suggest that sites would therefore need to be found either in the green belt and /or mainly in Warwick District. With respect to these residents, it would also be logical for there to be available public transport links to provide the ‘umbilical cord’ to fulfil work commitments and satisfy social relationships. The potential scale of this West Midlands overspill is huge. According to the Birmingham Issues and Options Plan there is currently a 78,415 shortfall plus a 28,000+ shortfall from the Black Country. The text also suggests that Coventry has a shortfall amounting to 1964 dwellings per annum. Clearly it would be preferable to engage in some form of strategic planning so that these pressures can be assessed in a comprehensive way.

Form ID: 80222
Respondent: Acres Land & Planning

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Form ID: 80223
Respondent: Acres Land & Planning

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Form ID: 80225
Respondent: Acres Land & Planning

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Issue C4. New Buildings. The Government sets building standards through Building Regulations and therefore it would be inappropriate and confusing for the two Councils to come up with a separate sets of standards and would be almost impossible to enforce. Issue C5. Existing Buildings. The Local Plan should not set unrealistic targets which building owners cannot possibly meet. Local authorities and Government might wish to incentivise property owners to save energy and retrofit improvements. However, it would be unrealistic to require a zero-carbon target which could not have any guarantee of being achieved.

Form ID: 80226
Respondent: Acres Land & Planning

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Form ID: 80227
Respondent: Acres Land & Planning

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Issue D3. Designing Adaptable, diverse and flexible places. If authorities wish to create diverse and flexible places, there is no point in imposing fixed density requirements. The clue is in the title! Each area and/or application should be considered on its merits. The appropriate option is therefore Option D3a.

Form ID: 80230
Respondent: Acres Land & Planning

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Issue T1. 20 minute Neighbourhoods. The aim for ‘20 minute neighbourhoods’ is a desirable ‘aspiration’ which can be better applied to an urban context but has a different and wider relevance to the rural context, where people often lead more insular lives. The fact that both Stratford and Warwick are largely rural Districts seems to have become forgotten and the analysis seems somewhat ‘urban focused’. Yet many nuclear rural settlements with a shop, school and bus service are in fact potentially ideal 20 minute neighbourhoods where shopping, schooling and social activities are all done within the same community. Issue T2. Sustainable transport accessibility. There is only a limited amount that forward planning can do to generate widespread public transport provision in Warwickshire. Indeed, it could be pointless to frame new development around bus services unless those routes are guaranteed to be secure and relatively frequent. However, more development is likely to protect the frequency of bus services – if necessary supported by subsidy. The Councils should therefore make every effort to strengthen bus and train networks both by policy intervention and through direct subsidy – in the urban and rural areas.

Form ID: 80231
Respondent: Acres Land & Planning

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Form ID: 80232
Respondent: Acres Land & Planning

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Issue B3. Special Landscape Areas. The accompanying text explains that national policy does not encourage Local Landscape designations – but Stratford on Avon DC pressed ahead with them anyway! In Stratford on Avon the existence of the SLA policy is being used (in my specific self-build example) to press for additional checks, further assessments and extra plans which is creating more expense and additional controls. This new Local Plan would seem to be the appropriate opportunity to drop the formal policy and simply refer to the nature of the landscape within the text, rather than conflict with national advice. The solution is therefore Option B3c. Issue B5. Environmental Net Gain. In an ideal world we might all wish to see net environmental gain as a result of new development, but this may be difficult to achieve. The BNG policy is an expensive DEFRA policy which effectively involves a subsidy from homebuyers and developers to rich landowners holding offset land. It a regressive policy to support the agricultural industry and replace EU subsidies. I would be concerned if the Local Plan set unachievable objectives which then stifled new development through lack of viability. The Councils need to mount a test bed to see whether environmental gain can be achieved before imposing any such policy.

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