Issue and Options 2023

Yes

Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Growth of South Warwickshire’s existing settlements should form part of the overall development strategy to deliver sustainable development which meets the needs of the local community. Paragraph 79 of the NPPF (2021) is clear that planning policies should ‘identify opportunities for villages to grow and thrive’, thus development sites should be allocated across the broad spectrum of South Warwickshire’s towns and villages. It is recommended that a settlement hierarchy is utilised to ensure development is directed towards the most sustainable towns and villages and the level of growth proposed is commensurate of the settlement’s sustainability. Settlement hierarchies are a well-established planning tool which assist Local Authorities in meeting the overarching economic, social and environmental sustainability objectives set out in paragraph 8 of the NPPF (2021) and will assist in meeting the Council’s 13 sustainability objectives identified in the Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Issues and Options Stage (November 2022).A development strategy which includes expansion to existing settlements which is underpinned by awell-evidenced settlement hierarchy and housing and employment needs assessment will meet the test of soundness set out in paragraph 35 of the NPPF (2021). It would be positively prepared to meet South Warwickshire’s objectively assessed needs, justified by utilising an appropriate strategy based on proportionate evidence and consistent with the overarching aims of national planning policies. Q-S4.2: Bidford-on-Avon is a highly sustainable settlement which offers a wide range of facilities and services to meet the needs of local residents, including access to public transport to provide sustainable connections to nearby towns and villages. Bidford has been identified in the Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Issues and Options Stage (November 2022) as a small settlement location which is within easy foot or riding distance to key services to assist in contributing to the 20-minute neighbourhood principles. A 20-minute neighbourhood is defined as ‘a compact and connected place, with a range of services that meet most people’s daily needs. A compact neighbourhood is one in which land is used efficiently so that buildings are distributed appropriately for their uses’ in the 20-minute Neighbourhood Guide (2021) prepared by the Town and Country Planning Association. The key principle relates to a 10-minute walk each way between homes and services. The principles of the 20-minute neighbourhood have underpinned the South Warwickshire Settlement Analysis (2023) and it is our understanding that subject to further consultation and evidence base preparation, the Councils are intending to incorporate the principles within the South Warwickshire Local Plan. As part of the individual identification of settlements, detailed in section 3.5 of the Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Issues and Options Stage (November 2022), Bidford has been identified as a smaller location which may be able to deliver 50-500 new homes. We agree with this view in principle given that Bidford is a highly sustainable settlement. However, 500 dwellings should not be considered a maximum upper limit if it can be demonstrated that additional development can be delivered which accords with the three overarching sustainable objectives set out in paragraph 8 of the NPPF (2021). This is particularly prudent given the current housing crisis and the national requirement to significantly boost the supply of homes. We are also not aware of any justification that has resulted in the upper limit and therefore to meet the test of soundness detailed in paragraph 35 of the NPPF (2021), the identified range should be a guide figure and the proposed allocations in each settlement should derive from the evidence base prepared in support of the local plan preparation. Our client is promoting Land North of Stratford Road, Bidford (ref: 562), which can deliver circa 500 homes. As set out in our supporting Vision Document (March 2023), we consider that a high-quality scheme can be delivered which positively contributes to the Council’s 13 sustainability objectives. The proposed level of housing facilitates the provision of other land uses on site, including employment development, a care home and a local centre. The non-residential elements of the scheme would be of benefit to the entire local community, elevating the sustainability of Bidford and further supporting the Councils aspiration of achieving 20-minute neighbourhoods. The submission of the mixed-used site should be given due consideration in assessing the sustainability of Bidford and its potential for growth. Overall, we agree with the connectivity analysis for Bidford contained in the Settlement Design Analysis (Appendix 2) which assesses the settlements edges to be Grade A (best connectivity) through to Grade E (poorest connectivity). Land North of Stratford Road is assessed to be Grade B (parcel 11(B)) and Grade C (parcel 12 (c)). The Grade B parcel being located on the eastern side of Grafton Lane and Grade C to the west. The analysis notes that a connection to the industrial estate would increase the connectivity performance of the western parcel of land. The analysis does not highlight any other growth areas which score higher for connectivity thus our client’s site presents an excellent opportunity for settlement expansion in an area which will support the 20-minute neighbourhood principles. The mix of land uses proposed at Land North of Stratford Road will further increase the connectivity of the site to key facilities and services. The local centre and care home is proposed to be located to the west along Stratford Road to reduce walking and cycling distance for the community. The proposed employment development to the north west of the site will be accessed via a new vehicular and pedestrian access from Grafton Lane which will increase parcel 12(c)’s connectivity performance in line with the Councils recommendation. A vehicular and pedestrian access is also proposed between the employment land and Wellington Road to further improve connectivity to the north of the settlement. We agree with the landform analysis prepared by the Council. Land North of Stratford Road is not impacted by the flood zone, existing green infrastructure or topography. Furthermore, the site is not constrained by any known insurmountable technical constraints. The density analysis for Bidford provides a useful evidence base to inform the preparation of site layouts. The evidence has been incorporated within the vision for our client’s site. Firstly, the employment land has been located to the north west which will result in it being read as an extension to the existing industrial area. Whilst we are not at a detailed design stage, we consider a development could come forward which responds to the existing density of Bidford and provides a lower density suburban edge along its eastern boundary. We also agree with the Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-onAvon Local Plan (SWLP) (September 2022) which concludes that the eastern edge of the settlement is an appropriate location for growth from a heritage perspective. To ensure the South Warwickshire Local Plan meets the test of soundness detailed in paragraph 35 of the NPPF (2021), it is paramount that the Councils use the evidence base, including the settlement analysis, to develop a plan which is justified.

We agree that the emissions modelling is a useful element of the evidence base to inform the Local Plan. However, it is important to note that reducing emissions is only a small element of achieving sustainability and this needs to be balanced against building a strong, responsive and competitive economy, supporting strong, vibrant and healthy communities and significantly boosting the supply of homes. Warwick District Council and Stratford on Avon District Council, as plan-makers, need to take into account the emissions model along with the full evidence base to ensure the plan meets the test of soundness including being positively prepared, justified, effective and consistent with national policy.

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The delivery of employment land to meet economic needs should not be viewed in isolation to the delivery of residential development. To support local and national economic objectives, it is essential that sufficient employment land is delivered to meet the needs of South Warwickshire and any unmet need from neighbouring Authorities. In location’s where substantial residential growth is proposed, it would be beneficial to increase employment land to support the economic vitality of the settlement and reduce the communities need to travel to access employment. As part of the proposal for Land North of Stratford Road, Warwickshire Property Development Group are proposing to deliver circa 1.8 hectares of industrial land which will be accessible from the existing industrial development and Grafton Lane. This development will make effective use of the previously developed land and will provide employment opportunities to existing and future residents of Bidford. The provision of a local centre and care home along Stratford Road will also provide a small number of jobs for the local community. Boosting the supply of employment land is particularly important to assist in the current economic recovery and to support the creation of a strong, responsive and competitive economy. Elevating the economy of Bidford will have a knock-on effect on the wider area and a prosperous economy can also assist in contributing to local and national environmental and social objectives.

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In accordance with Table 9 (Overall Housing Need in Coventry and Warwickshire (dwellings per annum) of the South Warwickshire Local Plan Part 1 (Stage 2: Issues and Options Consultation, January 2023), the 2014-based projection results in a housing need of 1,239 per annum for Stratfordon-Avon and Warwick. The trend-based approach results in an increased housing need of 1,679 per annum. It’s important to note that for all other Local Authorities in Coventry and Warwickshire, the trend-based projection results in a lower housing need, with the exception of Rugby. Paragraph 61 of the NPPF (2021) is clear that to determine the local housing need, the standard method must be used unless ‘exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals’. This is reiterated in paragraph 003 of Planning Practice Guidance relating to Housing and Economic Development Needs Assessments which reads as follows; ‘there is an expectation that the standard method will be used and that any other method will be used only in exceptional circumstances.’ The first step to calculating housing need in the Planning Practice Guidance is setting the baseline using the national 2014-based household projection rather than a trend-based approach. The Coventry & Warwickshire Housing and Economic Development Needs Assessment (HEDNA) (November 2022) states that ‘population growth for Coventry appears to be systematically overestimated, which leads to trend-based projections that are demonstrably too high. Additionally, there is evidence that more recent trends in population growth (confirmed by Census data) in many parts of Warwickshire have been stronger than in the period to 2014 – mainly due to changes in migration levels – and so the 2014-based figures can be thought of as unreliable. It is also the case that other key aspects of population projections (fertility and mortality rates) have diverged significantly from those projected in the 2014-based projections.’ Paragraph 015 of Planning Practice Guidance relating to Housing and Economic Development Needs Assessments states that ‘where an alternative approach results in a lower housing need figure than that identified using the standard method, the strategic policy-making authority will need to demonstrate, using robust evidence, that the figure is based on realistic assumptions of demographic growth and that there are exceptional local circumstances that justify deviating from the standard method. This will be tested at examination.’ Thus, whilst we have not scrutinised the data and evidence underpinning the proposed trend-based approach, in our view proceeding with the alternative approach presents a risk of significant scrutiny during examination testing. In any event, the objectively assessed housing need is a minimum starting point. As detailed in paragraph 10 of Planning Practice Guidance relating to housing and economic needs assessment, the objectively assessed housing need is ‘a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour.’ It is also strongly recommended that South Warwickshire include a further economic uplift to facilitate growth and support the community in the economic recovery. The economic benefits of delivering housing and its contribution to building a strong and competitive economy in line with paragraph 8 of the NPPF (2021) is well established. The Economic Footprint of UK Housing Building in England and Wales (July 2018) prepared by the Home Builders Federation and Lichfields states that £39bn is generated as an economic output as a result of house building each year. This financial output can also result in a positive impact on the environmental and social objectives outlined in national planning policies. As detailed in our response to Q-H2-1, South Warwickshire have a significant need for affordable housing. Chapter 6 of the South Warwickshire Local Plan Part 1 (Stage 2: Issues and Options Consultation, January 2023) is clear that affordable homes are primarily delivered as a percentage of market housing schemes. Thus, in order to significantly boost the supply of affordable homes to meet the needs of the local community, a further uplift to the assessed housing need is required. As detailed in our response to Q-H4-1, Q-H4-2 and Q-H4-3, an uplift is also required to meet the needs of neighbouring Authorities in accordance with the duty to cooperate and the test of soundness.

As detailed in Chapter 6 of South Warwickshire Local Plan Part 1 (Stage 2: Issues and Options Consultation, January 2023), the primary source of affordable housing is through delivery as part of market housing schemes. We are not aware of any policy change which is likely to alter this position. Thus, we strongly recommend that the best way to significantly increase the supply of affordable housing across South Warwickshire is to allocate sites for residential development significantly above the minimum objectively assessed need. This aligns with the planning practice guidance which makes clear the identified need is a minimum starting point and uplifts can be applied where it is justified. This approach would in our view meet the test of soundness by being positively prepared to meet local need, justified by being based on an appropriate evidence base and consistent with national policies aim of significantly boosting the supply of homes. To ensure the Plan is effective, we recommend that as the Plan preparation progresses, South Warwickshire agrees Statements of Common Grounds with all landowners and developers that have draft allocations within the plan, this will assist in demonstrating deliverability at independent examination.

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In order to address the specialist needs for older people, we recommend that a specific planning policy is included in the South Warwickshire Local Plan. Similar to that contained within the Warwick District Local Plan (September 2017) and Stratford-on-Avon District Core Strategy (2011-2031), a criteria-based approach would be considered an appropriate mechanism for controlling the delivery of older people accommodation. However, these Plan’s do not allocate sites which are suitable for meeting the identified need and instead rely on applicants demonstrating proposals meet the needs of older people. In order to ensure older people accommodation is delivered in South Warwickshire, we recommend the plan incorporates appropriate allocations. This could either be as part of a wider mix-used schemes or sites solely for the delivery of older people accommodation. This strategy will accord with the test of soundness detailed in paragraph 35 of the NPPF (2021) by meeting the objectively assessed need through allocated sites which have derived from aproportionate evidence base. It will also align with national planning policies which state that plans should reflect the need for different groups in the community, including older people. It is essential that older people accommodation is situated in highly sustainable locations which are accessible to facilities and services to meet the day to day needs of the residents. This will not only support the environmental objective by reducing the need to travel but it will result in significant social benefits by creating a strong, vibrant and healthy community. As part of the proposal for Land North of Stratford Road, Warwickshire Property Development Group are proposing to deliver a care home adjacent to the proposed local centre. It is strongly contended that the older people accommodation will meet the needs of the local community, in a location which accords with local and national sustainability objectives.

No

Q-H4-1: Chapter 6 of the South Warwickshire Local Plan Part 1 (Stage 2: Issues and Options Consultation, January 2023), states that ‘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 owing to Stratford-on-Avon District’s shared boundaries and inter-relationships with Solihull and Redditch boroughs and Bromsgrove district’. The identified sites in Stratford-on-Avon amount to a total of 530 dwellings, including STR.D – East of Banbury Road, Stratford-upon-Avon which has infrastructure constraints. In accordance with the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Position Statement Addendum (December 2021), the total shortfall of housing is 66,139, comprising of 37,900 arising from Birmingham and 28,239 from the Black Country. In 2021, the identified contribution from Authorities within the housing market area totalled 13,935. Thus, there remains a significant shortfall across the HMA which has not been accounted for. Given the scale of the unmet need, we strongly disagree with the Council’s proposed approach to meeting the Birmingham and Black Country shortfall. It is not clear what evidence the Council is using to underpin this approach. Thus, if South Warwickshire were to continue without further evidence, the test of soundness would not be satisfied. Moreover, South Warwickshire should be fostering a positive and proactive approach to delivering sustainable housing to assist in addressing the current housing crisis. The NPPF (2021), is clear that for a Plan to be found sound. it must be positively prepared which includes as a minimum ensuring that ‘unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development’. We are not aware of any evidence which demonstrates that allocating additional sites to contribute to meeting the Birmingham and Black Country HMA shortfall to 2031 is unpractical or fails to achieve sustainable development. Thus, we strongly recommend that South Warwickshire include an uplift on their housing need to address this identified unmet need. We do however agree that given the location of the unmet need, the allocation of additional sites would be most appropriate within Stratford-on-Avon given its proximity to the source of the unmet need. Q-H4-2: As detailed above in our response to Q-H4-1, South Warwickshire should be allocating additional sites to assist in meeting the Birmingham and Black Country HMA shortfall to 2031. The South Warwickshire Local Plan subject of this consultation does however have a plan period of up to 2050. Thus, in order for the plan to meet the test of soundness, it must take into account the shortfall arising over that period. Birmingham City Council has commenced its Local Plan Review to 2042. The Council has identified a shortfall in housing of 78,415 homes. The Black Country Local Plan is no longer proceeding and the Local Plans for the four Black Country Councils will now be prepared separately. Thus, it may be that an additional shortfall for the HMA will be identified through the planmaking process. Therefore, South Warwickshire should accommodate a proportion of the shortfall identified by Birmingham up to 2050. It is also highly likely additional unmet need will arise from the Black Country and we recommend that South Warwickshire keep this under constant review to ensure a flexible Plan is prepared which can assist in meeting any unmet need identified. It is essential that this is incorporated within the plan to ensure that it meets the test of soundness by being positively prepared, justified, effective and consistent with national planning policies.

It is our view that the ideal position would be to allocate sites for unmet need as close to the area which has an identified unmet need. However, given the scale of the unmet need to be accommodated within South Warwickshire, this approach could lead to disproportionate growth in certain areas which could have a determinantal impact on achieving sustainability. Thus, we recommend that approach is undertaken in conjunction with utilising the Council’s settlement hierarchy to direct development towards the most sustainable settlements in South Warwickshire.

No

2.1.1 The intention to develop a vision and strategic objectives that cover the period to 2050 is supported and is in accordance with Paragraph 22 of the National Planning Policy Statement, which states: “Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.” 2.1.2 The longer-term framework is required to inform both plan making and decision taking. However, to accord with this approach, the SWLP should include consideration of the spatial strategy over this period, including future infrastructure requirements. 2.1.3 Paragraph 11 of the NPPF highlights the need for plans to promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects. The vision and strategic objectives are too narrowly focused on the main settlements and not therefore compliant with Paragraph 11 of the NPPF. There is a need to ensure that a comprehensive vision for the plan area provided, which will in turn provide a more suitable basis for preparing LP2s for each district. A comprehensive vision that relates to the plan area as a whole should be one of the key drivers for preparing a Joint Local Plan. 2.1.4 The vision and strategic objectives as written are not therefore considered to have sufficient granularity.

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2.1.5 Given the need for the vision and spatial objectives to provide a comprehensive vision for the whole of the plan area (not just the main settlements) it follows that the Local Plan should identify the infrastructure requirements for all scales, types and location of development (Option I2a). This approach is also consistent with Paragraph 11 of the NPPF. 2.1.6 In terms of the relationship between infrastructure delivery and development, with SWLP should accord with Paragraphs 68 of the NPPF and in so doing: “identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability”. 2.1.7 Too much emphasis on larger site allocations could also negatively impact on housing delivery due to some common problems associated with bringing such sites forward. For example, it of common for large sites to be in multiple ownerships requiring complicated legal arrangements to be in place before development can be progressed. There are also often lengthy lead in times due to enabling infrastructure being required first to ‘open up’ a site. Mindful of such issues, the NPPF at Paragraph 69 further states that: “small and medium sized sites can make an important contribution to meeting the housing requirements of an area, and are often built out relatively quickly.”