Issue and Options 2023
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2.7 Economic Policy (E3) 2.7.1 Policy relating to economic growth should ensure that this is aligned with the scale and location of planned housing growth within South Warwickshire, ensuring that a balance between homes and jobs is maintained as far it is practical to do so to help ensure that an significant increase in out-commuting or in-commuting is avoided. 2.8 Protecting Economic Assets (E6a) 2.8.1 A policy protecting economic assets, e.g. Wellesbourne Airfield, Stoneleigh Park and other similar built infrastructure is supported. Another way to ensure that such locations are not at risk from development is allocating sufficient land for housing and employment elsewhere within the plan area. 2.9 Core Employment Area (E7.1) 2.9.1 The Core Employment Area is supported. It will be important to ensure a balance between homes and employment within this area and ensure that a range of housing, including affordable housing is available to help avoid in-commuting from outside of the area. Harbury could have a role to play in helping meet housing need within the Core Employment Area. 2.10 Major Investment Sites (E7.2) 2.10.1 Allocating additional land for employment uses at the major investment sites within the Core Employment Areas is consistent with Paragraph 82 of the NPPF, it will help create the conditions in which business can invest, expand and adapt and is supported. 2.11 Existing Employment Allocations (E8.1) 2.11.1 It is agreed that existing employment allocations, including revisions to Atherstone Airfield, should be carried over into the SWLP. This will help safeguard the sites for employment use. 2.12 Protecting Existing Employment Uses (E8.3) 2.12.1 Proposals seeking the loss of a business, commercial or community building or facility should be subject to marketing, viability and alternative use tests. Such measures will help ensure that employment land and buildings are protected from development pressure for higher value uses. It is also suggested that any requirements for marketing relate to a continuous period (to avoid sites being placed on the market for a few weeks, taken off and then put back on the market).
2.14.1 Question H2.1 asks what is the best way to significantly increase the supply of affordable housing across Warwickshire? Affordable housing needs to be delivered in key settlements and villages to meet local need where it arises over the plan period. If a halt is put on development in such settlements as part of the spatial strategy this will only lead to increased affordability issues in rural areas. 2.14.2 Paragraph 62 of the NPPF highlights the importance of assessing needs and reflecting these in planning policies: “Within this context, 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, families with children, older people, students, people with disabilities, service families, travellers27, people who rent their homes and people wishing to commission or build their own homes). 2.14.3 Paragraph 63 continues: “Where a need for affordable housing is identified, planning policies should specify the type of affordable housing required, and expect it to be met on-site.” 2.14.4 This emphasises the need for the Local Plan to set out a spatial strategy with sufficient granularity to ensure that local housing needs are met where the need arises and especially those settlements which offer sustainable development opportunities such as Harbury. 2.14.5 Table 8.5 of the HEDNA highlights the income gap between private renting and buying. Table 8.45 of the HEDNA identifies a total need for affordable housing (rented and affordable home ownership) of 547 dwellings per annum in Stratford on Avon and 830 dwellings per annum in Warwick. Affordable housing delivery is therefore a key challenge for the South Warwickshire Local Plan and the best way to significantly increase the supply of affordable housing is to ensure that sufficient deliverable and developable sites are allocated for housing over the plan period. This should include a balanced portfolio of sites, in terms of their size and location. Over reliance on large sites (with associated lead in times and build out rates) could inhibit the ability to deliver affordable housing over the plan period. 2.14.6 Question H2.2 relates to the approach to affordable housing requirement, with the options of a single affordable housing requirement for the whole of South Warwickshire, separate affordable housing requirements for Stratford-on- Avon and Warwick Districts or a more localised approach with separate affordable housing requirements for different localities across South Warwickshire. It is noted that the existing Stratford Core Strategy has different thresholds for different areas. This approach was based on the findings of the Affordable Housing and Core Strategy Viability Assessment (March 2014) and it is suggested that this approach should therefore be replicated, unless the emerging evidence base indicates otherwise. H2-2c is therefore the preferred approach.
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2.15.1 It is important to provide accommodation for people to downsize into that is also capable of adaptation. The viability of such housing is best achieved via larger developments that can offer a dwelling and tenure mix and still remain viable, this approach also helps ensure the provision of mixed communities.
2.17.1 The approach to meeting needs to 2031 is supported. The scale and shortfall of future needs arising from Birmingham (78,415 to 2041) and the Black Country to 2050 is likely to be significant and will clearly need co-operation across authorities within the housing market area (and possibly further afield), including agreement on the scale of need and the basis for apportioning this to local authorities.
2.17.3 This question seems oddly framed since there is no provision currently in place to ‘require’ the authorities to meet shortfalls from outside of South Warwickshire. 2.17.4 As noted above, the I&O document recognises the need to consider un-met needs from neighbouring authorities. The timetable for the Joint Local Plan indicates that the Plan would be submitted by June 2025 and adopted by December 2025. It is therefore likely that the Local Plan will be examined under existing legal requirements (including the duty to co-operate). This highlights the need to ensure that any contribution to un-met needs arising from outside the district that the Councils agree to is incorporated in future iterations of the Local Plan. As the duty to cooperate relates to the preparation of the plan it cannot be rectified post-submission, so if the Inspector finds that the duty has not been complied with, they will recommend that the local plan is not adopted and the examination will not proceed any further (Planning Practice Guidance Paragraph: 031 Reference ID: 61-031-20190315). 2.17.5 The duty to co-operate therefore provides the mechanism for agreeing any arrangements but such arrangements would need to be agreed by the authors of the plan and relevant parties prior to the SWLP being submitted. An inspector could not amend the plan once it is submitted because any issues relating to the duty to co-operate cannot be rectified post submission. In terms of meeting any identified need it is suggested that the SWLP identifies specific sites that are suitably located to help meet needs arising from outside the district – with other sites allocated to meet needs arising from within the districts. The Green Belt represents a significant constraint. Options for accommodating sustainable development outside of the Green Belt should be considered before locations within the Green Belt are considered, consistent with Paragraph 141 of the NPPF.
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2.13 Housing Need (H1.1) 2.13.1 Paragraph 61 of the NPPF notes 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 – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.” 2.13.2 The NPPF mandates the use of the 2014 subnational household projections (SNHP) in the Standard Method. The Coventry & Warwickshire Housing & Economic Development Needs Assessment (HEDNA) sets out the rationale for deviating from this approach, because of historic overestimation of the population of Coventry. The HEDNA adopts a trend-based projection and this approach is supported. 2.16 Minimum Space Standards (H3) 2.16.1 H3a and H3b relate to the provision of minimum space standards. The minimum space standards have applied to permitted development since September 2020. The requirement for all development to meet the minimum space standards is supported (H3b). 2.16.2 H3c suggests including a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. This approach is supported but any requirement would need to be evidenced based and subject to viability testing. 2.18 Custom built housing (H5) 2.18.1 Question H5 explores options relating to the provision of sites for self-build and custom homes (H5a - identify specific sites, H5b - require large sites to provide a proportion of custom housing, H5c – case by case basis). The requirement for larger sites to include a proportion of self build and custom housing on site will help ensure that sites for self build and custom build homes are brought forward with the necessary infrastructure in place, H5b is therefore supported. 2.19 Delivering Homes in South Warwickshire (H7) From a review of the I&O document and supporting evidence base the key points in relation to delivering homes in Warwickshire are: The SWLP must avoid being too strategic and focussing on strategic allocations – it must provide a spatial strategy with sufficient granularity for the whole of the plan area. It must provide a balanced portfolio of sites – ensuring a continuous supply of deliverable and developable sites over the plan period (avoiding over reliance on strategic sites that may not start delivering housing until the second quarter of the plan period). It should identify a range of housing sites that will meet future needs, including affordable housing – rather than relying on LP2s and NDPs. The evidence base should be reviewed to ensure a consistent approach to the identification of sustainable locations for growth across the plan area, this includes revisiting the settlement hierarchy.
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2.20 Climate Change Mitigation and New Buildings (C4.1 and C4.2) 2.20.1 WPDG supports a phased approach to net zero carbon for new buildings, setting a future date by which all new development will need to achieve net zero standards. This could be 2030 in line with the ambitions of the South Warwickshire Climate Action Plan. In the intervening period new development will need to meet building regulation standards. 2.20.2 Question C4.2 asks what scale of development the requirement should apply to. It is suggested that this is applied to major developments as defined in Annex 2 of the NPPF (subject to viability testing).
