Issue and Options 2023

6.13 The standard methodology includes an affordability adjustment. However, the national planning practice guidance is clear that the affordability adjustment applied to the standard methodology formula is not a solution to problems of affordability as outlined below. “The affordability adjustment is applied in order to ensure that the standard method for assessing local housing need responds to price signals and is consistent with the policy objective of significantly boosting the supply of homes. The specific adjustment in this guidance is set at a level to ensure that minimum annual housing need starts to address the affordability of homes.” (Paragraph: 006 Reference ID: 2a-006-20190220) 6.14 The Plan confirms that, across the Plan area, the median house price to income ratio is over 10.5. For Warwick District, the affordable housing need identified in the Table 10 of the Plan is some 839 dwellings per annum. When this is compared to the overall housing need for the District, stated at Table 9 of the Plan, affordable housing need would equate to 104% of identified housing need using the trend-based projections. The situation is similar in Stratford-on-Avon District. 6.15 For Coventry, the affordable housing need identified in the Table 8.13 of the HEDNA is some 1,887 dwellings per annum. When this is compared to the overall housing need for the District, 1,964 dwellings per annum, affordable housing need would equate to 96% of the total housing need using the trend-based projections. 6.16 Given the above, applying the standard method or trend-based approach will barely scratch the surface of addressing affordability and accordingly, it is suggested that an affordability adjustment should be applied to the identified housing need in order to address the considerable housing affordability issue across the Plan area. 6.17 Furthermore, to address Coventry’s affordability issues specific sites, i.e. Westwood Heath, should be identified to assist with meeting this need.

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6.18 Table 11 of the Plan only provides data until 2032 but the Plan itself covers a long period. Therefore, before an approach is determined, the level of need should be fully evidenced over the entire Plan period as this will have a direct effect on the required strategy. 6.19 Nevertheless, in meeting any identified need for specialist housing for older people, large scale sites are able to cater for a wide variety of needs and therefore where evidenced, such schemes could accommodate these needs in a proportionate manner.

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6.1 This approach was determined through the Stratford Site Allocations Plan (“SAP") which is still in draft format and yet to receive the scrutiny of a Local Plan Inspector, as such only limited weight can be given to this strategy at present. 6.2 In any event, the sites identified in Stratford-on-Avon District are to address needs until 2031 based on unmet needs that existed at the time. The SWLP covers a period well beyond this and Birmingham City Council has also commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a staggering shortfall in housing of 78,415 homes, with additional shortfalls potentially identified from the Black Country authorities. 6.3 Birmingham City Council has commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a staggering shortfall in housing of 78,415 homes, with additional shortfalls potentially identified from the Black Country authorities. 6.4 There remains to be an agreed and co-ordinated approach to addressing unmet needs around Birmingham so the SWLP should consider accommodating some needs having regard to, inter alia, the functional relationship between the South Warwickshire and the source of these shortfalls. It is noted that for the purposes of the SA the Councils have tested the effects of an additional 5,000 and 10,000 homes, which we support in principle. However, further engagement and agreement with neighbouring authorities is required and any level of unmet need planned to be accommodated must also be subject to a future review, pending the outcome of any wider work to comprehensively address unmet needs in the region.

6.1 It is noted that there is no specific question regarding Coventry’s potential unmet needs but given the significant affordability issues and the likely requirement for an uplift to the trend-based approach, we consider that it is likely that there will be unmet needs to be addressed in the SWLP. 6.2 Whilst the distribution of unmet needs will be a matter for the respective LPA’s to address, the identification of specific strategic sites to assist with meeting unmet needs is considered to be a robust approach as it ensures sufficient sites are actually identified to meet this need and that these are in appropriate locations. It is clear, given its relationship with Coventry, that Westwood Heath is strategically well located to assist with meeting any unmet need from the Coventry as well as assisting with addressing the unmet need from the wider region from places such as Birmingham.

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Issue H1: Providing the right number of new homes Q-H1-1: The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014-based household projections towards a trend-based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? 6.1 The NPPF 2012 introduced a radical shift in relation to the approach to meeting housing needs. This remains in the 2021 version where at paragraph 8 it outlines the three overarching objectives to securing sustainable development and paragraph 8b states that to achieve the ‘social objective’ it is necessary to “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…” 6.2 Paragraph 60 of the NPPF then 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, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.” 6.3 However, despite the additional requirements and objectives imposed by the NPPF, it is widely accepted that there is a national housing crisis due to the consistent failure to achieve the Government’s target of 300,000 homes per annum, with affordability unsurprisingly worsening across many parts of the country, year on year. Accordingly, it is vital the SWLP sets a positive framework to fully accommodate its housing needs and importantly address existing underlying issues as well. 6.4 The NPPF is clear at paragraph 61 that housing need should be calculated using the Government’s Standard Method unless there are exceptional circumstances to justify an alternative approach. The HEDNA outlines a rationale for applying a trend-based approach for which there is merit but noting the test of national policy for such an approach, it is considered that further justification is still required in this regard. However, regardless of whether the standard method is used, based on the 2014-based projections, or whether the alternative trendbased projection is used, this should still only be the starting point for determining the housing requirement for the Plan. 6.5 The Plan acknowledges that there will likely be a need to accommodate some unmet housing needs from adjoining authorities which of course represents one potential uplift (addressed in response to a separate question), but it is suggested that an affordability adjustment should also be applied. The Plan confirms that, across the Plan area, the median house price to income ratio is over 10.5. For Warwick District, the affordable housing need identified in the Table 10 of the Plan is some 839 dwellings per annum. When this is compared to the overall housing need for the District, stated at Table 9 of the Plan, affordable housing need would equate to 104% of identified housing need using the trend-based projections. The situation is similar in Stratford-on-Avon District. 6.6 Affordability is an on-going and increasing pressure which will require a proactive approach that should be rooted in increasing the housing requirement given that market led housing schemes have, and will continue, to deliver the biggest supply of affordable homes. 6.7 Regarding Coventry’s needs, as part of the trend based approach the HEDNA identifies historic issues with calculating Coventry’s needs which appear to be largely driven by how the student population has influenced demographic projections. Whilst further justification for this deviation from the standard method is still needed, when considering Coventry’s needs and the type of development that has taken place and is needed in the future it is still important that development comes forward that meets the needs of the whole population. 6.8 The 2021/21 AMR for Coventry indicated that housing delivery is ahead of the overall requirements established in the current Local Plan. However, of the total number of completions, 3,818 dwellings, it is important to note that a significant proportion of houses delivered were Purpose Built Student Accommodation (PBSA), 2,621 dwellings compared to 1,233 residential dwellings. 6.9 Focusing on the types of dwellings delivered, of the residential dwellings delivered in 2021/22, the majority (54%) were flats/apartments. 6.10 The type of housing delivery is also having implications for the level of affordable housing delivery, which has been continually declining throughout the plan period. From a peak of 39% in 2012/13 the general trend for affordable completions as a percentage of the overall number has continued to decline with only 5% in 2021/22. 6.11 This decline in affordable housing and the rate of PBSA being delivered within Coventry further confirms the importance of allocations coming forward that can provide a range of house types, including family accommodation. This is reinforced when looking at the needs for different house types within the HEDNA. The type of accommodation needed for Coventry is closely aligned with Warwick and Stratford-On-Avon Districts and show a clear need for family-sized market accommodation i.e. 3 bedroom houses (40%). 6.12 Given the finite supply of land within Coventry and the recent trends for smaller units and PBSA there is a clear need to ensure that developments that provide for a range of house types, in particular family-sized accommodation, to help meet Coventry’s needs. Westwood Heath is strategically well-located to provide for this type of accommodation as part of a sustainable community. Q- H6: Pitches and Plots for gypsies, travellers and travelling showpeople 6.1 Answer – It is considered that the SWLP should adopt a flexible approach to Gypsy and Traveller provision and this approach should utilise a combination of options H6A (identify a range of specific sites in sustainable locations) and H6C (rely on a case by case approach where applications are assessed against a range of criteria). This will ensure that locations are chosen that a suitable and attractive for Gypsy and Traveller and Travelling Showpeople which will ensure their needs are met. The provision of such sites as part of Sustainable Urban Extensions (option H6B) is not considered to be appropriate. Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire The site – Westwood Heath 6.2 CEG control 130 hectares of land on the southern edge of Coventry, adjacent to the University of Warwick’s main campus. 6.3 The site is located on the edge of the City of Coventry, the sub-regional centre. It therefore benefits from easy access to a range of services and facilities. It is not subject to any landscape designations, is located within Flood Zone 1 and does not contain any designated heritage assets. 6.4 Whilst situated in the Green Belt, circa 30 ha of this is identified as safeguarded land (to meet longer-term strategic development needs) through Policy DS21 of the WDLP. 6.5 Policy DS20 ‘Directions for Growth South of Coventry’ of the WDLP acknowledges the transformational change that could occur in the area and commits Warwick District Council (WDC) to an early partial review within five years of the date of adoption of the plan (Summer 2022). The policy is clear that this will allow the Council to address any additional evidence regarding the need and potential for development in this area and in particular to ascertain whether necessary infrastructure has become available to allow safeguarded land to be brought forward to meet local housing need, should additional housing be required. 6.6 The Coventry City Local Plan similarly safeguarded an area of land south of Westwood Heath Road (see Policy GB2) which would be released upon a review of the plan and clarity on development proposals within Warwick District. 6.7 Having regard to the above, WDC subsequently commenced preparation of a wider south of Coventry masterplan framework, which is in progress (further detail outlined below). 6.8 The site is located adjacent to and south of the Westwood Heath Road and would form a natural extension to the existing residential area. It benefits from having direct frontage along the Westwood Heath Road thus enabling a new junction to be accommodated to access the development which links into existing footways. 6.9 A number of local facilities including the Westwood Academy Secondary School, recreational pitches, a Sport and Wellness Hub, convenience food stores are in the immediate vicinity of the site. Tile Hill station (offering connections to Birmingham and London) is 1.4km away and Coventry City Centre is 6.4km and is accessible by Bus and Cycle. Local bus stops are within a comfortable walking distance from the site along within the University of Warwick’s main campus making public transport a genuine option for travel. 6.10 The site benefits from excellent pedestrian infrastructure with continuous footways on both Westwood Heath Road which can be enhanced. Similarly, the proximity to the campus will access existing cycle infrastructure and this will be integrated with the green travel corridor providing links into Coventry and across the area. This corridor also has the potential to integrate with wider connections to the HS2 interchange at Arden Cross. The site is therefore in a highly sustainable position that benefits from excellent public transport linkages. 6.11 Development in this location would provide a significant level of market and affordable housing and supporting community infrastructure. It would also help facilitate the delivery and provide financial contributions towards a green-travel corridor which would facilitate an improved southern access to The University of Warwick. These infrastructure improvements will align with the significant transport improvements already being implemented in the area, including the improvements at the A46 Stoneleigh Junction and the new crossing of the A45, which would, in its own right, deliver significant social and economic benefits locally and at the sub-regional level. Our proposals would also align with the opportunities identified by WDC through the planned preparation of a wider south of Coventry masterplan. 6.12 Given that the SWLP has a remit of exploring strategic growth opportunities, it should comprehensively consider the substantial benefits that can be delivered through large scale growth at Westwood Heath, in particular supporting the delivery of a green travel corridor, a strategic piece of infrastructure, noting that paragraph 11a of the NPPF states that plans should positively seek opportunities to meet the development needs of their area. 6.13 Having regard to the above, CEG proposes to prepare a detailed Vision Document for the site, which will be supported by a range of technical work to demonstrate how the site could successfully deliver a residential-led mixed use development on the edge of Coventry. At this stage, a ‘Conceptual Framework’ prepared by Define is provided (see Appendix 1 to these representations) to outline how development of the site could sustainably be provided. This demonstrates that the site can address site specific considerations, comprising the following; • Circa 2,500 market and affordable dwellings of a type that will make a significant contribution to specific housing needs, divided as follows: - Circa 650 within the safeguarded land; and - Circa 1,850 dwellings within wider land. • Employment/commercial development in a strategic location to offer collaboration opportunities between business and the university • Significant community infrastructure provision including a neighbourhood centre, a 2 FE primary school, sports pitches, public parkland and biodiversity parkland; • A substantial network of green infrastructure with green corridors that will provide opportunities for sustainable travel and recreation. This will build upon a local neighbourhood concept; • New movement corridors to help address existing traffic and associated environmental issues within Coventry and aligning with ongoing infrastructure improvements in the area, improving access to the University with the potential to facilitate access to the HS2 interchange at Arden Cross; • Ensuring development avoids coalescence between settlements through keeping development to the North of HS2; and • Strong connectivity to Coventry and the University of Warwick’s main campus, supporting its role as a Major Investment Site. 6.14 Overall, the proposals represent a highly sustainable option growth option that can deliver a range of substantial benefits. Wider South Coventry Masterplan 6.15 In April 2022 a report was taken to WDC Cabinet seeking approval to enable the formation of a master planning framework for land to the north and east of Kenilworth/South Coventry. A copy of the framework area is included at Appendix 2. 6.16 The Cabinet approved the recommendation of the report resulting in the formation of a working group which includes WDC, Coventry City Council, Warwickshire County Council and the University. The purpose of the working group and the masterplan (as per the Cabinet Report) is to: • To map and understand the various planned and emerging developments in the area; • To explore how to maximise community benefits including through improvements to green and blue infrastructure and connectivity; • To assist partner organisations in preparing their own masterplans for specific sites and to reflect their aspirations in the wider planning of the area ; • To understand how the climate emergencies declared by Warwick District Council, Warwickshire County Council, the West Midlands Combined Authority and the University of Warwick should inform the future planning of this area ; • To provide a focus for considering how best to engage with HS2 in terms of how this project can bring improvements to the area (including by linking with the HS2 Context Integration Study); • To provide a context for considering travel and transport improvements in the area, which should prioritise active and sustainable travel but also consider the purpose, justification and business case for the A46 Strategic Link Road; • To provide a framework and rationale for future business cases and bids to deliver transport infrastructure projects (e.g. road, VLR, South of Coventry/University of Warwick Railway Station); and • To enable, subject to wider work on growth options across South Warwickshire and any agreement within the South Warwickshire Local Plan as to the development strategy, consideration of whether, where and how this area may be suitable for further growth as part of the Local Plan. 6.17 The site is located within the framework area and as well as being capable of coming forward in isolation, could also form part of a wider growth area to the South of Coventry. The site can assist with delivering the aspirations for the masterplan area including: • Supporting the delivery of new homes and employment opportunities, should the SWLP consider this an appropriate area for growth; • Supporting the enhancement and further delivery of green and blue infrastructure; • Ensuring that the series of existing and emerging development sites are well designed and well connected in order to provide a coherent and cohesive masterplan for the area; • Contribute to low carbon and climate resilient development. • Connect new homes and key existing employment hubs such as the University and land around Coventry Airport promoting sustainable neighbourhoods and travel patterns in order to assist Councils drive towards net zero aspirations; and • Assist in the delivery and support of new strategic transport infrastructure such as Very Light rail; green travel corridors (A46 link road); cycle and footpaths; and Coventry/University of Warwick Railway Station 6.18 CEG understand that the working group have begun work on understanding the potential of the masterplan area and would welcome the opportunity to collaborate with the group in the near future.

Q-S3.2: Brownfield land Approach Option 3.2a: Prioritising brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. Paragraph 119 of the NPPF is clear that that the priority is to make effective use of land in meeting objectively assessed needs and that that this should make as much use as possible of previously developed or brownfield land. However, in stating this, it is also clear that the NPPF does not seek the use of brownfield land ahead of all other considerations and instead points to a balance when there is potential for conflict with other policies in the Framework. Brownfield land for development needs to be on the right sites, in the right location and as the Plan rightly indicates, locating development on brownfield land but in unsustainable locations can cause/or exacerbate issues in an area. In view of this, the balanced approach stated in Option S3.2a is considered the most appropriate. It is clear from the HELAA and level of growth that is needed across the plan area that a significant quantum of greenfield land will be required to accommodate development needs, such as land controlled by CEG and Mixed Farms. This is further evidenced through the Council’s Urban Capacity Study 2022, which confirms that capacity through urban sites and existing commitments is 19,950 dwellings over the plan period, leaving more than 10,000 dwellings to be accommodated on greenfield sites beyond the urban area.

Q-I2: Please select the option which is most appropriate for South Warwickshire Response - Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy: Paragraph 8a of the NPPF relates to the ‘economic’ objective of sustainable development, stating that the planning system should identify and coordinate the provision of infrastructure. In applying the presumption in favour of sustainable development for plan making, paragraph 11 outlines that all plans should “align growth and infrastructure”. Furthermore, paragraph 22 details that “Strategic policies should…anticipate and respond to longterm requirements and opportunities, such as those arising from major improvements in infrastructure”. Given the above, national policy is clear that Councils should, through plan making, positively plan for infrastructure. Having regard to the extent of the area covered by the SWLP, period it proposes to cover and likely scale of growth it will accommodate, it is considered that the SWLP should focus on strategic infrastructure to deliver the growth strategy. Furthermore, the SWLP should also consider what opportunities arise from major improvements in infrastructure, which is particularly relevant in the context of the area south of Coventry, noting the potentially transformational change that could occur in this area through infrastructure, as acknowledged in the framework masterplanning exercise commissioned for this area by WDC.

Q-S3.2: Brownfield land Approach Response- Option 3.2a: Prioritising brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area: 3.1 Paragraph 119 of the NPPF is clear that that the priority is to make effective use of land in meeting objectively assessed needs and that that this should make as much use as possible of previously developed or brownfield land. However, in stating this, it is also clear that the NPPF does not seek the use of brownfield land ahead of all other considerations and instead points to a balance when there is potential for conflict with other policies in the Framework. Brownfield land for development needs to be on the right sites, in the right location and as the Plan rightly indicates, locating development on brownfield land but in unsustainable locations can cause/or exacerbate issues in an area. 3.2 In view of this, the balanced approach stated in Option S3.2a is considered the most appropriate. In any event, it is clear from the HELAA and level of growth that is needed across the plan area that a significant quantum of greenfield land will be required to accommodate the development needs, such as land controlled by CEG. This is further evidenced through the Council’s Urban Capacity Study 2022, which confirms that capacity through urban sites and existing commitments is 19,950 dwellings over the plan period, leaving more than 10,000 dwellings to be accommodated on greenfield sites beyond the urban area. Issue S4: Growth of existing settlements Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.3 It is considered that growth of some of the existing settlement should feature as part of the overall strategy as this will help to ensure a sustainable pattern of development through aligning growth with jobs, services and facilities and infrastructure provision. Land to the South of Coventry should be included within this process. 3.4 Whilst outside of South Warwickshire, the City of Coventry, as the sub-regional centre, should be acknowledged as part of the overall strategy as indeed was the case in the formulation of the Warwick District Local Plan. Land to the South of Coventry at Westwood Heath should therefore be considered for growth for a residential led mixeduse development as part of the overall strategy within the SWLP.

Issue E1: Growing the South Warwickshire economy Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire? 5.1 Answer – Yes 5.2 The approach taken in the HEDNA is considered to provide an appropriate basis for identifying future levels of employment need. The ICENI report follows the methodology set out in National Planning Practice Guidance looking at a range of scenarios for identifying need. When planning for the longer term, up to 2050, taking a pasttrends approach is considered to be an appropriate basis for identifying future needs and is considered to be a more appropriate long-term basis than solely relying on other forecasting measures which have historically underestimated the level of need. 5.3 This will ensure the ability to positively plan for economic growth and in turn support the South Warwickshire Economy. Issue E3: Diversifying the economy Q-E3: Please select all options which are appropriate for South Warwickshire 5.4 Answer - Option E3a: Include a policy expanding on SDC’s current existing policy. 5.5 Given that the scope of the SWLP is a part 1 plan it is considered appropriate to include a policy that provides a high-level indication of employment requirements across South Warwickshire. It is not considered appropriate for this to be too detailed regarding specific sectors as there is a risk that this could frustrate the ability of newly emerging sectors to deliver economic growth and is likely to be more vulnerable to wider structural economic changes. Q-E7.1: Please select the option which is most appropriate for South Warwickshire 5.6 Answer - Option E7.1a: Include a policy directing employment to the Core Opportunity Area. 5.7 As set out through these representations the Core Opportunity Area represents an important opportunity for the South Warwickshire economy, it represents an area that combines key major investment sites including the University of Warwick Main campus and major road infrastructure aligned to the key settlements of Stratford – Upon-Avon, Warwick and Leamington. However, it is also considered that the role of Coventry should be more clearly reflected in the Core Opportunity Area diagram. 5.8 Therefore, to ensure that the SWLP sufficiently realises the potential of this area it is considered that a policy to direct employment within this area should be included however this should be more closely tied in with the role of the Major Investment Sites to ensure that the specific role of these sites is not undermined. Q-E7.2 Please select the option which is most appropriate for South Warwickshire 5.9 Answer - Option E7.2a: Include a policy relating to additional economic growth at the major investment sites. 5.10 The Major Investment Sites are clearly key economic drivers of the South Warwickshire Economy. Therefore, this should be underpinned through the inclusion of a policy that specifically directs economic growth at the major investment sites. This would allow additional commercial development to take place to help drive inward investment.