Issue and Options 2023

Yes

Nothing chosen

Q-S8.2: : For sites coming forward as part of this threshold approach, what do you think would be an appropriate size limit for individual sites? Threshold of 20 dwellings Whichever growth strategy is pursued, and these representations do not seek to comment on the options presented, as the Issues & Options paper acknowledges, with a plan period running to 2050, omitting Stratford and Warwick’s rural hinterland in respect of housing growth options will fail the rural community; both economically and socially. It will also fail to ensure the health and well-being of communities in several ways. It is appreciated that South Warwickshire’s main towns and larger villages provide a wider range of services and facilities than the smaller villages and hamlets across the rural area. They can more readily meet the day to day needs of communities and serve neighbouring areas in providing accessible services and employment opportunities. However, sustainability is more than the ability to access services, facilities and employment by means other than the private car. This is particularly so given the increasing number of the working age population working from home, especially in rural areas – a point acknowledged in the Coventry & Warwickshire Housing & Economic Development Needs Assessment (HEDNA) – paragraph 4.41. Paragraph 85 of the NPPF recognises that rural areas are not static places, stating that, “Planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. In these circumstances it will be important to ensure that development is sensitive to its surroundings, does not have an unacceptable impact on local roads and exploits any opportunities to make a location more sustainable (for example by improving the scope for access on foot, by cycling or by public transport). The use of previously developed land, and sites that are physically well-related to existing settlements, should be encouraged where suitable opportunities exist.” Paragraph 78 of the NPPF also states that, “In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs.” The Country Lane and Business Association (CLA) report, “Sustainable Communities: the role of housing in strengthening the rural economy” was published in 2022. The report highlights the issues rural communities face in comparison to their urban counterparts - "a population ageing at a faster rate, proportionally fewer affordable homes, pressure on house prices from second home ownership and a larger gap between house prices and wages.” The report, in referencing member surveys and statistics from DEFRA, CPRE, and the Affordable Housing Commission, writes that, “The pricing out of the younger generation has resulted in rural areas ageing faster than other parts of the country, yet with the least provision of suitable homes for the elderly. The loss of young people and full-time occupiers in rural areas continues to contribute to the closure and loss of key services and amenities, which will only be exacerbated by the pandemic. For rural areas to thrive, there needs to be an adequate, available and diverse supply of homes, which includes different tenure types of varying sizes. The existing lack of homes in rural areas prevents families to continue living in their community, key workers to be based near to their places of work and the elderly to downsize.” The demand for the younger generation to move to rural areas has likely increased as a consequence of the pandemic and the acceptance (and positive encouragement by many businesses) of home working but it exists. The HEDNA identifies this at paragraph 4.37. “More generally the market is varied with people of all ages renting within the authority however there is a definite trend of younger single people, couples and young families looking to rent within the area. Most of those seeking rental properties in Warwickshire live locally or used to live locally and are looking to move back into the area, looking for a return to a more rural life.” It’s pertinent that the HEDNA notes this demographic look to rent, raising the question of affordability and accessibility to the type and tenures of housing available for sale within rural areas. The older populations in South Warwickshire are also comparatively high compared to nearby authorities (Coventry, North Warks, Nuneaton & Bedworth and Rugby). The figure below is taken from the HEDNA and shows Stratford having the highest proportion of people aged 65 and over. Warwick sees the highest proportion aged 16-64 (outside Coventry) which the report notes is linked to its student population. When that transient student population is taken into account, the proportion aged 65 and over increases. The HEDNA doesn’t provide a detailed analysis of the rural housing situation in South Warwickshire. The lack of a detailed study examining the issues for South Warwickshire’s rural communities is, it is considered, unhelpful in fully understanding what benefits would be derived by a chosen growth strategy. It is however clear that the rural area, and its smaller villages and hamlets are places that cannot afford to stagnate. Like their larger neighbours, they need to remain dynamic and vibrant places that afford residents the ability to move into appropriate and accessible housing without having to move away or be prevented from moving in. Issue S8 recognises this in explaining how, “Small scale development can play a role in preserving the vitality of smaller settlements, for example by providing additional pupils for the local school, new customers for local facilities, and by helping ensure people can stay living locally when their accommodation needs change.” Issue S8 states that it is expected that limited infill within settlement boundaries will be permitted in the SWLP and this would be seen as “the baseline position”. This is supported but it will not, alone, be sufficient to address the rural housing issues. It is questionable how much housing can be delivered within the rural settlements by way of infill without cramming developments in to otherwise more spacious, low density environments. Moreover, and more importantly, developments would tend to be very small scale and below a threshold in delivering affordable housing, housing for older persons or the accessible housing for younger people and families to access. For that reason, there has to be an alternative strategy and thus full support is given to an alternative approach which would allow for more development at rural settlements. To achieve an appropriate and balanced housing type, tenure and mix, it will necessitate housing outside but adjacent to defined settlement boundaries. This approach would reflect policies in North Warwickshire’s new Local Plan (2021). Policy LP2 (see below) allows for, or rather does not prohibit, development outside settlement boundaries. Guiding policies and “planning judgement” are to be applied on sites with a wider planning balance given to a particular proposal, the benefits it delivers to any given location and any harm that might be derived. It allows a more fluid decision making exercise which provides for the local communities whilst affording protection over disproportionate growth the settlement it adjoins. With SWLP having a plan period to 2050, this approach would be helpful to Stratford and Warwick in ensuring their villages provide the type of housing to meet the full needs of their population. The Examination Inspector’s final report into the North Warwickshire Local Plan provides useful context to this policy. “90. However, as submitted, Plan policy LP2 does not recognise the flexibility encouraged in the NPPF2012 and in the PPG towards housing provision beneficial to ‘rural communities’. Despite its proximity to several more populous areas, much of the Borough is rural in character and comprises small settlements dotted about the landscape. Furthermore the PPG sets out how all settlements can play a role in delivering sustainable development. It guides that ‘blanket policies’ restricting development in some settlements, or preventing their expansion, should generally be avoided. 91. Similarly, with reference to NPPF2012 paragraph 158, as submitted Plan policy LP2 is based on ageing evidence as opposed to the USSA (an updated assessment of the availability of services and facilities settlement by settlement). By consequence the restrictive approach to enabling development only within established settlement boundaries defined pursuant to policy LP2 is inconsistent with national policy. It would also undercut Plan policy LP8, which accords in-principle support to windfall development of 60 dwellings per annum (‘dpa’). An uplift in housing delivery in the Borough over recent years has, in large part, resulted from permitting development outside of settlement boundaries.” Whilst the inspector references NPPF2012, it is not considered the latest NPPF or PPG differ so greater so as to represent afundamental departure from this approach. Moreover, South Warwickshire has a similar settlement pattern albeit arguably to a greater extent. That is to say that it too is “rural in character and comprises small settlements dotted about the landscape.” Further viability work will be needed on the threshold to ensure that sites are deliverablein a manner that delivers the homes that are needed. That will include some market housing, including “aspirational housing”, but will be concentrated on homes for the ageing population, those in housing need (affordable) and accessible market housing to younger people and families wish to stay in, or move to, the rural area. If a threshold is fixed with no flexibility there is a possibility that sites are brought forward at artificially low numbers to avoid a disproportionately high (and unviable) number of affordable homes. The approach set out above, Policy LP2 (North Warwickshire Local Plan) provides this flexibility. A more nuanced approach that allows communities, councillors, and officers to better weigh the benefits. A scheme of 15-20 houses for example might deliver a wider range of housing and be able to provide other local community benefits, contributing perhaps to a play area or improved village facilities It is understood that some settlements, hamlets with only a handful of homes, are unlikely to provide the basis for growth. Local Service Villages and others that provide gravity for growth should however benefit from modest and proportionate growth, particularly with such a long plan period. It is therefore submitted that a threshold of 20 homes in these villages would provide the flexibility whilst affording protection to character and the social cohesion of settlements. In setting a threshold at this number, it would encourage better design and quality, a wider range of housing, including bungalows, and would deliver more affordable homes in the rural areas at quantities that would more likely be attractive to Registered Providers (noting that RPs tend to struggle to manage and maintain stock if they’re in small numbers dotted across a wide area). In setting a threshold at 20, protection to settlement and landscape character can still be maintained. Like in North Warwickshire, proposals would be considered “on their merits”with a planning balance applied. Without allowing for modest growth on the edges of villages, and relying on infill only, there is a genuine risk of stifling rural communities. Preventing older people downsize, younger people and families stay in their communities or move their, and those with housing needs to access the accommodation they need in the places they have a social connection with. It will also limit the ability for wider benefits of development to be passed on to communities by way of planning obligations. In giving this further consideration as the plan progresses, it might be advisable to review whether considering broadband availability as part of the sustainability appraisal would be helpful; particularly in light of the increased and ‘here to stay’ home working model.