Issue and Options 2023
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New searchQ-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? and Q-S4.2: Please add any comments you wish to make about the settlement analysis, indicating clearly which element of the assessment and which settlement(s) you are commenting on (Growth of existing settlements) Bellway agrees that existing settlements should be used as part of the overall strategy. These settlements have existing infrastructure which make them more sustainable, accessible and likely to deliver dwellings more quickly in the short-medium term. However, Bellway consider that the SWLP should include a revised settlement hierarchy which combines both LPAs’ existing hierarchies and reassess them to ensure that all settlements included in each tier are equally sustainable and less constrained. Some of the settlements considered to be the most sustainable in Warwick District offer less services and facilities then settlements in ‘lower’ tiers’ in Stratford District, such as Long Itchington. Additionally, Long Itchington is one of the few sustainable rural settlements which is not constrained by Green Belt, AONB or a Special Landscape Area, therefore, it should be identified as one of the settlements to target more housing growth to. Bellway supports the inclusion of Long Itchington within the Settlement Analysis document (January 2023). Appendix 3 includes the detailed assessment of Long Itchington. Bellway is supportive of their sites (SHLAA reference Long.9 and Long.18 being identified as some of the best connected sites adjacent to Long Itchington and the shops, services and facilities the settlement provides. Should the sites be allocated then their accessibility can be further improved through new pedestrian and cycle connections between the site and wider settlement. Bellway’s land to the south of the canal (Long. 21) scored slightly lower than Long.9 and Long.8 for its accessibility. Should the site be allocated, then Bellway consider that pedestrian and cycle links could be enhanced between the site and Long Itchington. The summary of page 6 of Appendix 3 states that areas ‘14’ and ‘15’ to the east of Long Itchington are within 800m of healthcare. It is unclear where this healthcare provision is and consider this should be reviewed.
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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? Yes - The NPPF (paragraph 61) identifies that in order to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method, unless exceptional circumstances justify the use of an alternative approach. Such an alternative approach should reflect current and future demographic trends. It is acknowledged that the ONS has highlighted that the 2014-based household projections gave rise to inconsistencies with the resultant housing need figure for Coventry. The Councils are in a Housing Market Area (HMA) with Coventry. In this context, the SWLP process provides an opportunity to consider what the need for Stratford on Avon and Warwick District Councils might be if more up to date household formation figures are taken into account within the HMA. It is understood that the approach followed through the HEDNA seeks to achieve this. Whilst the output from the HEDNA results in a slight lowering of the overall HMA need on a dwelling per annum basis, it is noted that the trend-based figures identified for Warwick (675 dwellings to 811 dwelling per annum) and Stratford-on Avon Districts (564 dwellings to 868 dwellings per annum) represent an increase over and above the minimum standard method based equivalents. National policy sets out an objective to significantly boost the supply of homes (NPPF paragraph 60). It is therefore considered to be a sensible and robust approach for the SWLP to be planning for, and identifying allocations to meet, this higher minimum figure in order to ensure that there is a sufficient supply of homes coming forward in this area. It is important to note that once the minimum housing need is established, national guidance states that assessing housing need is just “the first step in the process of deciding how many homes need to be planned for. It should be undertaken separately from assessing land availability, establishing a housing requirement figure and preparing policies to address this such as site allocations” (Planning Practice Guidance (‘PPG’) Reference ID: 2a-001-20190220). The standard method identifies “a minimum annual housing need figure” and “does not produce a housing requirement figure” (PPG Reference ID: 2a-002-20190220). The housing requirement figure must take into consideration any economic aspirations and the significant housing needs arising from the Greater Birmingham and Black Country HMA as well as the Coventry and Warwickshire HMA. In order to be positively prepared (NPPF paragraph 35), we expect that the SWLP should make a contribution to both of these HMA shortfalls and any proposed contribution should be supported by reasonable evidence and justification for how the figure has been calculated. QH2-2 select an affordable housing option for South Warwickshire No preferred option - Bellway considers that further information on market dynamics and demand within South Warwickshire should be taken into consideration when setting an affordable housing approach. There is not considered to be sufficient information available in the public domain at present to be able to provide a firm answer to this question. Further evidence needs to be made available, notably with respect to viability. Q-H3: Please select all options which are appropriate for South Warwickshire Bellway supports option H3d: None of these – do not set specific space standards. Bellway consider that space standards should be set by national guidance and Building Regulations and agreed on a site by site basis depending on the proposed scheme. Should the SWLP seek to impose specific standards then these will need to be justified. In relation to the NDSS, the PPG (Paragraph: 020 Reference ID: 56-020-20150327) identifies that LPAs need to take account of need, viability and timing. In relation to the M4(2) and M4(3) standards, the PPG (Paragraph:007 Reference ID: 56-007-20150327) states that there is a need for LPAs to give regard to: the likely future need for housing for older and disabled people (including wheelchair user dwellings); size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes); the accessibility and adaptability of existing housing stock; how needs vary across different housing tenures; and the overall impact on viability. Q-H5: Please select all options which are appropriate for South Warwickshire (Self and Custom Build) Bellway support Option H5c: Rely on a case-by-case approach whereby planning applications for self and custom build homes will be assessed against a range of criteria to determine their suitability. The requirement for custom and self-build housing plots needs to be determined on a case by case basis. The very nature of self and custom build housing means that it is difficult to plan for precise locations of delivery. Such requirements should be based on local evidence such as the self and custom build register and local eligibility test (See PPG Reference: Paragraph: 025 Reference ID: 57-025-20210508).
The need for a greater focus on affordability, tenure type, and mix of housing to be delivered in the South Warwickshire is an important aspect of delivering sustainable communities. The supply of affordable housing, and the affordability of housing in general, is also influenced by the overall supply of housing coming forward. The SWLP should therefore be seeking to plan for the delivery of more than the minimum number of homes identified by the HEDNA to assist with this. Consideration of site viability, particularly in regards to the number of brownfield sites or sites required to deliver a significant amount of infrastructure, will also be important to ensure sites are delivering an appropriate level of affordable housing.
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Specific sites should be allocated to deliver specialist homes for older people. This will ensure that there is a sufficient supply of suitable dwellings in the right places being delivered across the plan period.
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Q-H4-1: Do you agree with the approach of contributing to meeting the Birmingham and Black Country HMA shortfall to 2031 on the identified sites in Stratford-on-Avon District? No Bellway consider that a review of sites available should be undertaken. Sites allocated within the Site Allocations Plan (which is not yet adopted) should be considered separately to the SWLP and any proposed retention of existing allocations with no planning permission should be reviewed and confirmed if they are still deliverable. Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan Bellway consider that the SWLP should be accommodating growth to meet the housing shortfall arising from the Greater Birmingham and Black Country HMA. There is an identified shortfall of circa 28,000 dwellings across the Black Country up to 2039 and circa 78,000 dwellings from Birmingham up to 2042 which is considered to be significant. The NPPF (paragraph 35) requires plans to accommodate unmet need from neighbouring areas where it is practical to do so. Given the close proximity of the SWLP area to the Greater Birmingham HMA, Bellway consider that in order to be found sound, the SWLP should include a contribution towards the significant shortfall.
Bellway considers that specific sites should be allocated to meet the needs of the HMA. However, as said elsewhere in their response, Bellway considers that the SWLP should identify housing growth adjacent to existing settlements outside of the Green Belt, such as Long Itchington, in the first instance
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