Issue and Options 2023
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New searchParagraph 61 of the Framework advises that in order to determine the minimum number of homes needed, strategic policies should be informed by local housing needs assessment, conducted using the Standard Method in National Planning Practice Guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing needs figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for. We note that the Standard Method housing figures for Stratford-on-Avon and Warwick Districts are 564dpa and 675dpa respectively. The trend based projection in the HEDNA suggests that 868 dpa are required in Stratford-on-Avon and 811 dpa in Warwick District respectively. As the HEDNA figure is above the Standard Method housing requirement we have no particular concerns with the HEDNA methodology departing from the Standard Method as the level of development proposed would ensure that the minimum Standard Method housing requirement is exceeded. We note that this is not the case in the Coventry and Warwickshire plan area as a whole, where the total housing requirement in the HEDNA is less than the Standard Method requirement. This is principally due to the fact that the HEDNA suggests that the housing needs of Coventry is significantly below the Standard Method figure. We restrict our comments to the Stratford-on-Avon and Warwick sections of the HEDNA only and do not seek to comment on the Coventry figure at this stage given that it relates to a different plan area. In terms of the approach of the HEDNA, it is noted that Table 8.13 – Estimate Need for Social/Affordable Rented Housing by Local Authority, identifies a net need for 419 affordable dwellings per annum in Stratford-on-Avon and 582 affordable dwellings per annum in Warwick District. This equates to 67% and 52% of the identified overall housing requirement respectively for the two authorities. The PPG advises at paragraph 2a-024 that the total affordable housing need can be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probable percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the strategic plan may need to be considered, if it would help to deliver the required number of affordable homes. In all likelihood, the principal way affordable housing will be delivered during the course of the plan period will be through planning obligations associated with residential developments. We are concerned that there will be a significant shortfall of affordable housing provision during the course of the plan period to meet their identified need, as is not realistic to expect housing allocations to deliver 67% or 52% affordable housing. There should, therefore, be consideration to uplift the housing requirement to ensure that an appropriate amount of affordable housing is met. This is particularly important given that the plan advises that the issue of housing under-supply is “specifically and crucially . . . . an issue to do with the lack of affordable housing supply”. There are other documents that support an uplift to the SWDP’s housing requirement to assist with affordable housing delivery. The Stratford-upon-Avon District Housing Strategy (2021 – 2026) sets out three aims including supporting communities and building sustainable and affordable homes. The Warwick District Council Housing Strategy (2014 – 17) sets an objective of meeting the need for housing across the district. The Draft Plan advises at page 98 that there is an issue with affordability, with individuals with lower paid jobs being unable to afford to live within the plan area and having to commute from Coventry. A lack of housing land supply will increase house prices making this issue more profound. The draft Plan also recognises that providing new homes will support the local economy, through the creation of construction jobs and help ensure that existing facilities and services remain open by increasing footfall. All current evidence suggests that the housing requirement should be adjusted upwards from the HEDNA figure to support affordable housing delivery. This would support the Social Role of sustainable development identified by the NPPF, by ensuring that a sufficient number and range of homes are provided to meet the needs of present and future generations.
In our view the most appropriate way of “significantly increasing” the overall supply of affordable housing across South Warwickshire is to have a housing requirement that is sufficient to support the delivery of much needed affordable housing through planning obligations. This matter is addressed in response to Q-H1-1 above. In terms of the three strategies proposed, we have no particular preference between a plan wide affordable housing requirement, a separate affordable housing requirement for Stratford-upon-Avon and Warwick districts or a localised approach. We would, however, suggest that the simplest approach would be to have a plan wide figure. As the Draft Plan points out, the extent of administrative boundaries is unlikely to be the principal factor that people consider when looking for affordable properties. It is, however, acknowledged that a universal affordable housing policy will not address the significant variance in affordability across the plan area, which can only be addressed by a localised approach.
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We support the recognition that the SWLP will have a role to play in meeting the housing shortfall arising from the Black Country and Birmingham. The Draft Plan acknowledges that the Issues and Options Birmingham Local Plan identifies a housing shortfall of 78,415 dwellings. However, no reference is made to the extent of the housing shortfall arising from the Black Country. Following the abandonment of the Black Country Plan, the four Black Country authorities are producing individual Local Plans. However, as the Preferred Options version of the Black Country Plan included a housing requirement shortfall figure based upon the Standard Method, the identified housing shortfall in the Preferred Options version of the plan can be considered a credible starting point for the consideration of the potential housing shortfall. The Preferred Options Black Country Plan identifies a housing shortfall of 28,239 dwellings. As a consequence, the total housing shortfall arising from the conurbation is 106,653 dwellings. We note that the Sustainability Appraisal suggests that an additional 5,000 to 10,000 homes to support the growth requirements of the Birmingham and Black Country conurbation. This is the equivalent to less than 5% to 10% of the total housing shortfall. It is entirely possible that a greater level of housing growth will be required in the SWLP plan area. In terms of the Coventry shortfall, whilst the HEDNA suggests that the housing requirement for Coventry should be significantly below the Standard Method housing requirement for the city this has yet to be tested. It is a realistic proposition that it may be established that Coventry should seek to deliver a Standard Method compliant housing figure. The SWLP, therefore, consider options for delivering additional housing to support for the growth of Coventry.
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Q-H3a – Should the National Space Standards be applied? The emerging plan correctly recognises that Nationally Described Space Standards should not automatically be included within emerging plans. Footnote 49 of the NPPF advises that Nationally Described Space Standards can only be applied through policies where the need can be “justified”. The PPG provides guidance on the evidence that is required to “justify” space standards. The Draft Plan advises that at this point in the plan process the Councils have not gathered evidence on the need for and benefit of, including Locally Described Space Standards. There is, therefore, currently no evidence to support the inclusion of such a policy. Should this evidence be produced we reserve the right to comment further. In terms of introduction of M4(2) and M4(3) standards, these are building regulation requirements. It is highly likely that new building regulations will be put in place by the time the SWLP is adopted. There should not be dual regulatory control. Q-H5 – Custom built housing The most appropriate way of delivering custom built housing is Option H5a – Identifying a range of specific sites within or on the edge of settlements to deliver custom and self-build housing. These locations are mostly likely to appeal to self-builders. In Spitfire’s experience, there is very little interest in self-build and custom build plots on large scale market developments. Requiring a set proportion of larger sites to deliver self-build and custom build houses is unlikely to meet the demand for these properties. Requiring larger sites to provide self built plots creates a series of problematic development control matters. As the details of self-build houses will not necessarily be known at the application stage, it means that full planning applications cannot be submitted for schemes that require self build plots. This results in the creation of more complex “hybrid” planning applications.
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Q-C2 – Please select the energy system approach which you believe to be the most appropriate for South Warwickshire. It is our view that the SWLP should have a policy to encourage the consideration of decentralised energy systems, however, there should not be a threshold above which such systems are expected. Decentralised energy systems can be costly and not always practical. There is currently a lack of evidence to demonstrate that the 2,500 threshold suggested for the use of decentralised energy systems is achievable and will not adversely affect viability. Instead, the SWLP should include a policy advising that the provision of decentralised energy systems would be considered a significant benefit in the planning balance during the course of determining planning applications.
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Q-C4.1 – Please select the building regulations requirement option that is appropriate for South Warwickshire Option C4.1a is the most appropriate, the SWLP should not include a policy setting higher standards on renewable energy that the building regulations. The SWLP is being prepared to cover the period up to 2050. During the course of the plan period building regulations are likely to change. It is appreciated that it is highly likely that there will be at least one Local Plan review within the next 5 to 10 years, however, by the time a replacement Local Plan is in place updated building regulations could have been produced resulting in an out of date policy in the plan. In addition, any additional standards would need to be fully factored into any viability assessment work produced by the Council’s support of preparation of the SWLP. The additional costs associated with the increased building relation standards could have significant viability issues, potentially making some brownfield sites undeliverable, or causing viability issues that reduce the quantum of affordable housing provided. Whilst we fully support the concept of delivering energy efficient buildings and working towards net zero carbon buildings, the implications of making this mandatory in the plan need to be fully understood in the context of viability.
