Issue and Options 2023

5. The NPPF Paragraph 32 states: “Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed the relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, where possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).’ 6. It is noted that the SA in the conclusion for the Sustainability Appraisal states, at paragraph 7.15.11: “High level assessment of Spatial Growth Options that are not all distinct from each other, with the exception of Option 5, means that sustainability performance can only be evaluated with several caveats. These include the fact that detailed locational information is not available and the ability to identify effects with precision is challenging. The scores in Table 7.1 are strictly a guide and do not represent a diagnostic analysis. Mitigation has not been factored into the performance of the Growth Options since it is best worked up once more detailed locational information is available.” [emphasis added] 7. As the Issues and Options are very high level at this stage, it is hard to properly comment on the SA which by its own admission is caveated and no mitigation has not been considered.

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10. Yes, we consider that growth of some of South Warwickshire’s existing settlements should be part of the overall strategy. 11. South Warwickshire has a dispersed settlement pattern (as set out in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy) and is home to a significant number of existing settlements of varying sizes. The explanatory text under Issue S4 sets out that there are nine towns (Alcester, Henley-in-Arden, Kenilworth, Royal Leamington Spa, Shipston-on-Stour, Southam, Stratford-upon-Avon, Warwick and Whitnash), at least 82 villages and hundreds of hamlets. 12. Issue S4 sets out that the South Warwickshire Local Plan will seek to maximise the capacity of its existing urban areas in order to meet development needs to 2050. However, in deciding upon the best distribution strategy for new development within South Warwickshire, it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements (of all categories). 13. Ettington is categorised as a ‘Category 3 Local Service Village in Policy CS.15 of the adopted Stratford-on-Avon Core Strategy. 14. Ettington offers a large range of services and facilities, including a shop, post office, community centre adjacent to a children’s playground, MUGA and playing fields, pub, hotel and conference centre church, and a primary school. The nearest bus stop is on Banbury Road, 5 minutes from the site. 15. Land at Old Warwick Road, Ettington located immediately adjoins the built-up area boundary of Ettington and existing residential development to the north and east. The promotion site would be well connected to the built-up area of and would constitute sustainable development. 16. Given the pressing need for additional housing within the Stratford-on-Avon District, Ettington is clearly a sustainable location to accommodate additional housing growth. The Site has been carefully considered to enable a comprehensive planned development to be achieved to deliver new housing (market and affordable) which is well-located in relation to the town and will enhance its vitality in line with national planning policy. There is a need to allocate small sites as well as large site as they play a role in delivering housing quickly and contribute to the vitality and viability of existing villages. Accordingly, it is considered that the Site should be allocated as a residential site within the South Warwickshire Local Plan.

17. The settlement analysis does not consider all settlements in the Districts, it should also consider ‘networks of villages’ which can provide local amenities for new residential development. The settlement analysis should therefore be updated to include all settlements in the District, to do so would be in line with Paragraph 79 of the NPPG (2021) which states that: ‘To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.’

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Appropriate strategy

Yes

A higher limit is appropriate

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30. All settlement boundaries should be reviewed as part of the SWLP, this will ensure consistencies of approach between Stratford-on-Avon and Warwick Districts, out of date boundaries can be reviewed which and there could be a subsequent increase in housing delivery.

Yes

31. It is important to emphasise that the Planning Practice Guidance is clear in its approach that the ‘standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area’ (Paragraph 010; Reference ID: 2a-010-20190220). The draft South Warwickshire Local Plan should therefore reflect that the proposed ‘Housing Need’ figure is only the starting point and additional housing may be required to facilitate economic growth or the delivery of affordable housing. 32. For example, an appeal decision for up to 800 dwellings at the Former North Warwickshire Golf Club (Appeal Ref. APP/P4605/W/18/3192918 – a decision which was ‘called-in’ by the Secretary of State) highlighted the chronic shortfall in affordable housing which has come forward within Birmingham City since 2011. Paragraph 14.108 of the Inspector’s Report states that only 2,757 new affordable homes were provided in the City over the first 6 years of the Plan period. This represents less than half of the target provision and a net increase in only 151 affordable homes if Right to Buy sales are taken into account. The Inspector goes on to state that given the heavy reliance in the five year housing land supply on City Centre apartment schemes, it is difficult to see how that trend can be reversed in the short to medium term (paragraph 14.109). 33. Whilst it is noted that Birmingham City Council does not form one of South Warwickshire’s Authorities, it highlights recent difficulties with delivering homes on brownfield sites. The high proportion of flatted developments, coupled with the increased likelihood of viability issues, has led to a chronic shortfall in the provision of affordable homes. Should the South Warwickshire Authorities follow a similar approach, it may therefore be necessary to increase the Housing Requirement, in accordance with national guidance, to improve affordability. 34. We note that work is ongoing to confirm how much housing can be provided from various sources, both in terms of existing and future capacity to help meet the need. This includes an understanding what has already been built, has planning permission or is identified for development in existing Plans and the capacity of small ‘windfall’ sites. 35. Overall, we support a trend-based approach in principle. However, it is considered that any shortfall in housing supply should be regarded as a minimum given that it is currently calculated against an untested housing target that may require an upward adjustment to take account of affordability.

36. The Local Plan needs to address the key strategic issue of housing and affordability. The main approach of dealing with this issue is by facilitating housing growth to ensure a balance of demand and supply which will be the only means of driving housing prices down. The allocation of sites will also facilitate the delivery of affordable housing. Since the adoption of the Core Strategy, national policy has developed following first the Housing White Paper, Fixing the Broken Housing Market (February 2017), and then latterly the Revised NPPF (2021), which build on that original document. 37. The key messages of national policy have therefore been ensuring faster delivery, diversification of supply and consequent strong support for small and medium housebuilders and smaller sites in sustainable rural locations. NPPF paragraph 20a emphasises the importance of a comprehensive strategy in respect of housing delivery, which in turn reflects section 19(1B)-(1C) of the PCPA 2004. 38. NPPF paragraph 60 continues to emphasise the importance of boosting supply. This is reinforced by NPPF paragraphs 74 to 77, which collectively set in place a requirement to ensure a healthy, rolling 5 year housing land supply. 39. NPPF paragraph 69 reflects the need to ensure a range of small and medium sized sites, as these can be built out quickly on the importance of choice and competition and paragraphs NPPF 78-79 in respect of delivering supply at villages). These are all key components of soundness under NPPF paragraph 35. 40. A number of these principles are reflected in the most recent Housing White Paper: Planning for the Future (August 2020) and Changes to the Current Planning System (August 2020), which represent a clear direction of travel for national policy in the early part of 2021, and thus during the examination of the new Local Plan.

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