Issue and Options 2023
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New searchQ-S3.2: Please select the option which is most appropriate for South Warwickshire Option S3.2a: Prioritise 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. Dependent on the results of the urban capacity study, it could be that brownfield development forms a part of our development strategy. Brownfield sites are frequently found within towns and can therefore often accommodate a higher development density. Prioritising development on brownfield land, especially at higher densities, might reduce the need for greenfield development. However, instead of developing all brownfield sites, this option looks to prioritise brownfield redevelopment in line with the identified growth strategy, where it can be proven the site is in a sustainable location, or when the development can show that it would have a positive impact on the sustainability of the area. In some instances, brownfield redevelopment can exacerbate issues and result in development occurring in unsustainable locations. This option aims to reduce such development. Option S3.2b: Prioritise development on brownfield land, incorporating existing buildings into development proposals wherever possible, irrespective of its location This option looks to prioritise the redevelopment of all brownfield land irrespective of whether the site is in a sustainable location. Whilst redevelopment of brownfield land is, on the whole, a sustainable approach, locating redevelopment in unsustainable locations can sometimes exacerbate issues within an area, and this is a risk of prioritising all brownfield sites for redevelopment. Option S3.2c: None of these 8. It is noted that the South Warwickshire Urban Capacity Study (October 2022) has concluded on capacity that: ‘This capacity of around 19,950 compares to a housing need for South Warwickshire over the new plan period of 30,750. This housing need figure is subject to change, and is also likely to require the addition of a buffer to allow choice and competition in the market in accordance with Planning Practice Guidance. We have sought to ensure that the assumptions underlying these figures strike an appropriate balance between conservatism and optimism to ensure robustness – whilst there may be some scope to further optimise capacities, particularly if the SWLP were to include policies to require the higher end of our established optimised density ranges, this is likely to require a higher burden of evidence in order to ultimately demonstrate that the SWLP is a sound local plan. A theoretical exercise to consider the potential yields from car park consolidation has indicated that between 800 and 3,400 dwellings could be created. This would however require significant levels of intervention and management to be realised. The shortfall between urban and existing committed housing capacity could be reduced by undertaking development on public car parks around South Warwickshire, where we have identified potential yields of up to 3,400 dwellings. However, this would necessitate a significant programme of intervention and management in order to be realised. It may also be possible to apply the optimised densities established through the Urban Capacity Study to some sites which have been allocated in existing local plans but which do not yet have planning permission (Site Category 2). However, whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.’ [emphasis added] 9. Therefore, the Council(s) evidence base clearly demonstrates the need for the release of greenfield sites. Q-S5.2: Do you think new settlements should be part of the overall strategy? Yes | No | Don’t Know 18. Spitfire do not object to the consideration of new settlements as part of the Council’s Growth Option. 19. A range of sites varying in scale and size should be explored in order to secure the delivery of new homes. The expansion of existing settlements and new settlements allocated in the Local Plan should also be explored further to see whether there is capacity to be extend these further. Smaller sites are likely to have no significant infrastructure or utility constraints. The site can be accessed off public highway, the site is in the control of a developer (Spitfire) which makes it a deliverable site. Q-S5.3: In response to the climate change emergencies, we are looking at rail corridors as a preferred approach to identifying potential locations. Do you agree? Yes | No | Don’t Know Spitfire have no objection to this growth option being explored but the end goal must be that development is located sustainably and can utilise and improve existing sustainable modes of transport. This option should be assessed against the other options being explored in order to confirm the overall infrastructure requirements of this development option. Q-S8.2: Please select the option which is most appropriate for South Warwickshire 27. A higher limit is appropriate for individual sites this will ensure flexibility and a subsequent increase in housing delivery and will ensure sites also deliver much needed affordable homes. Option S9a: Save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. Any revisions to existing boundaries, and consideration of which settlements have boundaries, would be saved for Part 2 plans and NDPs. The advantage of this approach is that waiting until Part 2 is likely to mean more detailed information is available – for example non-strategic allocations will likely not be made until Part 2, so waiting for these to come forward means any boundary revisions can accurately reflect new allocations. The disadvantages are that inconsistencies of approach between Stratford-on-Avon and Warwick Districts would not be addressed in the short term; and it results in a longer time period to address any out-of-date boundaries. Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. The aim would be to achieve a consistent approach across Stratford-on-Avon and Warwick Districts regarding the type or size of settlement that has a defined boundary. The main impact is on where limited infill development is permitted, and where ‘open countryside’ policies apply. The disadvantage is that some nonstrategic land allocations will likely not be made until Part 2 plans come forward. In such cases, it becomes difficult to make appropriate revisions to boundaries in advance of these non-strategic allocations. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire 28. All settlement boundaries should be reviewed as pry 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.
34. 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. 35. 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. 36. 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. 37. 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. 38. A number of these principles are reflected in the 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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45. Contributions to meeting the Birmingham and Black Country HMA shortfall to 2031 can be accommodated by either increasing the growth proposed for Option 5: Dispersed. Housing targets should be minimum ones in light of the wider Housing Market Area issue and the need to address the Birmingham and Black Country HMA unmet housing needs
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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 29. 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. 30. 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). 31. 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. 32. 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. 33. 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. Q-H2-2: Please select the option which is most appropriate for South Warwickshire: Option H2-2a: A single South Warwickshire wide affordable housing requirement A single affordable housing requirement across the whole South Warwickshire area would provide a consistent approach across both Districts. This results in the most certainty – for developers, greater certainty in anticipating their costs; and for Councils, greater certainty in anticipating delivery of affordable homes. However, this approach would not reflect variations in value, or variations in affordable housing demand, in different areas of the Districts. This could result in a greater level of challenge on viability grounds in areas with lower house prices, and missed potential for affordable housing delivery in areas with higher house prices. Option H2-2b: Separate affordable housing requirements for Stratford-on Avon and Warwick Districts Separate affordable housing requirements for each District would go some way towards reflecting local requirements and local viability calculations. It would provide a reasonable level of certainty for developers and Councils. However, the District boundaries are unlikely to be the most accurate way of reflecting of variations in value, or variations in affordable housing demand, in different areas of South Warwickshire. 39. We consider Option H2-2b; providing a separate affordable housing requirement for Stratford-on-Avon and Warwick Districts, would be appropriate in terms of reflecting local requirements and local viability calculations. However, it is considered that the tenure and type of affordable homes sought should be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. Option H2-2c: A more localised approach with separate affordable housing requirements for different localities across South Warwickshire A more localised approach could reflect with greater accuracy the variations of value, or variations in affordable housing demand, in different areas of the Districts. This may mean fewer challenges on viability grounds. However, having different requirements in different localities adds a level of uncertainty – it makes it harder for developers to anticipate their costs, and it makes it harder for Councils to anticipate delivery of affordable homes. There could also be unintended consequences if it makes certain areas more attractive to developers than others, with the potential that this makes it more challenging to deliver the chosen spatial growth strategy. As acknowledged on Section 6.1 (fourth paragraph) of the Scoping report increasing the housing target would address housing affordability: “We could consider increasing our housing figure to help address housing affordability.” 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? Yes 40. Birmingham City Council has commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes. 41. Issue H1 above sets out the approach to needs arising within Coventry and Warwickshire. Even under the redistribution of housing resulting from the trend-based projection, Coventry may not be able to accommodate all of its housing needs (1,964 homes per annum), and as such a relatively modest shortfall may exist to 2050. 42. South Warwickshire sits most fully within the Coventry and Warwickshire HMA, with Warwick District most strongly related to Coventry given its shared boundary and interrelationships with the city. South Warwickshire is also within the Birmingham and Black Country HMA owing to Stratford-on-Avon District’s shared boundaries and inter-relationships with Solihull and Redditch boroughs and Bromsgrove district. Through the Duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs. 43. Given the size of South Warwickshire, it is considered that any additional needs can be accommodated outside of any protected areas (e.g. Cotswolds National Landscape/AONB). One exception could be areas designated as Green Belt, particularly if such locations are deliverable, available and suitable for release from the Green Belt to deliver high quality residential developments. Locations for additional growth should be sustainable in close proximity to where people want to live. 44. In light of the above considerations, we 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. Option H5a: Identify a range of specific sites within or on the edge of existing settlements of approximately 5-20 homes in size to be developed only for self and custom build homes. This would group this type of housing together in small sites in various locations, and whilst it gives certainty as to where this type of housing will be provided, it is dependent on landowners putting sites forward for this type of housing. This approach would not allow for individual plots in other locations that some people might prefer, although it should be borne in mind that the provision of such homes in open countryside would not be appropriate. 46. This would be the preferred option and should be considered for all settlement types, this would enable the South Warwickshire Authorities to group this type of housing together in small sites in various locations, such an approach would be dependent on landowners putting sites forward for this type of housing. Option H5b: Require large developments of, say, over 100 homes to provide a proportion of self and custom-build homes within the overall site. This would provide more certainty of delivery as it would be a requirement of the larger development sites across the area and could provide a wider spread of this type of home across South Warwickshire. However, some people looking for self and custom build homes may not wish to live or on the edge of a large housing site. It will be necessary to establish what an appropriate proportion of such homes should be on such sites. 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. This option depends completely on the private sector in terms of the quantity and suitability of any submitted planning applications for self and custom build homes. Whilst this approach may be useful in conjunction with either Options 1 or 2, relying on this option alone would make it impossible to ensure that sufficient numbers of self and custom build home are made available Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire Spitfire’s experience as a medium sized housebuilder is that self and custom build sites work better when they are stand alone rather than forming part of a large consortium site. Marketing strategies will need to be agreed with the LPA and form part of any s106 agreement to ensure sites come forward and in the event, evidence is produced that no interest has been generated from the marketing strategy that homes can revert back to open market dwellings.
47. Yes, the Alscot Estate Biodiversity Project which was implemented in April 2020.
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Q-C4.1: Please select all options which are appropriate for South Warwickshire 49. Any such proposed policy would be a duplication of control and is unnecessary.
