Issue and Options 2023

Q-S1 – Please select the strategic green and blue infrastructure option which is most appropriate for South Warwickshire We fully support the Local Plan including policies on the provision of strategic blue and green infrastructure. However, the preparation of the Plan should not be delayed by the production of the Local Nature Recovery Strategy. In addition, the Local Nature Recovery Strategy will not be tested in the same way development plan policies will through the examination process. It is, therefore, our view that the preferred approach should be Policy S1a, identification of strategic green and blue corridors in the SWLP in advance of the preparation of a Local Nature Recovery Strategy, so that this policy can be brought forward in a timely manner and tested through the examination process. It is noted that page 34 of the Plan advises that it is anticipated that the Part 1 Plan will set out the development principles and associated blue and green infrastructure required for the broad locations that are identified, and the Part 2 Plan will provide more details on the strategic locations and also set out the development principles and details on the non-strategic locations identified for growth. As detailed elsewhere within our representations, we object to the preparation of a two part plan. However, if this is ultimately the preferred approach the Part 1 Plan should not defer to the Part 2 Plan for additional details on the strategic locations for growth as it may delay their delivery. The policy guidance for the strategic allocations contained within the Part 1 Plan should be sufficient for them to be brought forward immediately, without having to delay the preparation of applications until the completion of the Part 2 Plan. The Part 1 Plan will need to make it clear that the strategic sites can be brought forward for development upon adoption of the Part 1 Plan in order to ensure that there is a continue supply of housing and employment land. QS2 – Please select the intensification options which are most appropriate of the South Warwickshire Whilst we fully support making the best use of available sites, the plan needs to be realistic in terms of the ability of an intensification policy to deliver additional development. Page 39 of the Draft Plan advises that intensification can be achieved in a number of ways. We comment on these options as set out below: • Conversion of upper floors of buildings to residential use We have no objection to this proposal, however, permitted development rights and positive planning policies in general have facilitated in bringing the upper floors of buildings back into residential use for a number of years. The inclusion of a policy supporting such proposals is unlikely to result in any significant increase in dwellings. • Additional storeys and buildings This is an unreliable source of housing. There needs to be an understanding of whether buildings are structurally capable and designed in such a way to allow additional floors added to them. Also, there may be design implications and visual impact issues associated with the creation of additional stories. There have been permitted development rights in place for a number of years that allow for the development of two extra stories of accommodation on certain buildings, meaning that such schemes can already come forward in a number of instances. This is unlikely to be a significant source of supply. • Re-use of empty homes When a home is empty it is often for good reason. For example, an elderly person going into care accommodation with the hope that they may return home, or general churn in the housing stock. Furthermore, re-using an empty home is not a “net” source of supply unless once the property became vacant it was recorded in the housing land supply calculations as a loss of a dwelling, which we very much doubt it will have been. There is the potential for there to be double counting from this source of supply. • Infill in residential areas There are positive policies in place for filling the gaps in street frontage and developing disused garage blocks within the adopted Local Plans. A policy supporting infill development is unlikely to result in additional sites coming forward beyond those that are already available. We have significant concerns with the suggestion that car parks could be developed for housing. A car parking strategy would need to be prepared in order to establish whether these car parks are required, as removing car parks could impact on local shops and services where customers use the car parks, or reducing car parking space available in residential areas resulting in additional on street parking. In addition, all of these sources of supply would, in effect, be windfall sites. They are not a new source of supply that will be boosted by the inclusion of a policy in the SWLP. In terms of new developments there needs to be a realistic consideration of the net developable areas and densities that can be achieved. In order to secure high quality design, new developments will need to provide on site open space, green infrastructure and have the ability to satisfy biodiversity net gain requirements This is likely to impact upon the net to growth land ratio available. Indeed, if it is assumed that 40% of greenfield sites will be required for green infrastructure and biodiversity net gain offsetting, this is likely to reduce the total net developable area to around 50% of the gross when infrastructure requirements are considered. Indeed, we note that the plan’s ecological policies suggest that 50% of sites may need to be set aside for green and blue infrastructure (Option C9.1a). Furthermore, we expect the Plan will require a variety of house types to come forward, ranging from bungalows and apartments, to larger 3, 4 + bed properties. Sufficient car parking must be provided within residential schemes in order to try to avoid on street car parking. There will also be areas within the Plan, such as on the edge of settlements and villages, where densities will have to reflect the character of the surrounding area in order to provide a high quality design. In summary, whilst we have no objection to the inclusion of an intensification policy, it is our view that it is highly unlikely to result in significant additional development and should not be treated as a new source of housing land supply beyond that expected from windfalls. Q-S4.1 – Do you think the growth of some of our existing settlements should be part of the overall strategy? Yes. The growth of the existing settlements should be a key part of the growth strategy of the Plan. The SWLP’s housing and employment requirement should be delivered principally through the expansion of existing towns and settlements. The level of development directed to each of the settlements within the plan area should be influenced by a series of factors. This includes the level of service provision within each of the subject towns and the nature of the development opportunities being proposed in these locations. Southam should be a priority area for housing allocations. It is not constrained by the Green Belt. The town has in excess of 6,500 residents and approximately 2,800 dwellings. The town centre provides a range of shops, services and facilities including a number of schools, a leisure centre and library, medical centres, a police station and a post office. There are good public transport services to Leamington Spa, Coventry, Rugby and nearby villages. There is a well established employment area on Kineton Road that provides a range of jobs. The town has been successful in attracting a number of large companies. The town functions as a service centre for much of the eastern part of the district. A large number of rural communities look to the town for their everyday needs. Southam College strengthens the town’s role as the local secondary school. It is one of the largest settlements in Stratford District and is clearly a sustainable location for additional development. Q-S5.2 – Do you think the new settlements should be part of the overall strategy? The development of new settlements can be an effective way of delivering a significant amount of housing and supporting infrastructure through the plan making process. However, new settlements that require a complete infrastructure package will, in all likelihood, take at least 5 to 6 years from the allocation plan to start to deliver housing. They must, therefore, be supplemented by smaller and medium sized allocations. Vistry’s land interest at Southam can provide 750 0- 800 dwellings in the short term significantly boosting the supply of housing whilst any new settlements allocations are realised.

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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 toward a trends based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? Paragraph 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. 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 Vistry’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 build 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.

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-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. Q-C9.1 – Please select a biodiversity option which is most appropriate for South Warwickshire In our view it is not necessary for the SWLP to include a policy requiring new developments to incorporate measures to increase biodiversity. In November of this year it will be a statutory requirement for all development proposals to demonstrate 10% biodiversity net gain. As this is set out in the Act it does not need to be repeated in policy.