Issue and Options 2023

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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? Policy SAP.4 of the Stratford-on-Avon Site Allocation Plan Revised Preferred Options (June 2022) intends to provide Stratford’s contribution to meeting Greater Birmingham & Black Country’s shortfall to 2031 on the following sites: - STR.A – North of Evesham Road, Stratford-upon-Avon - STR.B – East of Shipston Road, Stratford-upon-Avon - STR.C – South of Alcester Road, Stratford-upon-Avon - MAPP.A – West of Birmingham Road, Mappleborough Green We do not object in principle to the majority of the unmet need being provided in Stratford, however the three sites proposed in Stratford are less suitable locations for growth than to the northeast of Stratford for the reasons set out in our answer to question Q-S4.2. It is identified that an additional shortfall of some 78,000 homes for the Greater Birmingham and Black Country HMA will be required up to 2042. Whilst the review of Birmingham City Council’s Local Plan to 2042 is ongoing, we encourage the Council to be proactive and look to plan for accommodating part of this unmet need within South Warwickshire, which is likely to be greater than 78,000 homes should the plan period match the SWLP to 2050. 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. The scale of any shortfall to meet the housing needs of the Birmingham and Black Country HMA should be proportionate and reasonable for South Warwickshire. Whilst the current draft of the Levelling Up and Regeneration Bill looks to remove the Duty to Co-operate, this has not yet gained Royal Assent and the transitional arrangements within the NPPF mean that the current NPPF plan-making rules will apply to this emerging Local Plan and therefore paragraph 35(a) will still apply which required unmet need to be accommodated where it is practical to do so and is consistent with achieving sustainable development. The collapse of the Birmingham Development Plan has created uncertainty about how much housing will need to be exported to areas including South Warwickshire. It is likely that the figure will increase the SWLP will need to contribute towards meeting this need.

If the Council are required to meet housing shortfalls from outside of South Warwickshire it should be accommodated in the most sustainable locations for growth even if this means releasing further Green Belt land to achieve sustainable patterns of growth.

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Q-H2-1 - What is the best way to significantly increase the supply of affordable housing across South Warwickshire? The delivery of affordable housing is, for the most part, via allocated and windfall sites. If the housing requirement is reduced, so too will affordable delivery. And affordability ratios in Warwickshire are substantial. The best way therefore to significantly increase the supply of affordable housing is to allocate greenfield sites, including the release of Green Belt, for 10+ units across the District. Non-brownfield sites have fewer viability and deliverability issues than brownfield sites and are therefore often capable of delivering a policy compliant level of affordable housing, unless site specific constraints such as the need to ground large overhead powerlines indicates otherwise. Q-H2-2 - Please select the option which is most appropriate for South Warwickshire: 1) Option H2-2a: A single South Warwickshire wide affordable housing requirement. 2) Option H2-2b: Separate affordable housing requirements for Stratford-on-Avon and Warwick Districts 3) Option H2-2c: A more localised approach with separate affordable housing requirements for different localities across South Warwickshire We do not agree with a more localised approach with separate affordable housing requirements for different localities. This will lead to affordable housing across the District becoming fragmented and could also potentially impact on viability more in some locations than others. The approach either needs to be one % requirements across South Warwickshire or one in each District (i.e. different standards for the Stratford-on-Avon area and one for Warwick District. Otherwise, the requirements will be too complicated and piecemeal. Q-H3 - Please select all options which are appropriate for South Warwickshire 1) Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. 2) Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. 3) Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4) Option H3d: None of these Option H3a – do not seek to include minimum space standards in a policy in the SWLP. It is onerous to prescribe in policy that minimum space standards should be met. We would support in principle a policy which requires “up to X%” to be built to M4(2) or M4(3) standards but this should not be a requirement for all dwellings. Q-H5 - Please select all options which are appropriate for South Warwickshire 1) 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. 2) Option H5b: Require large developments of, say, over 100 homes to provide a proportion of self and custom-build homes within the overall site. 3) 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. Option H5b is not acceptable. It is impracticable to require mainstream housebuilders to provide self / custom build plots throughout a development as it leads to a fragmented development with unbuilt plots left empty on a phase or phases when the rest of a phase is built and occupied. Opportunities for self / custom build should be made through specific site allocations for that purpose only under H5a above alongside encouraging applications under H5c. Q-H6 - Please select all options which are appropriate for South Warwickshire 1) Option H6a: Identify a range of specific sites in sustainable locations of up to 15 pitches/plots in size to be developed only for Gypsy and Traveller and Travelling Showpeople homes. 2) Option H6b: Require large developments of over 500 homes to provide a proportion of Gypsy and Traveller and Travelling Showpeople homes on the edge of the overall site. 3) Option H6c: Rely on a case-by-case approach whereby planning applications for Gypsy and Traveller and Travelling Showpeople homes will be assessed against a range of criteria to determine their suitability. Option H6a should be taken forward. It is not acceptable to require large development to provide a portion of Gypsy and Traveller and Travelling Showpeople homes on the edge of the overall site. This will affect sites’ cohesive design and placemaking, impacting on sales rates and viability.

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Q-C4.1 - Please select all options which are appropriate for South Warwickshire: 1) Option C4.1a: Do not have a policy and allow new development to comply with the national building regulation requirements, which may change over time. 2) Option C4.1b: Set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. 3) Option C4.1c: Have a phased approach to net zero carbon, setting a future date by which all new development will need to achieve net zero standards. In the intervening period new development will need to meet building regulation standards. Option C4.1a is preferred as it would be onerous to set a standard higher than the building regulations requirement. A policy could encourage a local standard beyond building regulations but should not mean that an application should be refused because it does not meet regulations over and above the national standard. In time, the building regulations will evolve to allow a phased approach to reaching Net Zero. A separate approach would hinder plan delivery due to developers having to have a different design, building process and materials to the regulations, slowing the pace of delivery and reducing viability. Davidsons are committed to energy efficiency in our homes and currently build to a high standard than buildings regulations require.

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Q-C9.1 - Please select the option which is most appropriate for South Warwickshire: 1) Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity. 2) Option C9.1b: Do not include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity. We do not object in principle to the inclusion of a policy requiring a net gain in biodiversity provided that the policy wording allows for flexibility and allows for off-site mitigation where a net gain cannot be met in full on-site. This requirement will soon gain Royal Assent through the Environment Bill; therefore, it is prudent to include a policy on biodiversity net gain. It seems onerous to include in policy a requirement that less than 50% of a wider site is to consist of paved / hard surfaces. It could be an aim or ambition but needs to allow for site flexibility (e.g. a site might require 52% hard surfaces but still be more than acceptable in drainage terms.

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Q-D.2 - Please select all options which are appropriate for South Warwickshire: 1) Option D2a: Develop a South Warwickshire Design Guide 2) Option D2b: Develop design guides and/or design codes for specific places (e.g. existing settlements or groups of settlements, or an ‘area’ in the case of a new settlement) where the spatial strategy identifies significant change. 3) Option D2c: Develop design guides/codes for strategic development sites/locations. It would be onerous to produce design guides or design codes for specific places or strategic development sites through the Local Plan process. In line with the anticipated Levelling Up and Regeneration Bill and the requirement for Local Authorities to produce whole area design codes, it would be prudent for the Council to produce a South Warwickshire Design Guide. It need not cover every aspect of design or every type of development. There is then the option for site specific design codes to be produced for large scale strategic sites through the application process. Option D2a would therefore be preferred. Q-D3 - Please select all options which are appropriate for South Warwickshire: 1) Option D3a: Include a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. 2) Option D3b: Include a policy which specifies a minimum density requirement across South Warwickshire, whilst emphasising that the minimum may be exceeded. This minimum could for example be set at a similar level to the existing policy in Warwick District - i.e. minimum 30d.p.h. 3) Option D3c: Identify appropriate density ranges for different locations /areas across South Warwickshire and specify these ranges in policy. These ranges could be based upon the prevailing characteristics of existing places. 4) Option D3d: Identify appropriate density ranges for different locations/areas across South Warwickshire based upon accessibility and potential accessibility of these places. 5) Option D3e: None of these Option D3a is the best option here. Any policy on density will need to be flexible enough to be able to adapt to the different needs of each site and location. It is too onerous to specify density ranges on a location or area basis, therefore in policy terms it is enough for policy to highlight the relevance and importance of density and acknowledge that it may change on a site-by-site basis. Q-D5 - Should we continue with the approach to include a high-level strategic policy within the Part 1 plan and to utilise heritage assessments to inform the growth strategy, and delay detailed policies to Part 2? Heritage is obviously an important consideration when looking at the growth strategy and deciding on draft allocations, however it is important to remember that other factors such as sustainability and the level of public benefit brought by a site can outweigh any heritage harm, particularly where such harm can be mitigated through design principles. It is too straight forward to base plan allocations heavily on heritage impact. The Part 1 Plan should continue with high-level strategic policies but should include draft allocations for strategic site such as Clopton Quarter. This would be informed by the further evidence base to be prepared including the Green Belt review. On a site-specific basis, Clopton Quarter is located on a key entrance to the historic town. As shown on the masterplan and within the vision document, and by our award-winning developments elsewhere (see Houlton and Leicester Forest East), Davidsons are committed to creating exemplary frontages which respect and enhance the immediate location.

Conclusion To conclude, Land at Clopton Quarter sits to the northeast of Stratford within the assessed ‘Broad Location for Growth’ B.26 ‘Stratford Northeast’. We consider the extend of the Stratford North-East Broad Location for Growth to be unrealistic given the landscape and heritage constraints which lie further east / southeast of the Clopton Quarter site. Therefore, the land under our control at Clopton Quarter should come forward as a standalone extension to Stratford for the reasons set out in detail in this response. The site will deliver the following benefits: - A leading example of a 20-minute neighbourhood by virtue of its sustainable location. - 700 units, including affordable housing. - 40% of the site designated as multi-functional green / blue infrastructure (14ha) - Biodiversity net gain and ecological enhancement. - Restoration of the Vale Orchard landscape through new orchard planting with native fruit trees. - A new, mixed use pedestrian gateway into the Welcombe Hills Country Park. - Infrastructure improvements to the highway network. In addition to the site being suitable for development in itself, it is also important to highlight that it is the only logical location for further growth at Stratford, and Stratford must take some growth. Whilst the land to the west / southwest / south / southeast is not designated as Green Belt, these areas bring their own problems in delivering sustainable development in Stratford. Land to the south of the racecourse is designated as Flood Risk Zone 3, and so would not be suitable. Any development towards Long Marston as part of a new settlement and any further development off Banbury Road / the A3400 to the southwest of Stratford would be reliant on the completion of the Southwest Relief Road. This road was rejected for Housing Infrastructure Fund (HIF) funding and whilst the Cala scheme has contributed £45million towards the road, there is a funding gap of £86million with no clear delivery mechanism. Without this road further development will create chronic traffic problems in the centre of Stratford as the only way to join the A46 would be to use Bridge Street / Bridge Foot. Traffic along this route would be increased to an unacceptable level. Any further development to the west would be further away from the centre of Stratford and would thus be less sustainable. It would also bring unacceptable heritage impact to Anne Hathaway’s Cottage and the surrounding area. Further development to the northwest would also be too detached from Stratford, leading to unsustainable development and an over-reliance on the car. This area has no defensible boundaries and the release of this Green Belt land would result in unrestricted sprawl into the open countryside and it is severed from Stratford-Upon-Avon by the A46, meaning that residents would be separated with no permeability into the town. This location is also further from Stratford than Clopton Quarter, meaning it is a less sustainable option. The site is acceptable in heritage terms and is a logical location for growth considering that the other locations around the edge of Stratford are not suitable and will lead to unacceptable highway impacts. We therefore request that Land at Clopton Quarter is considered in isolation, excluding the remainder of the potential Broad Location for growth, as a suitable residential allocation within the South Warwickshire Local Plan. Therefore, Land at Clopton Quarter should be released from the Green Belt and be allocated for up to 700 units for the reasons set out in this representation. We will be engaging with the Green Belt Review process once this commences.