Issue and Options 2023
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New searchWe support the vision in principle, which seeks to create a prosperous, stronger and sustainable South Warwickshire. The vision provides a positive framework for the Strategic Objectives and is generally aligned with the three overarching sustainability objectives set out in NPPF Paragraph 8. We are supportive of the Strategic Objectives, which will address the key strategic challenges and opportunities that have arisen since the Warwick District Local Plan was adopted in 2017. We consider that the Site, which has the potential to deliver 150 new homes in Kenilworth as well as significant open space in a sustainable location, would assist the South Warwickshire Authorities in achieving these objectives.
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).’ It is noted that in the conclusion for the Sustainability Appraisal it 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] Furthermore, the following technical assessments are currently being undertaken to help inform later stages of the plan: • Transport Assessment • Climate Change Impact Assessment • Biodiversity and Green Infrastructure Assessment • Landscape Character Assessment • Health Impact Assessment • Green Belt Study • Heritage Assessment The Issues and Options SA is, by its own admission, heavily caveated and no mitigation has been considered. We therefore reserve the right to comment further at a later stage, once the Sustainability Appraisal has advanced following the outcome of key evidence base documents.
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Yes, we consider that growth of some of South Warwickshire’s existing settlements should be part of the overall strategy. South Warwickshire has a dispersed settlement pattern 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. 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. As set out in Strategic Policy DS4 of the current Warwick District Local Plan, the majority of growth in Warwick District is focused on the main urban areas of Warwick, Leamington, Whitnash and Kenilworth and on the southern edge of Coventry. The distribution of development is as follows: a) Previously developed land within urban areas and in particular those areas where there is greatest potential for regeneration and enhancement; b) Where greenfield sites are required for housing, they should generally be located on the edge of built-up areas in sustainable locations close to areas of employment or where community facilities such as shops, bus services, medical facilities and schools are available or can be made available; c) Where greenfield sites are required for employment, they should be suitably located for the needs of 21st century businesses, accessible via a choice of transport modes and in close proximity to existing or proposed housing; d) Limiting development on sites that would lead to the coalescence of settlements to ensure settlement identity is retained; e) sites that have a detrimental impact on the significance of heritage assets will be avoided unless the public benefits of development outweighs the harm; f) areas assessed as high landscape value or other highly sensitive features in the natural environment will be avoided; and g) taking the national green belt policy into account, sites that are currently in the green belt will only be allocated where exceptional circumstances can be justified. Kenilworth is one of the main urban areas in the District and comprises one of the most sustainable settlements in the spatial distribution of growth. Land at Warwick Road, Kenilworth is located on the southern edge of Kenilworth. The adjacent neighbourhood to the north of the Site (known as ‘Castle End’) includes numerous local services, such as a post office and St John’s Primary School which are within a 15-minute walk. Additional leisure services are available along the A452 and within the Oaks Precinct Shopping Centre, including beauty salons and takeaways. Kenilworth School Sixth Form lies north west of the Site within a 5–10-minute walking distance. A greater diversity of facilities can be found within Kenilworth’s town centre along the northern end of Warwick Road and Abbey End. The main town centre is within a 5–10- minute cycle distance of the Site. The promotion site is therefore well connected to the built-up area of Kenilworth and would constitute sustainable development in accordance with Strategic Policy DS4 of the Warwick District Local Plan. Indeed, it is considered that the new homes at land at Warwick Road will comply with the 20-minute neighbourhood concept, owing to the close proximity of the site to Kenilworth’s services and facilities. Given the pressing need for additional housing within Warwick District, Kenilworth 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. Accordingly, it is considered that the Site should be allocated as a residential site within the South Warwickshire Local Plan.
It is acknowledged that there have been issues with estimating and projecting the population in Coventry, meaning population growth in the City has been systematically over-estimated by ONS (dating back to at least 2001) and that the over-estimation works through into population projections that are demonstrably too high and unrealistic. The draft Plan considers that as the overall housing need in Coventry is lower in the HEDNA (compared to the previous 2014-based projections), it follows that the Local Plan will be likely to need to accommodate fewer additional homes from Coventry based on these figures. However, 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. 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). 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. 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. 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.
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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. 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. 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 interrelationships with Solihull and Redditch boroughs and Bromsgrove district. Through the Duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs. 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. 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.
Housing needs that cannot be met within neighbouring areas must be met as close as possible to those areas, or within areas where sustainable transport connections can easily be made to those areas. 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. Kenilworth is situated approximately 6 miles (10 km) to the south-west of Coventry and comprises the closest town within the District to the city. Kenilworth also benefits from a train station and excellent road connectivity to Coventry. As such, the market town is ideally located to accommodate any housing shortfalls from outside of South Warwickshire, particularly Coventry. In accordance with the guidance contained within the Framework, development should also be focussed in the most sustainable locations in terms of availability of shops, facilities and services, as well as access by modes of transport other than the private car. In addition, it is considered that development should be distributed over a range of settlements rather than in single settlements in order to ensure their vitality and viability in accordance with the principles of sustainable development set out in the Framework. L&Q Estates consider any housing shortfalls from outside of South Warwickshire should be directed to sustainable locations in accordance with the distribution of development established in Strategic Policy DS4 of the adopted Warwick District Local Plan. Kenilworth is identified as one of the most sustainable settlements in the settlement hierarchy and spatial distribution of growth in Warwick District. It offers a large range of services and facilities, including supermarkets, banks and hardware shops. The promotion site would be well connected to the built-up area of Kenilworth and would constitute sustainable development. Indeed, it is considered that the new homes at land at Warwick Road, Kenilworth will comply with the 20-minute neighbourhood concept, owing to the close proximity of the site to Kenilworth’s services and facilities. Given the pressing need for additional housing within Warwick District, in addition to meeting the housing shortfalls from outside of South Warwickshire, Kenilworth is clearly a sustainable location to accommodate additional housing growth. The Site at land at Warwick Road, Kenilworth 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. Accordingly, it is considered that the Site would be an appropriate location to accommodate a residential development to meet housing shortfalls from outside of South Warwickshire.
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Q-H2-2: Please select the option which is most appropriate for South Warwickshire: 4.8 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. L&Q Estates support a collaborative approach to identifying site-specific affordable housing requirements, including tenure and type of affordable homes to be provided on-site. Q-H3: Please select all options which are appropriate for South Warwickshire L&Q Estates have no objection to a requirement to meet optional Building Regulations M4(2)/M4(3) in principle (Option H3c). It is considered that this should be achieved by requiring a certain proportion of homes on sites in medium or higher value zones to meet the optional standards. However, we reserve the right to comment further at a later stage, once the specific requirements for sites have been clearly defined. Q-H5: Please select all options which are appropriate for South Warwickshire Whilst it is considered that Option H5a 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. Therefore, this approach may not provide sufficient suitable development permissions to meet the identified demand in accordance with the duties under sections 2 and 2A of the Self Build and Custom Housebuilding Act 2015. We consider Option H5b is appropriate for South Warwickshire, provided it can be demonstrated that there is currently a need for self-build and custom build plots identified in the self-build and custom build register for the local authority where the site is located. The proportion of self and custom-build plots to be made available within large sites should be sufficient to match the current number on the register. Such an approach would align with the aims of Paragraph 62 of the NPPF in terms of providing opportunities for people wishing to commission or build their own homes. It is considered that any policy under Option H5b should also include a fall-back option of reverting any unsold self-build plots to the developer to build, should any of these plots not be sold after an appropriate marketing period (of, say, 12 months, for example).
