Issue and Options 2023
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New searchISSUE S1: GREEN AND BLUE CORRIDOR 2.10 The preliminary landscape proposal for the Land at Old Town, Gaydon Site has demonstrated that a range of elements such as: the retention of existing and new hedgerows, additional tree and woodland planting, and the potential ecological benefits associated with Sustainable Urban Drainage systems, will provide multiple ecological benefits. 2.11 Green and blue infrastructure can be incorporated within a development in a number of ways. As the layout design of such sites as Land at Old Town, Gaydon progress, it would be advantageous for additional evidence from the emerging Sub-Regional Green Infrastructure Strategy to be made available as soon as possible in order to inform the proposal. 2.12 Ellis Machinery would support Option S1a as preferable, considering the production of a Local Nature Recovery Strategy will come after the SWLP Spatial Growth Strategy has been determined. ISSUE S4: GROWTH OF EXISTING SETTLEMENTS 2.13 Yes, Ellis Machinery consider that growth of some of South Warwickshire’s existing settlements should be part of the overall strategy. 2.14 As stated within the consultation document, 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 approach to growth across South Warwickshire seeks to maximise the capacity of its existing urban areas in order to meet development needs to 2050. The approach acknowledges growth around the edges of the existing settlements, potentially alongside and in combination with other options such as new settlements. 2.15 Gaydon is identified as a Category 4 Local Service Village (LSV) in the Stratford-on-Avon Core Strategy (SOVCS). Policy CS.15 of the Local Plan sets out the distribution of development across the District, promoting a pattern of balanced dispersal in settlements. These smaller villages often have the capacity (in terms of limited impact on landscape, biodiversity etc) to accommodate small/medium scale residential developments. 2.16 The Old Town, Gaydon Site immediately adjoins the built-up area boundary of Gaydon with existing residential development to the north and east. The Site would be well connected to the built-up area of the village and would: • Assist in meeting the District’s housing need, including a diversity of housing stock for both market and affordable housing; • Assist in maintaining the viability and vitality of the Gaydon village services and facilities, and • Ensure that there is a supply of small and medium sized sites, that are free of infrastructure constraints and can be delivered quickly. 2.17 Given the pressing need for additional housing within the Stratford-on-Avon District, Gaydon is a sustainable location to accommodate additional housing growth. Initial Technical Reports for the Site have been prepared and included in the Call for Sites submission. The Technical Reports demonstrate that the Site has no constraints that would preclude a speedy delivery of new homes. 2.18 Accordingly, it is considered that the Site should be allocated as a residential site within the South Warwickshire Local Plan. ISSUE 5: THE POTENTIAL FOR NEW SETTLEMENT 2.24 Ellis Machinery does not object to the consideration of new settlements as part of the Council’s Growth Option. 2.25 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 that are unlikely to have significant infrastructure or utility constraints, such as Land at Old Town, Gaydon, as well as providing direct benefit to the local community are able to be delivered quickly. ISSUE 8 SMALL SCALE DEVELOPMENT OUTSIDE THE SPATIAL GROWTH OPTION 2.30 No, the scale of a development should reflect the character of the locality and any specific housing need of the local area. ISSUE S9: SETTLEMENT BOUNDARIES AND INFILL DEVELOPMENT 2.31 Ellis Machinery would support Option S9a, existing boundary that have already defined within the Core Strategy, Local Plan, emerging SAP or an NDP.
2.32 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. 2.33 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. 2.34 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. 2.35 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). 2.36 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. 2.37 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 of what has already been built, has planning permission or is identified for development in existing Plans and the capacity of small ‘windfall’ sites. 2.38 Overall, Ellis Machinery 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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ISSUE H2: PROVIDING THE RIGHT TENURE TYPES OF HOMES 2.39 Ellis Machinery consider Option H2-2b; providing a separate affordable housing requirement for Stratford-on-Avon and Warwick Districts, would be the most appropriate in terms of reflecting local requirements and local viability issues. 2.40 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. ISSUE H3: PROVIDING THE RIGHT SIZE OF HOMES 2.41 Ellis Machinery has 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, Ellis Machinery reserve the right to comment further at a later stage, once the specific requirements for sites have been clearly defined. ISSUE H5: PROVIDING CUSTOM AND SELF-BUILD HOUSING PLOTS. 2.42 Ellis Machinery consider that both Option H5b and H5c would be appropriate for South Warwickshire. Both approaches 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. For each option, it must 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. 2.43 Option H5b should 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).
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ISSUE C4: NEW BUILDINGS Q-C4.1: Please select all options which are appropriate for South Warwickshire 2.44 Ellis Machinery would not support any of the above. Any such proposed policy would be a duplication of control and is unnecessary.
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ISSUE C9: MITIGATING BIODIVERSITY LOSS Q-C9.1: Please select the option which is most appropriate for South Warwickshire 2.45 NPPF Paragraph 32 advises that local plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Further, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including establishing coherent ecological network that are more resilient to current and future pressures. 2.46 Ellis Machinery is supportive of the requirement to enhance biodiversity across development sites. The provisions of the Environment Act 2021 requiring a 10% net gain secured through a planning condition will come into force in November 2023. Planning Policy should reflect this change to the planning context. Option C9.1a is considered to be the most appropriate for South Warwickshire.
