Issue and Options 2023

There is an acute recognition in the Issues and Options consultation documents of an affordability problem across South Warwickshire Plan area, where those on low incomes and young people struggle to access the housing market. Warwick District Council’s latest ‘Authority Monitoring Report’ (AMR) (for the period 2020-2021) indicates that against an annual requirement of 280 affordable dwellings since the beginning of the currently adopted Plan period in 2011 (within its own area), the Council have delivered 841 affordable dwellings (out of a total requirement for 2,800), 30% of the target. Stratford-on-Avon’s latest AMR for the period 2021-2022 (published December 2022) identifies that in the current Core Strategy plan period of 2011-2031, 3,204 affordable dwellings have been provided out of a total 10,019 dwellings (net) built. This equates to 37% of all dwellings and is just above the Plan’s affordable housing policy requirement of 35% of all dwellings to be affordable. Notwithstanding Stratford-on-Avon’s marginal reported over delivery, the HEDNA considered the affordability issue across the District further. It identifies at Table 8.45 that the estimated annual need for affordable housing (rented and affordable home ownership) across Stratford-on-Avon and Warwick is 1,386 dwellings per annum. Whilst it is recognised that these are ‘net’ figures and not ‘newly arising need’, PPG paragraph 2a-024 makes provision to encourage local authorities to consider increasing planned housing numbers where this can help to meet the identified affordable need: “The total affordable housing need can then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probably 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 where it could help deliver the required number of affordable homes.” It is identified at paragraph 4.4 of the HEDNA that the overall affordable need is high relative to the overall housing needs. As stated within this paragraph also, …'policies for affordable housing provision within local plans should therefore be influenced by a combination of the needs evidence, viability evidence…' The NPPF also outlines the important role that strategic policies play in the delivery of affordable housing. Furthermore, paragraph 63 states that 'where a need for affordable housing is identified, planning policies should specify the type of affordable housing required and expect it to be met on-site unless: a) off-site provision or an appropriate financial contribution in lieu can be robustly justified; and b) the agreed approach contributes to the objective of creating mixed and balanced communities.' The South Warwickshire Local Plan will have an important role in meeting the unmet housingneed and assist in the wider unmet affordable housing need across Coventry and Warwickshire. The Issues and Options consultation recognises that the area has an acute affordability problem, and it is suggested that to address this, the Plan must consider providing housing above the ‘minimum’ need, to boost supply, and in turn deliver additional affordable housing. The evidence base provided so far demonstrates that there is an undersupply of affordable housing that needs to be addressed which the previous local plans have not delivered. A new settlement allocation within the plan provides the opportunity to deliver and boost the supply of much needed affordable housing within both districts.

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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. This would be dependent on being able to evidence a need for these requirements across South Warwickshire, without having an unacceptable impact on affordability of properties. It may be considered strategically important when considering the capacity of strategic sites. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified.” Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 'Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.' It is clear that the introduction of the NDSS requires a Local Plan policy which has been fully evidenced, justified and viability tested. If NDSS is subsequently justified and pursued, the policy should be sufficiently flexible to recognise that well-designed house types which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. This would be dependent on being able to evidence a need for these requirements across South Warwickshire, without having an unacceptable impact on affordability of properties. It may be considered strategically important when considering the capacity of strategic sites. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. Should the council be minded to implement a policy relating to specific delivery of accessible homes, for example through the delivery of a percentage of housing on site to meet these standards, there would need to be suitability evidence to demonstrate that there is a need. The provision of such accommodation should be taken into consideration with regards to viability and build costs. Q-H5: Please select all options which are appropriate for South Warwickshire As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016-20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. The HEDNA evidence and Self-Build Register for both authorities should form part of the evidence base that informs any emerging policies that deal the delivery of selfbuild/custom plots on applications for residential development. If the Plan is going to require a % of self-build plots this must reflect current evidence of need. Lone Star Land support the provision of larger sites providing an element of self-build and custom build sites within a percentage of development. However, from their experience and established knowledge of the South Warwickshire area, the demand for self-build and custom build sites are predominantly located within the edge of existing villages and settlements. Therefore, there will be a need for the plan to provide an appropriate proportion of custom and self-build plots in the most viable and appropriate locations which will be deliverable in the plan period. It is considered appropriate to make policy provision for smaller sites, exclusively for custom and self-build, to be delivered within or on the edge of individual settlements where appropriate. Not all Custom self-build demand is for properties on larger residential schemes, that are otherwise being delivered by national housebuilders. Further, if there is a policy requiring self/custom build on major sites then it is nevertheless submitted that it should include a mechanism to allow for such plots to come forward for market housing if demand is subsequently found to be absent. For example, if serviced plots for self-build and custom housebuilding have been made available and marketed for a set period of time at an agreed "market price" andhave not sold, plots can be used for delivery of general market housing

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Q-C4.1: Please select all options which are appropriate for South Warwickshire 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. Without a policy in the plan, we would be tied in with national minimum requirements, and have no control over changes to these standards over time. If a net zero carbon policy is to be implemented by the Council, it must be fully evidenced and justified and included in viability considerations. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficiency. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire It is understood that a Whole Life-Cycle Carbon Assessment considers a building’s carbon impact on the environment as a whole and are most usefully undertaken once a building has been constructed but prior to occupation. The value of Whole Life-Cycle Carbon assessments is recognised and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, however if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, the purchasers and/or mortgagees will own the properties. It is unclear how units once occupied would be required to share information in respect of energy use, air quality and overheating risk data with a third party, where the developer no longer holds ownership and therefore does not have responsibility of maintaining the property. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.

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Q-C9.1: Please select the option which is most appropriate for South Warwickshire Lone Star Land Ltd. are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms of the delivery of biodiversity enhancements. It is considered from a biodiversity net gain perspective, development proposals within a new settlement provides greater opportunities for BNG on site. Furthermore, BNG within a development of a strategic scale would be able to ensure the vitality of habitats and/or landscapes.

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The inclusion of a policy on the design of safe and attractive streets is supported in principle. However, any design elements must be fully evidenced and justified and should take into account Warwickshire County Highways Authority design standard, in particular where departure from those standards could affect the future adoption of development proposals.

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Q-D2: Please select all options which are appropriate for South Warwickshire In principle, the introduction of design codes and design guides would accord with national policy where NPPF paragraph 129 states that "Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale…"(our emphasis). The Government also has a National Design Guide and National Model Design Code which are in place to guide the design of development. Lone Star Land Ltd. therefore agree that the principle of Design Codes/Design Guides to guide development is acceptable. However, the development of such policies should be justified in terms of the specifics of the development that would justify the introduction of a site-specific design code/guide that goes beyond the detailed guidance in the National Design Code. This is likely only to be necessary for larger strategic sites such as settlements such as Deppers Bridge. In these circumstances design codes can be a valuable tool to provide high quality development. Paragraph 129 of the NPPF states that design codes should allow developers to contribute towards within the design guide/code process. Lone Star Land would support a policy which would enable collaborative working with local councils to positively produce a shared vision for a new settlement that is deliverable and viable in South Warwickshire at Deppers Bridge. This work may be undertaken in parallel with the preparation and submission to support an application for the development of the new settlement site. In addition, design codes/guides are not mandatory as set out in the NPPF, and the desire for such a policy tool to be utilised should not hold up development coming forward if such a tool is not in place. Further, even where introduced there needs to be some element of flexibility to allow developments to come forward even if they are not fully strictly in accordance with all criteria. Site specific matters and failure to comply with all criteria, where the alternative would not have detrimental impacts should not be used as a blanket reason to refuse development. Q-D3: Please select all options which are appropriate for South Warwickshire There is no in principle objection to a potential policy on housing densities. However, a blanket approach to density is unlikely to be effective. Rather, a site specific/flexible approach to density should be considered. A minimum density may be set out, but where additional development could assist the delivery of services and facilities, sites could beencouraged to exceed this minimum density where it could be done in a manner consistent with other development plan policies. For large scale allocations, a target average density may be appropriate to allow for flexibility across the wider site. This strategy could also be linked to the use of site-specific design codes. The development of a new settlement at Deppers Bridge would provide an opportunity to develop more homes within mixed-use real places at ‘gentle density’, thereby creating streets, squares and blocks with clear backs and fronts. By ‘gentle density’ this means where homes are more closely placed in the townscape than at present, but without negating the environmental benefits of lower emissions, frequent small-scale greenery and pleasant views across streets patrolled by sunlight. In alignment with the aspirations of Central Government, as outlined in the published reports produced by the Building Better, Building Beautiful Commission, local policies should encourage ‘gentle density’ which could at a strategic level be pursued through design codes.

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Q-W3: Please select the option which is most appropriate for South Warwickshire Option W3a: Include an overall policy on health. In order to align with government policy, it is considered that there will be necessity for the plan to have regard for a policy relating to health. The NPPF states that in order to achieve sustainable development the planning system has three objectives. Paragraph 8(b) refers to the social objective which includes the provision of services that reflect current and future needs of communities in respect of health. Paragraph 20(c) also states that Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for community facilities including health infrastructure. Engagement with relevant stakeholders, specifically the NHS trust and associated commissioning groups is essential at an early stage to understand the necessary infrastructure provisions required to accommodate growth and development within the plan period. Requests relating to the delivery of specific physical infrastructure should be clearly identified in the Infrastructure Delivery Plan and should be identified and considered within the plans emerging viability evidence base and relevant assessments.

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Q-T1: Please select all options which are appropriate for South Warwickshire Option There are significant benefits of utilising 20-minute neighbourhood principle whereby people are able to meet their regular day to day needs within reasonable walking distance of their home or workplace. To ensure the success of the concept of 20-minute neighbourhoods a clear, holistic definition or vision will need embedding in policy. Any relevant policies will need to be specific enough to provide confidence for decision makers but also a degree of flexibility to allow its application across a range of places with different context, for example across urban and rural areas within the districts. It is considered that this policy approach follows the objective of sustainable development and aligns with the overarching principles of this Local Plan and could be achieved within a new settlement proposal at Deppers Bridge. Issue T2: Sustainable transport accessibility across South Warwickshire Lone Star Land support the provision a general policy relating sustainable transport which requires the necessary infrastructure and services place to allow both existing and new communities to become more sustainable and to have much easier access to key services and facilities. The proposed new settlement at Deppers Bridge would allow for positive transport and housing impacts, delivering sustainable development that encourages the use of alternative modes of transport other than the private car and which allows for development with access to a range of services and facilities.