Issue and Options 2023

EXECUTIVE SUMMARY 1.1 These representations have been prepared by Boyer on behalf of Kingacre Estates Ltd (‘Kingacre’), in response to the Regulation 18 ‘Issues and Options’ consultation, prepared by Stratford-on-Avon District Council (‘SADC’) and Warwick District Council (‘WDC’) (‘the Councils’) for the emerging South Warwickshire Local Plan Part 1 (‘SWLP’). 1.2 Kingacre hold a specific land interest within Stratford-on-Avon District, known as the Land Adjacent to Grange Cottages, Hardwick Road (‘the site’). The site has previously been assessed in SADC’ Strategic Land Availability Assessment (‘SLAA’) under SLAA reference PM.08. These representations are aligned with this land interest and address topics within the SWLP consultation, and its supporting evidence base, accordingly. 1.3 The purpose of these representations is to assist the Councils in formulating an approach within the emerging SWLP plan-making process that is both consistent with national planning policy and the tests of soundness. 1.4 General support is provided to the overall objectives identified in the SWLP and detailed commentary is provided in relation to the appropriate Spatial Strategy for the District. However, it is considered that there are several flaws and omissions within the SWLP and its evidence-base at this stage, which are detailed within these representations. 1.5 The SWLP Issues and Options consultation proposes that the emerging plan should meet, as a minimum, the identified housing need arising within the plan’s area. Furthermore, the Plan affirms the duty of the Districts to meet a proportion of the residual unmet housing need arising from nearby authorities; in particular, need arising from within the Greater Birmingham & the Black Country HMA and the Coventry & Warwickshire HMA. 1.6 Significantly, the SWLP proposes departure from the Government’s prescribed Standard Methodology, replacing the 2014-based household projections with trend-based projections utilising up-to-date data from the 2021 Census. Consequently, both districts’ annual Local Housing Need figure increases markedly, reflecting demographic trends over the last decade. 1.7 Kingacre supports the Councils approach. Kingacre considers that the assessment of Local Housing Need detailed within the SWLP, based on the Councils’ Housing and Economic Development Needs Assessment (‘HEDNA’) (2022), adequately reflects current and future demographic trends and market signals, which should therefore be considered a sound approach as set out in planning practice guidance1 . 1.8 Furthermore, Kingacre supports the Councils’ commitment to accommodate the identified local housing need for the Districts in full, in addition to an appropriate amount of unmet need arising from nearby authorities in accordance with the Duty-to-Cooperate (‘DtC’). Such an approach would maintain the existing commitment, made in both SADC’s and WDC’s current adopted district plans, and would support housing delivery in the wider region in accordance with the Government’s commitment to significantly boost the supply of housing, ensuring minimum housing needs are met. 1.10 Notwithstanding the five Spatial Strategy Options identified in the SWLP, the Councils’ evidence-base identifies limited further growth potential in the most sustainable urban areas of South Warwickshire: Leamington Spa, Stratford-on-Avon, and Warwick, alongside the settlements covered by the West Midlands Green Belt and the Cotswolds National Landscape AONB. 1.11 To assist in meeting the District’s significant housing need, we recommend the allocation of Land Adjacent to Grange Cottages, Hardwick Road, Priors Marston (‘the site’) for up to 25 new homes within the emerging SWLP. The relatively unconstrained nature of the District’s central and eastern areas, in combination with the series of Local Service Villages, provides that these areas remain appropriate to accommodate a significant proportion of the identified housing need. The land at Priors Marston is available and well-placed to make a modest though nonetheless valuable contribution toward this. 1.12 To support the vitality of the Districts’ villages, including Priors Marston, and deliver muchneeded affordable housing in rural areas, it is crucial that the Councils support the sustainable growth of these areas and the villages. 1.13 To this end, Kingacre supports the identification of Spatial Strategy Option 5: Dispersed Approach as a suitable spatial strategy for South Warwickshire. Priors Marston comprises an unconstrained settlement that can accommodate sustainable growth during the plan period. The Land Adjacent to Grange Cottages, Hardwick Road, is well-positioned to make a valuable contribution to meeting the District’s development needs and support the delivery of much needed new market and affordable homes. 1.14 The Site is in a sustainable location, within practical walking and cycling distance of the range of services and facilities provided in the Village, and benefits from good access to nearby main settlements including Daventry and Leamington Spa. There are no significant constraints to the development of the Site which could not be effectively mitigated, meaning the site is capable of providing up to 25 high-quality new homes. 1.15 Kingacre confirm the Site is available for development immediately. The Site comprises a suitable location for development, current Development Plan constraints aside, and is achievable for the type of development proposed, providing a realistic prospect that 25 new homes (comprising market and affordable) can be delivered within the first five years of the emerging plan period. 1.16 Accordingly, Kingacre promote the allocation of the site for approximately 25 new homes in the emerging South Warwickshire Local Plan. INTRODUCTION 2.1 This representation is made by Boyer, on behalf of Kingacre Estates Ltd (‘Kingacre’) to act on their behalf in respect of the ongoing promotion of Land Adjacent to Grange Cottages, Hardwick Road (‘the site’) for residential development. A Site Location Plan is provided at Appendix 1. 2.2 These representations relate to the tests of soundness set out at paragraph 35 of the NPPF; namely, whether the emerging South Warwickshire Local Plan (‘SWLP’) is: a) Positively prepared – providing a strategy which as a minimum seeks to meet the area’s objectively assessed needs. b) Justified – provides an appropriate strategy, taking into account reasonable alternatives and based on proportionate evidence. c) Effective – deliverable over the plan period and based on effective joint working. d) Consistent with national policy – enabling the delivery of sustainable development. 2.3 At this early stage of plan-making, it is important that Stratford-on-Avon and Warwick District Councils (‘the Councils’) pursue an approach that is consistent with national policy, effective, justified, and positively prepared. These representations comprise our recommendations to assist the Council in achieving such an approach as emerging plan progresses toward adoption. 2.4 This representation should be considered in combination with previous representations submitted to Stratford-on-Avon District Council by Kingacre in relation to the ‘Site Allocations Plan Regulation 18 Revised Preferred Options’ consultation, which ran from 16 June to 29 July 2022, and the ‘SAP Regulation 18 Preferred Options’ consultation, undertaken in late 2020. Policy Context 2.5 Stratford-on-Avon District Council (‘SADC’) adopted the Core Strategy (2011 – 2031) on 11 July 2016 and Warwick District Council (‘WDC’) adopted the Local Plan (2011 – 2029) in September 2017. Together, the adopted plans set out the spatial strategy to meet development needs across South Warwickshire District up to 2029 and 2031 respectively. 2.6 The Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended) requires local planning authorities to review local plans at least once every 5 years from their adoption date. This is intended to ensure that planning policies remain relevant and able to effectively meet the needs of the local community. The SWLP, which is the subject of this Regulation 18 consultation, represents the outcome of these review processes; with SADC and WDC committing to working together to prepare a new local plan for the broader South Warwickshire area. The Issues and Options plan sets out a broad vision for South Warwickshire up to 2050, identifies the various issues associated with achieving this vision, and outlines several options to address each of those issues, including the overall strategy for the pattern, scale, and design quality of places within South Warwickshire. 2.8 Kingacre supports the Councils’ commitment to prepare a new Local Plan for the South Warwickshire area. Land Adjacent to Grange Cottages, Hardwick Road, Priors Marston 2.9 Land Adjacent to Grange Cottages, Hardwick Road, Priors Marston (‘the site’) comprises approximately 1.8 hectares of land toward the southern edge of Priors Marston village. The site lies to the south of Hardwick Road and to the west of Byfield Road, within the parish of Priors Marston. The site currently comprises an open field, bordered by dense hedgerows with some intermittent tree cover, wrapping around a small collection of dwellings (including Grange Cottages) to the north. 2.10 Stratford-on-Avon District Council assessed the site as part of the Strategic Housing and Economic Land Availability Assessment (2020) (‘SHELAA’) process, under Site ID number PM.08. The site is determined by the Council to be available for development, in accordance with the NPPF and Planning Practice Guidance (PPG). 2.11 However, conclusions have been arrived at that the site is neither suitable nor achievable for development at this time. Kingacre strongly disagree with the conclusion that the site is neither achievable nor environmentally suitable for development within the plan period. In Section 6 of these representations, the site is demonstrated to not only be both suitable and achievable for development, but preferable to alternative potential site options already considered by SADC at the Village. 2.12 The site is within a sustainable location and there are not considered to be any significant constraints to development of the site for residential dwellings within the plan period. The proposed development of up to 25 new homes would contribute toward the Districts significant identified housing need, in addition to providing a range of further benefits: including much-needed affordable housing, biodiversity improvements, and improvements to local community facilities. 2.13 The site is available for development now, offers a suitable location for development, and is achievable with a realistic prospect that housing can be delivered within the next five years. As such, the site should be considered favourably under the terms of the NPPF and consequently allocated for residential development in the emerging South Warwickshire Local Plan. CONCLUSION 7.1 The draft South Warwickshire Local Plan sets out how Stratford-on-Avon and Warwick District Councils propose to, as a minimum, meet identified local housing needs arising within the South Warwickshire Plan area. Furthermore, the Plan affirms the duty of the Districts to meet a proportion of the residual unmet housing need arising from nearby authorities; in particular, need arising from within the Greater Birmingham & the Black Country HMA and the Coventry & Warwickshire HMA. Kingacre fully supports this positive and proactive approach being taken by the Councils 7.2 Significantly, the SWLP proposes departure from the Government’s prescribed Standard Methodology, replacing the 2014-based household projections with trend-based projections utilising up-to-date data from the 2021 Census. 7.3 Kingacre supports this approach and supports the Councils’ commitment to accommodate housing needs in fully. This would maintain the commitment made within the adopted spatial strategies of each district and would support housing delivery in the wider region in accordance with the Government’s commitment to significantly boost the supply of housing. 7.4 The Issues and Options consultation presents five reasonable alternative Spatial Growth Options which could be implemented to direct new development within South Warwickshire over the plan period. Notwithstanding the problematic evidence-base supporting the assessment of these alternative Spatial Growth Options, Kingacre welcomes the identification of Spatial Growth Option 5 – Dispersed and recommends that, given further work to refine the option, it could represent an appropriate spatial strategy for South Warwickshire of itself. Or as a component part of any other overarching strategy taken to ensure the towns and villages across the SW area are supported, and sustainable planned growth is facilitated over the plan period – including delivery of much needed affordable homes. 7.5 The relatively unconstrained nature of South Warwickshire’s central and eastern areas, in combination with the presence of a series of sustainable, small-and-medium sized villages, provides that the area remains appropriate and capable of accommodating a significant proportion of the identified housing needs. 7.6 To this end, Kingacre recommends the identification of the Land Adjacent to Grange Cottages, Hardwick Road, Priors Marston, as being suitable for allocation within the next iteration of the SWLP, as part of any appropriate spatial strategy for the SW area. Priors Marston comprises an unconstrained settlement that could accommodate a reasonable level of growth during the plan period. The Land Adjacent to Grange Cottages, Hardwick Road, is well-positioned to make a very reasonable contribution to meeting development needs. The site is in a sustainable location, within practical walking and cycling distance of the range of services and facilities provided in the Village. The site benefits from good access to nearby main settlement areas, including Daventry and Leamington Spa, and good access to mainline train services at Banbury and Leamington Spa. There are no significant constraints to the development of the site, which could provide up to 25 high-quality new homes. 7.8 On behalf of our client, we can confirm the site is available for development now, represents a suitable location for development, and that development of the site is achievable with a realistic prospect that housing can be delivered within the first five years of the draft plan period. The site is deliverable and should be favourably considered for allocation in the next iteration of the SWLP. 7.9 We look forward to continuing to work with Stratford-on-Avon and Warwick District Councils, Priors Marston Parish Council, and the village’s community to provide much-needed new housing. 7.10 We hope these representations are of assistance in taking the plan forward. Should you require any further clarification on the issues raised in our comments please contact me.

Yes

No answer given

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Q-H1-1: This section details Kingacre’s position with regard to the scale of housing need within South Warwickshire. In determining the appropriate Housing Requirement for the South Warwickshire Plan, the discussion covers three core themes: a) the calculation of Local Housing Need, b) unmet need arising outside of South Warwickshire & the Duty-to-Cooperate, and c) the need for affordable housing. Calculating Local Housing Need 3.2 In considering ‘Issue H1: Providing the right number of new homes’, the SWLP identifies that the strategic policies contained within the emerging local plan should be informed by an assessment of Local Housing Need (‘LHN’). 3.3 After setting out the Government’s Standard Method for calculating LHN, the SWLP identifies that the calculation utilises 2014-based population projections, which are considered to be problematic for several reasons. To address these issues, the SWLP proposes to employ a revised version of the Standard Method, based on more up-to-date demographic (provided in the Census 2021 data) and market data, to calculate the housing need for the area. 3.4 In accordance with national planning practice guidance (‘PPG’), the Standard Method of calculating Local Housing Need for the Coventry and Warwickshire Housing Market Area (‘HMA’) results in an identified need of 5,554 dwellings per annum (‘dpa’). Subsequently, the SWLP identifies, at Table 9, that the LHN figure for Stratford-on-Avon district is 564 dpa, whereas for Warwick district it is 675 dpa. 3.5 However, the SWLP proposes to implement an alternative assessment of housing need, based on the recently published Housing and Economic Development Needs Assessment (‘HEDNA’) (2022), which covers the Coventry & Warwickshire Housing Market Area. Based on an assessment of demographic and market data over the previous decade, the HEDNA provides trend-based projections that identify a need for 868 dpa for Stratford-on-Avon and 811 dpa for Warwick. These are set against reductions in the assessed need for other areas within the sub-region; in particular, for Coventry. 3.6 Significantly, the ‘trend-based’ assessment of housing need derived from the HEDNA provides for an increased annual housing need figure for both districts; an additional 304 dpa in Stratford-on-Avon district and 136 dpa for Warwick district, over the plan period. This represents a significant uplift when compared with the 2014-based projections. Planning Practice Guidance (‘PPG’) provides that: Where a strategic policy-making authority can show that an alternative approach identifies a need higher than using the standard method, and that it adequately reflects current and future demographic trends and market signals, the approach can be considered sound as it will have exceeded the minimum starting point2 . 3.8 PPG confirms that the proposed departure from the 2014-based household projections represents a departure from the ‘Standard Method’. However, Kingacre considers that the approach detailed within the SWLP, consisting in the adoption of the ‘trend-based’ housing need figure derived from the HEDNA (2022), represents a sound alternative approach as per the requirements of the PPG set out above. 3.9 PPG clarifies that exceptional circumstances are required to justify an alternative approach where the approach results in a lower housing need than that identified using the standard method. However, given that the proposed approach results in a higher figure than the standard method calculation does for both individual district areas, this is not required. 3.10 In summary, Kingacre supports the proposed trend-based approach to assessing housing need within the South Warwickshire area, for the reasons set out above. Furthermore, Kingacre agree that the evidence presented within the HEDNA (2022) represents a reasonable basis for identifying future levels of housing need across South Warwickshire. Sustainability Appraisal of Alternative Policy Options 3.11 The Sustainability Appraisal (‘SA’) prepared to support the Issues and Options consultation assesses the two alternative housing numbers identified through the discussion above; namely, the 2014-based and HEDNA-based LHN figures: 1. Option 1 – Census 2021-based ‘HEDNA’ calculation: 868 dpa in Stratford-on-Avon and 811 dpa in Warwick. Combined total of 1,679 dpa. 2. Option 2 – 2014-based ‘Standard Method’ calculation: 564 dpa in Stratford-on-Avon and 675 dpa in Warwick. Combined total of 1,239 dpa. At paragraph N31, the SA concludes that: Pursuing either of the options would result in a major positive impact on SA Objective 9 (Housing) as it is expected that the proposed housing numbers would largely cater to the housing needs of residents, including delivering affordable homes, student accommodation, older persons accommodation, specialist accommodation and self and custom build housing, along with the accommodation needs of gypsy and traveller and travelling showpeople communities. 3.13 However, the SA notes that taking forward the LHN figure derived through the HEDNA should more accurately represent local housing needs than the Standard Method-derived figure, for the reasons set out previously in these representations. The SA concludes therefore that implementing Option 1 as the housing requirement for the SWLP should assist in meeting the housing needs of the local communities more successfully. 3.14 Beyond the additional benefit that Option 1 provides toward SA Objective 9 (housing), the SA concludes that the performance of either Option 1 or Option 2 is relatively indistinct in relation to the remainder of the SA objectives. Kingacre supports this conclusion.

Yes

Unmet Housing Need Arising from Outside South Warwickshire 3.15 As the SWLP notes, neither the Standard Method of calculating local housing need, nor the revised trend-based calculation detailed within the HEDNA (2022), take account of the provision of unmet need arising from outside of South Warwickshire; namely, from within the Greater Birmingham and Coventry & Warwickshire Housing Market Areas. 3.16 South Warwickshire lies fully within the Coventry and Warwickshire HMA, and Stratford-onAvon district also lies within the Greater Birmingham and Black Country HMA. The HEDNA (2022), published as part of the plan’s core evidence-base, affirms the conclusion that both the Greater Birmingham and Black Country HMA and the Coventry and Warwickshire HMA remain appropriate to the determination of housing need for South Warwickshire. In particular, the HEDNA (2022) states that Stratford-on-Avon District: ‘...will therefore need to consider unmet needs from Birmingham in setting housing targets within their respective local plans alongside any unmet needs from within the Coventry & Warwickshire HMA’ 3 . 3.17 Further supporting this conclusion, the draft plan clarifies that officer-level discussions have taken place between the relevant Councils that comprise the Greater Birmingham and Black Country HMA and the Coventry and Warwickshire HMA, as part of the Duty-to-Cooperate, to discuss the position regarding unmet need across the sub-regions. 3.18 The SWLP confirms that there are four sources of unmet housing need that may have implications for South Warwickshire: 1. Shortfall from the Greater Birmingham and Black Country HMA to 2031 2. Shortfall from the Greater Birmingham and Black Country HMA to 2050 3. Shortfall from Coventry to 2050, and 4. Shortfall from other HMA areas to 2050. 3.19 Together, these sources are expected to provide a substantial level of unmet housing within the region that needs to be accounted for within the South Warwickshire Plan. 3.20 In Stratford-on-Avon’s emerging Site Allocations Preferred Options (June 2022) Development Plan Document, Proposed Policy SAP.4 identifies several sites, with a total capacity of approximately 380 homes, which will be released to provide Stratford-on-Avon District’s contribution to meeting the shortfall in dwelling provision in the Greater Birmingham & Black Country HMA. Further to this provision of unmet housing need up to 2031, Stratford-on-Avon District will need to take account of Birmingham City Council’s Local Plan Review to 2042, which has identified a shortfall in housing of 78,415 homes in the Council’s recent Issues and Options consultation4 . 3.22 In addition to this, as noted within the SWLP, further unmet need may also be identified as arising from the other Black Country authorities. To address the shortfall arising within the Greater Birmingham and Black Country HMA, South Warwickshire (in particular Stratford-onAvon district) should seek to contribute as significant a proportion of the existing identified unmet need as reasonably practicable. Furthermore, the SWLP confirms that, even considering the redistribution of housing resulting from the trend-based projection, Coventry is unlikely to be able to accommodate all of its housing needs (1,964 homes per annum), and as such a shortfall may exist to 2050, which South Warwickshire will need to do its part in addressing

4 In meeting the substantial level of unmet need arising from outside of South Warwickshire (‘SW’), the SWLP identifies that preference should be given to accommodating that unmet need within the appropriate district relating to the source of need arising. For example, unmet need arising from the Greater Birmingham and Black Country HMA should be met within Stratford-on-Avon district as far as is reasonably practicable. 3.25 However, the western extent of the SW area, which is closer to where the unmet need arises, remains relatively constrained and is considered unlikely to represent the preferred location for development once these constraints are considered in the development of the spatial strategy. To assist in meeting this need, the SWLP should consider a dispersed approach to development in South Warwickshire, reflecting the existing historic pattern of development in the region and supporting the vitality of rural communities. 3.26 In summary, Kingacre supports the Councils’ commitment to meeting South Warwickshire’s minimum local housing need in full (whether calculated using the 2014-based population projections or the HEDNA trend-based projections), alongside an appropriate proportion of the unmet need arising from outside South Warwickshire. 3.27 The Councils’ constructive engagement with their neighbouring authorities toward understanding the position regarding unmet need within the HMA and, consequently, toward establishing the extent to which the district could appropriately contribute toward meeting that unmet need, is supported. 3.28 Kingacre recommends that the opportunity presented within the South Warwickshire plan, to contribute as significant a proportion of the identified unmet need as reasonably practicable, is taken forward when considering the appropriate Housing Requirement for the Districts. Section 33a of the Planning and Compulsory Purchase Act 2004 requires local planning authorities to co-operate with other authorities, the relevant County Council, and prescribed bodies or other persons, in relation to the preparation of the Plan. The Duty requires the Council to engage constructively, actively, and on an on-going basis, in the preparation of the Plan, in so far as it relates to a strategic matter. A strategic matter includes the sustainable development and use of land that has, or would have, a significant impact on at least two planning areas. 3.30 Government policy, set out in paragraph 26 of the NPPF, states that effective and ongoing working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. It goes on to state, in particular, that joint working should help determine where additional infrastructure is necessary, and whether development needs that cannot be met wholly within a particular plan area could be met elsewhere. Co-operation, therefore, is about maximising the effectiveness of plan preparation. 3.31 As noted previously, Kingacre welcomes the Councils’ commitment to meeting unmet need as part of this process. However, upon closer inspection, published evidence of regular ongoing meetings with the above bodies does not appear to be available. 3.32 In relation to the Coventry & Warwickshire HMA, the archive of meetings5 shows that there has not been a meeting since November 2019, and that the preceding meeting that had taken prior to this was in November 2018. Prior to this November 2018 meeting, meetings appear to have been taking place 3 – 4 times per annum. 3.33 With regard to the Greater Birmingham & Black Country HMA, the published evidence comprises a series of Housing Need and Housing Land Supply Position Statements, issued in 2018 (both February and September), September 2020, and the most recent in December 2021. 3.34 The 2020 Statement notes that ‘Detailed consideration of where need can be met is ongoing across the authorities and refers to the initial piece of work undertaken in 2018 known as the Greater Birmingham Strategic Growth Study’. The Position Statements suggest and demonstrates monitoring of need and supply is indeed taking place. However, there appears to be no published evidence suggesting that active and ongoing co-operation resulting from the monitoring has been and continues to be taking place at regular intervals. Given that one of the main purposes of the document is to ensure the ability to specifically respond to and accommodate unmet housing need generated outside of the SW plan area (but within intersecting HMAs), it would be helpful for the Council to provide further information on the ongoing work and efforts to ensure cross-boundary matters are being proactively and positively taken into account now. 3.36 The Councils will be aware that examining Inspectors have recommended the withdrawal of Local Plans in a number of authorities due to failings in implementing the duty-to-cooperate, including in Sevenoaks District and Buckinghamshire Councils. In recommending these withdrawals, the Inspectors have specifically cited failings regarding the matter of unmet needs in this regard. 3.37 To ensure that the SWLP is considered to be positively prepared and effective, it is recommended that; in addition to the Council continuing to pursue active and constructive engagement with its neighbouring authorities on strategic matters, it is equally as important that the Councils formally publish evidence demonstrating the ongoing engagement at the earliest opportunity. Ideally, this should be undertaken in advance of the next stage of consultation on the SWLP, to ensure it can be reviewed and examined in a timely fashion. The Need for Affordable Housing 3.38 South Warwickshire faces a significant need for affordable housing over the plan period, as affirmed within the SWLP. The conclusions of the HEDNA (2022) further demonstrate the extent of this need in the plan area, finding that there is a need within South Warwickshire for approximately 1,386 affordable homes per annum up to 2050. Specifically, the HEDNA (2022) clarifies that the need for affordable homes (per annum) is 547 for Stratford-on-Avon District and 839 for Warwick District6 . 3.39 Furthermore, the HEDNA (2022) identifies that: “In setting housing targets in individual local plans, the affordable housing evidence is also relevant. In the northern part of the sub-region in particular – in North Warwickshire and Nuneaton and Bedworth - this supports the case for considering, as part of the planmaking process, higher housing provision than shown in Table 15.5 in order to boost the delivery of affordable housing.” 7 . 3.40 The identified need for affordable homes in South Warwickshire, of 1,386 dwellings per annum, comprises approximately 80% of the overall identified housing need for the plan area of 1,792 dpa. In Stratford-on-Avon, the identified need for affordable housing relates to approximately 63% of the overall housing need for the District. The situation is even more challenging in Warwick, where affordable housing need represents 103% of the equivalent identified housing need for the plan period. To deliver the number of affordable homes that are needed in South Warwickshire, the plan would be required to identify a housing supply of approximately 3,465 dpa (assuming a policy requirement of 40% affordable housing provision is taken forward). This represents almost double the proposed identified annual housing requirement, which itself represents a substantially increased rate in relation to the 2014-based Local Housing Need figure. 3.42 Given that the identified annual need for affordable housing provision comprises approximately 80% of the overall annual local housing need, there is a clear case for examining the extent to which further growth could be accommodated within the SW area to promote the delivery of greater affordable housing. 3.43 Furthermore, there is a considerable need to support affordable housing delivery within South Warwickshire’s rural communities. For example, Stratford-on-Avon District’s own evidence-base confirms that there have been no new affordable homes delivered within Priors Marston village over at least the previous decade. 3.44 Clearly, if the services and amenities of Local Service Villages, such as Priors Marston, are to remain viable up to 2050, there is a need to plan for and deliver new market and affordable homes at the Village within the plan period. The Land Adjacent to Grange Cottages, Hardwick Road, presents the most suitable opportunity to provide this within the plan period.

Yes

The Sustainability Appraisal omits analysis of a significant number of sustainably located, smaller settlements within the district area, such as Priors Marston, which has a good range of facilities within the village itself and good vehicular access options to nearby larger towns. It is recommended that further work is undertaken prior to the publication of the next iteration of the emerging South Warwickshire Local Plan, to assess the various benefits provided by locating residential development within these Local Service Villages.

Q-S4.1: + Q-S4.2: The NPPF8 requires that strategic policies should set out an overall strategy for the pattern, scale, and design quality of places, making sufficient provision for housing and other development needs. Kingacre welcomes the Councils’ consideration of several alternative options for an appropriate spatial strategy for South Warwickshire up to 2050. 4.2 The Issues and Options consultation presents five alternative spatial options, which are evaluated within the Sustainability Appraisal prepared to support the plan. A further two ‘hybrid’ options are discussed within the Plan. The five alternative spatial options discussed within the SWLP comprise: • Option 1: Rail Corridors • Option 2: Sustainable Travel • Option 3: Economy • Option 4: Sustainable Travel and Economy • Option 5: Dispersed 4.3 Notably, the Issues and Options consultation (alongside the Sustainability Appraisal) consider the five alternative spatial options within a ‘Policy Off’ approach. This approach is problematic, as it is not possible to assess the deliverability of the various spatial options, as the availability, suitability, and achievability of the identified potential development locations has not been confirmed. 4.4 Furthermore, the alternative spatial options have not been assessed in accordance with their potential relationship with important planning designations, such as the West Midlands Green Belt and the Cotswolds National Landscape Area of Outstanding Natural Beauty (‘AONB’). Considering the protection afforded to each of these designated areas within the NPPF9 , notwithstanding adopted policy within the SW area, this is considered to be a serious limitation in the analysis which needs to be revisited. 4.5 Notwithstanding these limitations, Kingacre welcomes the identification of Spatial Strategy Option 5 – Dispersed. It is considered that, once further work has been undertaken to refine this general spatial strategy option, it would represent a suitable basis for the distribution of development within South Warwickshire up to 2050. The benefits of the approach are set out below, but comprise four core themes: • Lack of exceptional circumstances to justify release of land from the Green Belt, • Protection of the Cotswolds National Landscape AONB, • The availability and suitability of land within the SW area for development, and • Supporting the Viability and Vitality of the Rural Communities. The SWLP identifies that South Warwickshire demonstrates an historically dispersed settlement pattern and is home to a significant number of existing settlements of varying sizes. Recognising this dispersed settlement pattern, particularly within Stratford-on-Avon, the District’s adopted Core Strategy (2011 – 2031) implements a spatial strategy ‘...based on a pattern of balanced dispersal, in accordance with the distinctive character and function of the wide range of sustainable locations across the District’ 10 . 4.7 Furthermore, the emerging Site Allocations Plan (‘SAP’) for the District commits to implementing ‘...the basis of the distribution of development established in Policy CS.15 of the Core Strategy’. Kingacre welcomes the Council’s recognition that an appropriate spatial strategy for the SW area should continue to implement the ‘pattern of balanced dispersal’ set out within Policy CS.15 (Distribution of Development) of the adopted Core Strategy. 4.8 Together, the adopted spatial strategies for Stratford-on-Avon and Warwick Districts direct development toward the most sustainable settlements, whilst recognising the limited capacity of the main settlements to accommodate the full housing and economic needs of the area. Kingacre welcomes this approach and recommends that the Councils’ continue to implement a spatial strategy for South Warwickshire based on this sustainable and dispersed approach. 4.9 The Councils’ Urban Capacity Study (2022) affirms that South Warwickshire is reliant on the development of greenfield land to meet its housing needs; noting: ‘...the study has established that it is unlikely to be possible to meet currently development needs without significant greenfield development’ 11 . 4.10 Given the extent of the existing committed development within South Warwickshire (which includes both permitted and allocated development sites), much of which was directed to the most sustainable locations through the adopted spatial strategies, it is clear that there is limited further capacity for development within the most sustainable locations in the area. 4.11 The Urban Capacity Study (2022) identifies that, of the 30,750 new homes required in South Warwickshire within the plan period, there is an identified potential supply of up to 19,950 new homes, of which only 6,145 new homes are identified as being capable of development within the Districts existing urban areas12 . Consequently, despite the Councils’ best efforts to maximise the utilisation of brownfield land, there will clearly remain a substantial need to allocate housing on greenfield sites across the plan area. The West Midlands Green Belt & the Cotswolds National Landscape AONB 4.12 Outside the main settlement areas in South Warwickshire, two significant planning designations limit the development potential of land in certain areas of the SW area: namely, the West Midlands Green Belt and the Cotswolds National Landscape AONB. 4.13 A significant proportion of the land that is considered, by the SWLP, to be within the most sustainable locations in South Warwickshire (i.e., the north-western extent) is covered by the West Midlands Green Belt, including land north-west of Stratford-on-Avon, Warwick, and Royal Leamington Spa. Paragraph 140 of the NPPF requires that: Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified. 4.14 Given that the Councils’ have not yet undertaken the proposed Green Belt Study, to support a Green Belt review, the Issues and Options consultation is not capable of making an assessment as to whether such exceptional circumstances exist to justify the insetting of land from the Green Belt for the purposes of housing delivery. It is considered that, given the significant extent of land within the SW area that is not within the Green Belt, and as such able to accommodate housing development, exceptional circumstances do not exist to release land from the Green Belt. 4.15 On this basis, it would be difficult to conclude that any of the alternative spatial strategies would be appropriate as currently formulated. Following further technical work undertaken by the Councils’ to derive the availability, suitability, and achievability of potential development sites across the SW area, it would be possible to assess the spatial strategy options with a greater degree of accuracy. 4.16 To this end, Kingacre are able to confirm that the Land Adjacent to Grange Cottages, Hardwick Road, is available, suitable, and achievable for residential development within the next five years, in accordance with planning practice guidance. Supporting the Vitality and Viability of Rural Villages 4.17 In accordance with the discussion set out previously, Kingacre recommend that any spatial strategy for South Warwickshire includes the allocation of land to provide sustainable development at different levels across the current settlement hierarchy. 4.18 Such an approach would align with the general principle of Spatial Strategy Option 5, which would continue the delivery of the existing adopted spatial strategy in the Districts to support the sustainable growth of the larger settlements, whilst providing sufficient growth for the abundance of medium and smaller-sized villages in the SW area to support their sustainable growth. This strategy would also accord with paragraph 78 of the NPPF, which states: “Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.” 4.20 Reductions in average household sizes, alongside low housebuilding rates, present a challenge for rural communities. Without an appropriate uplift in the level of development in these locations, there is a risk that local services in such areas would become unviable, undermining the vitality and sustainability of the rural villages across SW plan areas. 4.21 In addition to helping maintain the vitality of villages, medium and smaller-scale development in appropriate locations will assist with the housing delivery, both in the short-term and over the life of the SWLP plan period. Paragraph 68 of the NPPF states that local planning authorities should promote a good mix of sites, with small and medium sites often able to be built out relatively quickly. This is supported by updated research by Lichfields, which reports that schemes of 500 dwellings or more take on average between 5 to 8.4 years from the validation of an application for outline planning permission to the delivery of the first new home. The consequence being larger sites typically only substantively contribute to new housing delivery later on in the plan’s lifespan. 4.22 As such, Kingacre recommends that the Council should be seeking to allocate sufficient small and medium sized sites to maintain housing delivery throughout the plan period. Furthermore, Kingacre encourages the Council to seek to secure efficient delivery of new homes from any future proposed site allocations, i.e., maximising development potential whilst ensuring appropriate local character and context are respected. This would be particularly important for the smaller and medium-sized sites, which would help to ensure the SW area meets its housing needs from the shorter-term. Q-S8.1: Yes, small-scale development is essential within rural communities to ensure the continued vitality and viability of the numerous smaller villages within South Warwickshire. Q-S8.2: Small-scale development is essential within rural communities to ensure the continued vitality and viability of the numerous smaller villages within South Warwickshire. What constitutes appropriate development will depend upon the specific circumstances of each site, it is therefore considered inappropriate to apply an arbitrary number to the maximum number of homes considered to be appropriate on such sites. Furthermore, given a limit of 10 dwellings per site, it would be unlikely that much (if any) affordable housing would be provided on development sites in rural communities if this threshold was applied. Given the stark need for affordable housing, particularly within smaller villages, the implementation of this threshold is considered to be inappropriate and larger sites should be considered appropriate depending on the context of that site. It is recommended that small-scale development at smaller villages should be assessed on a case-by-case basis.

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Q-S5.2: Given the comments set out previously, it is not considered to be reasonable to draw informed conclusions at this stage, given that there is no available information relating to the availability, suitability, and achievability of the broad locations identified for potential new settlements. In the absence of this critical information, it is not considered to be possible to meaningfully assess the relative benefits of this alternative spatial option. The SA report notes: 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 (paragraph 7.15.1). It is recommended that, whichever spatial strategy is deemed to be preferable, the Councils undertake further work to establish appropriate development sites to support the vitality and viability of Local Service Villages, such as Priors Marston. Q-S5.3: According with the response to Q-S5.2, given the lack of available information relating to the deliverability of any of the potential locations for new settlements, it is not considered to be possible to draw meaningful conclusions relating to their appropriateness within a preferred spatial strategy. Q-S5.4: In accordance with the discussion set out above, Spatial Strategy 5 – Dispersed is recommended as the most appropriate available spatial strategy option moving forward.

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EVIDENCE BASE 5.1 The Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Issues and Options Stage (‘SA’) (2022) comprises a core component of the evidence-base underpinning the emerging Local Plan. 5.2 Together, the Councils’ have identified five reasonable alternative spatial strategy options to be considered within the SA concerning where housing and employment development should be distributed at a strategic scale across the Plan area. These five options comprise: a) Seven alternative options for New Settlement locations for large scale development of not less than 6,000 new homes and associated infrastructure, b) 32 Broad Locations which represent options for up to 2,000 homes located around the Main Settlements such as Warwick, Stratford-upon-Avon and Southam for medium scale, chiefly residential, development and associated infrastructure, and c) 22 Small Settlement Locations for intermediate scale, chiefly residential, development for between 50-500 homes in any one location, typically associated with smaller settlements and villages. 5.3 As noted within the SA, the high-level assessment of the various spatial growth options, which are not distinct from each other (with the exception of Option 5), means that their performance can only be evaluated with several caveats. Such caveats include the fact that detailed locational information is not available, meaning the ability to identify potential effects with precision is challenging. As such, the assessment within the SA cannot represent a diagnostic analysis. 5.4 Furthermore, the SA has not factored any mitigation into the analysis of the growth options, as this is best worked up once more detailed locational information is available. 5.5 The SA evaluates the five spatial options against the SA criteria at a high level, at Table 2.1. The SA concludes that Spatial Option 5 performs worst, with the remaining options being relatively indistinct. However, Kingacre disagrees with this conclusion and the discussion below sets out the areas of dispute and the reasons for the disagreement: SA1: Climate Change Commentary Agreed. SA2: Flood Risk Commentary Agreed. Flood Risk effects are challenging to evaluate given the lack of locational information. SA3: Biodiversity Commentary Greenfield land does not necessarily equate with high-quality habitats. Development in dispersed locations provides an opportunity to deliver Biodiversity Net Gain and associated improvements across South Warwickshire’s ecological network. Given the requirement to deliver a minimum of 10% Biodiversity Net Gain on all new developments, it is considered that there would be a minor positive effect. SA4: Landscape Commentary Agreed. SA5: Cultural Heritage Commentary Agreed SA6: Environmental Pollution Commentary Agreed SA7: Natural Resources Commentary Agreed SA8: Waste Commentary As noted within the SA assessment (paragraph 7.9.1), all options perform similarly as they purport to deliver the same quantity of housing. SA9: Housing Commentary Agreed SA10: Health Commentary Agreed SA11: Accessibility Commentary Agreed SA12: Education Commentary As noted within the SA (paragraph 7.13.1), The extent to which all spatial options would facilitate good education for new residents is almost entirely dependent on the specific location of development, which is uncertain at this stage. It is therefore not considered to be possible to draw conclusions on the effect of this SA Objective at this stage. SA13: Economy Commentary As noted in the SA (paragraph 5.15.1), SA Objective 13 looks at opportunities for new residents to access local employment opportunities by sustainable or active modes of transport or being situated within proximity to existing employment. The assessment of all potential development locations, including those of the small settlements (at Table 5.1), provided a net positive result within the SA, given the proximity of the locations within the target distance of several employment opportunities. It is therefore not clear how the assessment of the overall spatial strategy option could reasonably be considered to provide a negative effect. Noting the comments set out in Table 1 (above), regarding the revised appraisal of Spatial Option 5 in relation to the SA Objectives, the Council is encouraged to challenge and reassess the current appraisal set out within the SA. In doing so, the Council is invited to take account of these comments when developing the next iteration of the SA and when directing and testing the next iteration of the SWLP.