Issue and Options 2023
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New searchTable 5 lists the new settlement locations and associated estimations of emissions from the Model for each Growth Option. However, there is very little numerical difference in emissions estimations, suggesting that additional work or refinement of the model is required in order to differentiate between each Growth Option. 3.24 Nonetheless, the fact that Long Marston Airfield (New Settlement Reference E1) has been identified as a location for development within each of the five Growth Options is supported. This clearly demonstrates its suitability for growth, irrespective of which Option is adopted.
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Q-H1-1: The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014-based household projections towards a trend-based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? 4.3 The latest HEDNA suggests exceptional circumstances exist to move away from the Standard Method for determining housing need as there are alleged issues with existing census data in estimating and projecting the population in Coventry. 4.4 The HEDNA has therefore modelled new demographic projections which take account of the initial 2021 Census data releases and seeks to assess how the population can be expected to change over time by applying more up-to-date assumptions about fertility, mortality and household formation rates. The HEDNA then applies these alternative projections through the framework provided by the standard method. 4.5 The HENDA suggests that, based upon the trend-based projections, whilst the housing need in Coventry City may have reduced, the housing need for Stratford-on-Avon has increased from 564 to 868 dwellings per year (304 dwellings per year / 53.9% increase). Similarly, the need for Warwick District has increased from 675 to 811 dwellings per year (136 dwelling per year / 20.1% increase). The total housing need for both Districts (and therefore South Warwickshire) has accordingly increased from 1,239 to 1,679 dwellings per year (440 dwellings pear year / 35.5% increase). 4.6 The housing need across the Plan Period has therefore increased from 30,975 to 41,975. This figure represents the minimum need that should be planned for and does not include any unmet need from neighbouring authorities (such as Coventry or Birmingham) which may be accommodated, or any addition homes that may be planned for to meet other socio-economic objectives (such as increasing affordable housing provision – see answer to Question H2-2). 4.7 Should the authorities choose to pursue the trend-based alternative, they must accept that their housing need increases substantially and that this need must be met, as a minimum. It would not be acceptable to reduce the level of housing provided within Coventry whilst seeking to retain the need for Stratford and Warwick suggested by the Standard Method.
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Issue H1: Providing the right number of new homes 4.1 The Church Commissioners praises the Consultation Document for recognising that ‘England is experiencing a housing crisis’ and that there ‘has been a failure in the supply of affordable homes to achieve the Government’s target of 300,000 homes annually’. The Church Commissioners also supports and echoes issues identified through the previous consultation and summarised within the Consultation Document, including that there is an affordability issue within South Warwickshire. 4.2 The Church Commissioners iterates that this is remedied by building more homes over and above the minimum identified requirement and does not agree with the narrative presented within the Consultation Document that ‘building lots and lots of (unaffordable) market homes will not address this issue’. Whilst the construction of ‘unaffordable’ homes may not solve the issue, the construction of general market housing is the only realistic way to reduce house prices and make homes more affordable. This process accords with the concept of supply and demand, which forms the basis of modern economics (see further our response to Question H2-1). Q-H2-2: Please select the option which is most appropriate for South Warwickshire: The Church Commissioners acknowledges the need for affordable housing across South Warwickshire, but reiterates that market conditions and housing need should be taken into account by both Councils. Given that market conditions and housing need (both market and affordable) vary across South Warwickshire, it is considered that it is most appropriate for each authority to have a separate affordable housing requirement. It is important the two district’s keep their affordable housing requirements separate, as their housing figures remain separate and therefore ensures this overall figure for each district is achievable. In addition, separate affordable housing requirements takes into account items such as geographical location and therefore the difference in land values, it also provides the opportunity for each District to target their own specific affordable housing need. This is supported by Paragraph 0041 (Reference ID: 23b-004-20190901) which sets out that plan makers should consider how needs and viability may differ between site typologies. 4.16 However, regardless of the affordable housing requirements proposed, the Council need to ensure that Policy is flexible in wording, allowing for viability to be taken in account and demonstrated where required to do so. 4.17 Furthermore, the proposed affordable housing policy is a strategic policy, which should be set out by establishing and understanding the need requirement, therefore the policy should be informed by evidence. This is supported by Paragraph 0041(Reference ID: 23b-004-20190901) which sets out that planning obligations policies should be informed by evidence of infrastructure and affordable housing need, and a proportionate assessment of viability. Consequently, there is potential that the two local authorities have different needs, and therefore the Policy should be addressed in accordance. However, The Church Commissioners cannot comment on details relating to specific quantified amounts, as there is no viability evidence presented alongside this consultation at present. 4.19 Option H2-2c should not be considered as it would result in affordable housing requirements being unclear and potentially unknown, therefore introducing risk, impacting upon bringing sites forward and ultimately delivering the required housing figures. Q-H3: Please select all options which are appropriate for South Warwickshire As set out under Paragraph 1.4 of the Issues and Options Report, the purpose of Part 1 of the Local Plan is to establish a robust and flexible framework to set out where and how much development should take place across South Warwickshire. Consequently, the introduction of minimum space standards is not appropriate for Part 1 as it is not a strategic consideration, thus none of the above options are the correct or suitable approach. Consequently, Option H3a should be pursued on the basis of not including minimum space standards in a policy within Part 1 of the Local Plan. 4.21 However, if the Council wish to include this, sufficient evidence should be presented as per PPG Paragraph 0022(Reference ID: 56-002-20160519) which sets out that in order to set minimum space standards within local planning policy, local authorities need to gather evidence to determine where there is need for additional standards in that area, to justify appropriate policies. The importance of this guidance cannot be understated. It is clear that the onus is on local authorities to demonstrate why standards are needed in that area ie the absence of such standards is consistently resulting in the provision of under-sized homes within Warwick and Stratford Districts. 4.22 However, it is also worth noting that in order to achieve Minimum Space Standards, larger plots will be required and therefore appropriate densities for allocated sites and what is deemed as suitable densities will need to be considered. Overall, having a Minimum Space Standard requirement may then impact upon achieving the overall housing need, therefore The Church Commissioners suggests the local authorities allocate more sites, above the HEDNA requirement in order to take account for Minimum Space Standards, ensuring the Standards can be met without impacting upon density and housing numbers, thus deliverability. Q-H5: Please select all options which are appropriate for South Warwickshire The Church Commissioners acknowledges the need for self and custom build homes. However, the Councils need to ensure sufficient evidence is present and demonstrated to show need and demand for such properties through their respective self and custom build registers. As such, it is considered that Option 5C is most appropriate, whereby developments can respond to evidenced demand. 4.29 In addition, any Policy should include wording to state that if there is no demand for the plots after a 12-month marketing period, then the plots can be released for sale on the open market.
Table 8.45 of the HEDNA (reproduced at Table 10 of the Consultation Document) identifies that there is a total annual affordable housing need of 547 dwellings in Stratford and 839 dwellings in Warwick (totalling 1,386 homes per year). This need is significant and, in the case of Stratford, is in excess of the trend-based alternative figure for overall housing provision that is also suggested by the HEDNA (868 dwellings per annum). 4.9 The Church Commissioners submits that the only way to realistically deliver affordable housing at a level that is anywhere close to the level of identified need would be to significant for both Councils to allocate a greater number of sites to deliver market housing over and above the minimum need identified by the HEDNA (either Standard Method or trend-based alternative). Such development would include a portion of affordable housing, in line with the relevant Local Plan policy. 4.10 At present, there is a policy requirement for 35% of proposed residential dwellings to be affordable homes in the Stratford District and 40% in the Warwick District. 4.11 As such, if the total trend-based alternative need figure (1,679 dwellings) was provided annually, and assuming affordable housing was provided at 40%, this would result in the provision of 671.6 affordable homes per year; 714.4 dwellings per year less than the identified annual affordable housing need. 4.12 It therefore follows that housing should be planned for in excess of twice the annual trendbased alternative need suggested by the HEDNA. Whilst this may be unrealistic, it remains more feasible than alternatives such as relying on affordable housing exception sites, relying on the Councils to deliver ‘Council housing’, or increasing the percentage of affordable housing provided on housing sites to unviable levels. 4.14 As a result, whilst acknowledging that the full scale of the affordable housing need is unlikely to be met, it remains that both Councils are obligated to allocate sites for housing significantly in excess of the trend-based alternative figure suggested by the HEDNA (41,975 dwellings across the Plan Period) and that all options to do so have been fully explored and exhausted, including Green Belt release.
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Issue H4: Accommodating housing needs arising from outside of South Warwickshire 4.23 The Church Commissioners supports both Councils in recognising that they have a responsibility to contribute towards meeting unmet housing needs arising from within both Birmingham and Coventry. The Church Commissioners also supports the recognition that, even if the trendbased alternative approach to housing need is pursued, Coventry may not be able to accommodate all of its revised housing need (1,964 homes per annum.) Q-H4-2: In addition to the existing shortfalls identified for the period to 2031, Birmingham City Council has also commenced work on its Local Plan Review to 2042 and has recently published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes to 2042. Additional shortfalls may also be identified arising from the Black Country authorities, notwithstanding the cessation of the Black Country Core Strategy. 4.25 The Consultation Document identifies that, for the purposes of the accompanying Sustainability Appraisal, Stratford and Warwick District Councils have tested the effects of an additional 5,000 and 10,000 homes. 4.26 The Church Commissioners broadly supports this approach, although no clear justification or rationale has been provided to justify the range of homes to be ‘tested’. 4.27 Furthermore, it is important to note that this unmet need covers the period to 2042, whereas the South Warwickshire Local Plan is proposed to run to 2050. Any contribution towards this need made within the South Warwickshire Local Plan should accordingly be capable of being delivered within the required timeframe, and not left until the end of the South Warwickshire Local Plan period.
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