Issue and Options 2023
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New searchIt is noted that under the heading ‘Meeting South Warwickshire’s Sustainable Development Needs’ there is an objective relating to ‘delivering homes that meet the needs of all our communities’. However, this objective only relates to addressing local housing need but does not include any reference to addressing development needs from neighbouring areas. This is despite the accepted position that South Warwickshire straddles two market areas; Greater Birmingham and the Black Country, and Coventry & Warwickshire. Both of these market areas have a history of unmet need which, in Birmingham’s case, has never been fully addressed and which is now worse (c. 78,000 dwellings) compared to the shortfall in adopted Plan (37,500). In Coventry, it is likely that their future needs will not be accommodated in full within their area due to its tightly-drawn boundary and so support will be required from neighbouring areas within the wider market area, including South Warwickshire. Notably, the IO document makes reference to two options for contributions towards these wider needs; 5,000 and 10,000 homes. 2.3 On this basis, RPS recommends that the objectives of the SWLP should be updated to reflect the emerging position regarding future (unmet) need across the wider market areas within which South Warwickshire is located and which make a clear commitment to assisting in addressing those needs
An Urban Capacity Study for South Warwickshire, dated October 2022, has recently been undertaken to inform the Local Plan. Its purpose is to identify the potential for residential development on brownfield land within the settlements in South Warwickshire. As pointed out in section 1.1 of the study report, a review of housing capacity has been undertaken in order to minimise the amount of development outside of existing urban areas. 3.7 The IO document goes on to state that the study has been undertaken as a theoretical exercise and is not intended to conclusively establish the urban capacity of South Warwickshire over the period to 2050, but rather to indicate potential untapped urban capacity within these identified settlements, subject to the application of policy and the conclusions of more detailed subsequent evidence work. That said, there are some important conclusions in the study that need to be emphasised at this stage as the study will form part of the evidence to underpin the development strategy in the SWLP. 3.8 The study has applied a number of important assumptions, as listed here: • The base date for the study and the conclusions around potential urban housing capacity is 1st April 2021 • The study assumes that all of the sites considered will be developed as ‘conventional’ dwellinghouses in Use Class C3 (not specialist housing i.e. student accommodation or older persons housing). • Capacity was measured on sites located in 23 settlements across the SW area, including Main Rural Centres defined in the Stratford-upon-Avon Core Strategy, and Growth Villages as defined in the Warwick Local Plan. This includes sites located in Southam . • The Urban Capacity Study does not represent a HELAA-level consideration of suitability, availability and achievability, it is important to note that it will be for the forthcoming HELAA to establish whether these sites are actually deliverable or developable in practice. 3.9 Section 4.6 of the study provides a summary of the overall potential urban housing capacity across South Warwickshire: • Total housing assumed over SW area for the 2025-2050 plan period is 30,750 dwellings, using the baseline figures based on the standard method • Total potential baseline housing supply for this period is 19,950 dwellings • Only 6,145 (31%) dwellings would be located within existing urban areas, the rest is located elsewhere REPORT JBB8799.C8269 | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 5 • Reliance in the supply (24%) predicted on sites not yet identified (windfall sites) totalling 4,840 dwellings • Suggested there some potential to increase densities on some sites • Potential yield of 3,400 dwellings by redeveloping public car parks, but this would necessitate a significant programme of intervention and management in order to be realised. 3.10 The study therefore identifies a significant shortfall in the potential for new housing to be accommodated on previously-developed land. The shortfall is currently 10,800 dwellings. This should be taken as a minimum shortfall, as not all sites with potential will actually be deliverable or developable once a full assessment has been carried out. 3.11 Based on these findings, the study concludes that: “whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development.” (RPS emphasis) 3.12 Furthermore, the shortfall is set against the standard method housing need figures (1,230 dpa across the whole area over 25 years). However, the IO document advocates for the use of an alternative ‘trend-based need for South Warwickshire, which gives a need for 1,679 dpa. Against this figure, the total need between 2025-2050 increases to 41,975 dwellings, thus increasing the shortfall to 22,025 dwellings. This clearly demonstrates that the focusing policy objectives on previously-developed land will not deliver anywhere close to the projected needs of the SW area, and therefore planning for development on greenfield land in sustainable locations must form part of development strategy for the SWLP. 3.13 In addition, under the assessment of sites by settlement, the study identified one previouslydeveloped site with an estimated capacity of 18 dwellings within Southam (Site ref. 512 – Land at Oxford Street) however the site is currently in retail use and therefore not available for development. No other potential development unconsented or unallocated sites have been identified within the settlement boundary. Consequently, it is inevitable that additional growth at Southam will need to be allocated on the edge of the settlement. 3.14 The IO document presents three options under this issue. On the basis of the current evidence provided on housing capacity, RPS would recommend that development on previously-developed land is supported only where sites are shown to be viable and deliverable, as well as being sustainably located. However, given the paucity of the overall supply from sites within urban areas, notably Southam, it is not considered reasonable to prioritise brownfield development ahead of other, greenfield locations as a matter of principle as this would put at grave risk the ability of the SWLP to meet the identified needs of the area. On this basis, RPS would not support Option S3.2a or S3.2b (and thus supports Option S3.2c).
There are a number of national and local factors that clearly demonstrate the appropriateness of a strategy which directs future growth to existing settlements within South Warwickshire. 3.17 Paragraph 69 of the NPPF recognises the important contribution that small and medium-sized sites can make to meeting the housing requirements of an area, which can be built out relatively quickly. This provides clear support for directing future growth to appropriately-sized sites on the edge of existing settlements and which can deliver sustainable development. And paragraph 85 also provides support for sites and locations that can meet the community (and business) needs of rural areas adjacent to or beyond existing settlements, and where sites are physically well-related to settlements such opportunities should be encouraged where suitable. Consequently, national policy clearly provides sufficient support and policy direction for focusing growth at or around existing settlements. 3.18 At the local level, RPS notes Table 2 of the IO document which lists a number of existing settlements identified in adopted plans across South Warwickshire. These include Southam. The settlement has been subjected to separate connectivity, accessibility and density analysis, which RPS responds to question Q-S4.2 under section 6 of this submission. Sustainability Appraisal (SA) has also been carried out on the broad locations within which the settlement is situated, and a response to the SA is provided in section 5 of this submission to question Q-I1. 3.19 The IO document hints at what the emerging development strategy might comprise based on commentary set out in the second paragraph under this issue (on page 43). This states that the SWLP will seek to: “…maximise the capacity of its existing urban areas in order to meet our development needs to 2050 (see Issue S2). However, in deciding upon the best distribution strategy for new development within South Warwickshire it is important for the Local Plan to consider the potential for growth around the edges of the existing settlements, potentially alongside and in combination with other options such as new settlements (see Issue S5).” (RPS emphasis) 3.20 In light of the findings of the Urban Capacity Study as discussed under Issue S3 of this submission, even when the capacity within existing urban areas on previously-developed land has been assessed it is clear that this will not be sufficient to meet the needs of the South Warwickshire District in the long term. It is therefore inevitable that development around the edges of existing settlements will be required, given these provide opportunities to deliver sustainable development on largely unconstrained land which can be built out quickly, or where larger sites are concerned these can deliver a steady quantum of development over a period of time in order to help maintain delivery against the targets in the SWLP. REPORT JBB8799.C8269 | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 7 3.21 Based on the foregoing analysis, RPS contends that focusing growth as part of the emerging development strategy on existing settlements, including Southam, aligns with national policy and offers clear potential to meet the development needs of the area, in light of the acknowledged constraints on land supply within settlements. The strategy should therefore incorporate locations for growth around and on the edge of existing settlements where local services and facilities are already available in close proximity to communities in order to achieve wider sustainable development objectives.
RPS has highlighted a number of issues with the CCEE study at a broad level in separate response to Issue S5, which are equally applicable to the assessment of emission estimates for each spatial growth option. That said, the IO document makes specific reference to the CCEE study findings which predicts Option 4 as having the lowest final annual emissions in 2050 and in the preceding years compared with the alternative options, whilst the Dispersed option (Option 5) has the highest emissions. 3.37 On this basis, the CCEE would point to Option 4 as offering a good option for reducing carbon emissions over the longer-term which would fit with the longer plan period to 2050.
The preamble states that Chapter 4 of the IO document sets out various options as to how the development needs to 2050 (e.g. infrastructure, jobs and housing) might be met. The approach to doing this is split into two sub-sections covering 15 ‘issues’ across both topics; on relating to ‘Development Requirements’ and the other ‘Development distribution strategy’ for the area. 3.59 Paragraph 16 of the National Planning Policy Framework (NPPF) requires that plans contain policies that are ‘clearly written and unambiguous’. In order to establish a clear and unambiguous plan it is critical that the approach to strategic policies follow a logical process. Whilst the title of this chapter may refer to ‘needs’ scant reference is made here to the nature or scale of development needs that should be addressed in the SWLP. Specifically, there is very little, if any, consideration at the top of the document to the growth needs of the area in terms of the level or scale of growth to be planned for in the SWLP. Instead, after setting out the draft vision and objectives in chapter 3, the IO document moves straight into considering issues that have a very limited relationship to the growth needs of the area. RPS would suggest that the five issues identified under ‘Development Requirements’ are generic topic-based factors that do not inform the identification of the growth needs for the area or the requirements or targets that might be necessary to address those needs. It is therefore unclear why these considerations have been given such elevated status at the beginning of the document. 3.60 RPS notes that issues relating to the number of homes and jobs that might be required, and the evidence base to justify the approach, is set out in chapter 5 of the IO document (RPS responds to this under separate questions). Whilst providing some clarity, RPS would suggest that given the importance of setting out the growth strategy (or options at this stage) a more sensible and logical approach would be to consider the issues relating to the overall development needs of the area in quantum terms first, before then moving on to consider what the requirement should be in light of the various ‘issues’ i.e. constraints, as identified here. This then provides a clearer and more logical basis for considering the spatial distribution of growth (and options) considered later on (Issue S7) 1 At present, therefore, the way the IO is structured is illogical and confusing and does not help the reader to understand the approach being proposed. RPS therefore recommends that the next iteration of the SWLP is reorganised to provide a clear position on the growth strategy at the outset, including the scale of need and the requirements defined to meet that need. This will provide a coherent basis for the spatial distribution strategy, taking into account the various issues identified.
Chapter 8 of the HEDNA includes an analysis of affordable housing need in Coventry & Warwickshire, which is claimed to follow the methodology set out in the PPG12 . Table 10 of IO document summarises the assessment of need for the SW authorities (drawn from Table 8.45 of the HEDNA) which is presented below. Table 4-2 Net Affordable Housing Need (per annum) – South Warwickshire only Rented Affordable Need Affordable Home Ownership Need Total Affordable Need Stratford-upon Avon 419 129 547 Warwick 582 258 839 SW area 1,007 378 1,385 Source: SWLP IO Jan 2023, Table 10; HEDNA Table 8.45; RPS 4.11 It is recognised in the published evidence base that affordable housing need is ‘high’ relative to the overall housing need across the C&WHMA (paragraph 4.4 of the HEDNA). RPS agrees. Table 8.14 of the HEDNA illustrates this point when comparing affordable need (rented need only) to the trendbased projections for each authority, including Stratford-upon-Avon and Warwick. The table showing the need across all C&WHMA authorities is represented below. Table 4-3 Net Affordable Housing Need (per annum) – C&W HMA Net Rented Need Adjusted Standard Method Affordable % Standard Method Affordable Housing Policy Requirement Notional Provision to Meet Rented Affordable Need in Full Coventry 1,887 1,964 96% 25% 7,548 North Warwickshire 131 119 110% 30-40% 374 Nuneaton & Bedworth 407 409 100% 25% 1,628 Rugby 407 735 55% 20-30% 1,628 Stratford-on-Avon 419 868 48% 35% 1,197 Warwick 582 811 72% 40% 1,455 Warwickshire 1,946 2,942 66% 6,282 C & W 3,833 4,906 78% 13,830 Source: C&W HEDNA Table 8.14 12 PPG ID-2a-018 to 2a-024 REPORT JBB8799.C8269 | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 18 4.12 The figures show that the rented affordable need as a proportion of the overall need for housing in the SW authorities is between 48-72% (or 60% across the two combined). Across the C&WHMA as a whole, the proportion is 78%. When adding in the affordable home ownership need, the proportions increase from 60 to 82% for the SW area, and from 78 to 91% for the C&WHMA. It is clear that the proposed policy targets will only deliver a fraction of the homes needed even if the policy requirements are met in full (which is unlikely). Affordable housing need therefore represents a significant proportion of overall need which needs to be addressed in the SWLP, and across the HMA as a whole, when considering future housing targets for the area. This is particularly the case in Warwick, but is nonetheless still an important factor in Stratford also. 4.13 In addition, the scale of affordable need as a proportion of total need shown above is, to a large extent, due to the need emanating from Coventry, which is 96%. The HEDNA (at paragraph 8.72) recognises that, in setting overall housing targets, the viability of development and the availability of funding are realistically constraints on the level of provision which can be achieved. If Coventry is to make any significant contribution towards meeting its own housing needs, of all tenures, then additional allocations will be needed. This will require a considerable focus on delivering more housing on previously-developed sites within the city’s boundaries and the push for higher policy targets. However, the focus on brownfield land and higher policy standards will inevitably raise concerns with the viability and deliverability of lower value housing. This is evident because Coventry has failed to deliver its affordable housing policy targets since 2011, achieving 2,562 affordable homes against a policy target of 3,828 (2011-2022)13, or 232 homes per annum. 4.14 On this basis, in devising an overall housing requirement in the SWLP, if the SW authorities are serious about addressing affordable housing delivery then consideration should be given to how the delivery of affordable can be maximised across the C&WHMA in order to deliver sufficient affordable homes to meet local needs, in line with national policy14. The best way to increase the supply of affordable housing across South Warwickshire is therefore simply to allocate more land in sustainable locations within the area. This is best achieved through the development of mixed-tenure private sector-led development in areas where viability is less of a problem, notably in South Warwickshire, relative to metropolitan areas such as Coventry.
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The Planning and Compulsory Purchase Act requires a sustainability appraisal to be carried out on development plan documents in the UK. Additionally, the Environmental Assessment of Plans and Programmes Regulations15 (SEA Regulations) require an SEA to be prepared for a wide range of plans and programmes, including local plans, to ensure that environmental issues are fully integrated and addressed during decision-making. 5.2 It should also be noted that SA is an iterative process and, as such, should be undertaken alongside development of the SWLP as it moves forward through the various stages in order to maximise its sustainability credentials. This includes taking into account responses made by stakeholders to the SA and SWLP consultations as part of the plan-making process, including those submitted by local and national house builders. In this context, the IO document explains (page 26) that the SA process will take on board any comments on the SA and use them to furnish the next report with greater detail and accuracy. 5.3 RPS has reviewed the Sustainability Appraisal of the South Warwickshire Local Plan Regulation 18: Issues and Options Stage (‘IO SA’) and provide a response to the question below.
