Issue and Options 2023
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The IO document highlights that a heritage evidence base is being prepared to support the SWLP, titled ‘Heritage and Settlement Sensitivity Assessment for Warwick and Stratford-on-Avon Local Plan (SWLP)‘ dated September 2022 (‘HSSA’). This is one of a number of technical documents that will help inform the choice of a single spatial option (or ‘preferred option’) to be consulted on at the next stage. 7.2 The IO document states that the HSSA has been prepared to determine the impact development may have on the heritage assets within various settlements, and will be used when determining the growth strategy (for the draft plan). Section 3 of the HSSA also states that the assessment will inform strategic site allocations and broad locations for growth within the development strategy for the Local Plan, but initially supporting the Issues and Options stage. Whilst the IO document has not requested any responses specifically on the HSSA, RPS has nonetheless reviewed the assessment with respect to Southam, which is set out below. Identifying potential impacts of development – Southam 7.3 Southam has been sub-divided into four sub-areas (North, South, East and West). The HSSA provides a table (not numbered in the report) which summarises the scores, based on a ‘RAG’ rating system, broken down by these sub-areas. The full assessment is provided at section 10.21 of the HSAA, alongside a number of supporting plans. 7.4 In summary, the HSSA scores the West sub-area as ‘Red’, and the other three sub-areas as ‘Green’. According to the HSSA commentary, this is largely the result of the Conservation Area and open landscape associated with the valley of the River Stowe which also contains the Scheduled Monument of the Holy Well. However, whilst the HSSA provides detailed commentary on each subarea, these sub-areas are not defined on a map or plan. This creates uncertainty for the reader in understanding how development on specific sites might impact on the sensitivity or susceptibility of heritage assets within those sub-areas. RPS recommends that the HSSA is updated to provide an indication of the boundaries of each sub-area so the reader can properly interpret the information provided. 7.5 That said, of particular interest is the sub-area North, which is assumed to cover the area that includes the Land off Coventry Road, which scores ‘Green’ in the RAG assessment. In respect of designated heritage assets, there are no known assets identified along the northern boundary of the settlement (see pdf page 190 of the HSSA for the mapping). In terms of the sensitivity and susceptibility of development in this sub-area, the HSSA acknowledges there are no designated assets present in this area and that the area comprises largely an agricultural and industrial landscape. In terms of potential impacts on heritage assets, the HSSA acknowledges that modern development to the north, south and east of the settlement has partially enclosed and eroded the Conservation Area and its setting (pdf page 188). The HSSA also acknowledges that this sub-area may be able to accommodate development, and thus does not preclude it from coming forward. 7.6 The HSSA mapping (on pdf page 191) does indicate the presence of features on the Historic Environment Record (HER) and other non-designated assets to the North of the settlement, which covers the Land off Coventry Road. This is consistent with information provided in the updated Vision Document for the site (Appendix A) which identifies Ravenswood House (also known as Southam Fields Farm) as recorded on the HER, but in any event these buildings would be retained. 7.7 On this basis, it is not anticipated that the development in this part of the sub-area, including the Land west of Coventry Road, would have an adverse impact on any designated heritage assets. Recommendations 7.8 In light of the findings highlighted above, the HSSA recommends that development should be restricted to the North sub-area of Southam (and other sub-areas), whilst avoided in the West subarea (see pdf page 189). RPS broadly concurs with these recommendations. 7.9 On this basis, RPS broadly welcomes the conclusion that development has potential in the North sub-area (subject to confirmation that Land off Coventry Road being promoted on behalf of Taylor Wimpey is located within this sub-area) and that any potential impact on any designated or non-designated heritage asset can be suitably mitigated as part of the planning application process.
It 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.
It 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.
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 1 st 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. • 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 | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 7 • Reliance in the supply (24%) predicted on sites not yet identified (windfall sites) totalling 4,840 dwellings • It is suggested there is 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 conducted. 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 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, 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).
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 1 st 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. • 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 | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 7 • Reliance in the supply (24%) predicted on sites not yet identified (windfall sites) totalling 4,840 dwellings • It is suggested there is 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 conducted. 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 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, 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
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.
