Issue and Options 2023

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RPS welcomes the preference for the alternative ‘trend-based’ projection set out in the HEDNA, which underpins the local housing need figures set out in the IO document. Nonetheless, RPS recommends that the adjustment for household suppression presented in REPORT | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 18 the HEDNA is reasonable and consistent with national policy and guidance and so should be taken into account in determining the scale of housing need in the SW area.

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 policy16. 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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k. It is therefore unclear how the SA Framework has been devised or how it has been applied in appraising each option, given there is scant reference to it in the evaluation of options or the detailed commentary in the supporting appendices. This lack of clarity and consistency in how the SA Framework has been applied undermines the transparency in the SA process, which is critical to ensure the appraisal is both robust and credible. However, whilst some initial mitigations have been suggested for some categories of options, none have been identified for the generic policy options (see IO SA Appendix E) nor, importantly, for the housing number options (in Chapter 9). There are no reasons given in the IO SA for why potential mitigation hasn’t been identified for these options. This again points to a lack of clarity and consistency in how the options have been appraised which further undermines the transparency in the process. Consequently, the potential contributions of 5000 or 10,000 dwellings to address unmet need as outlined in the IO document, and the spatial options to accommodate this need, represent reasonable alternatives that should be considered through the SA process for the SWLP. This should be undertaken and presented in the next iteration of SA, and a suitable policy response should also be presented in the draft (preferred options) version of the SWLP. It is therefore important that the findings from the SA are considered in the round alongside other relevant evidence regarding the suitability of specific locations and settlements in supporting the delivery of the spatial development strategy.

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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. 7.3 The HSSA does not include an appraisal of Haye Lane, East of Redditch site or its environs. Nevertheless, the Vision document appended to this submission (Appendix A) includes an initial review in relation to archaeology, built heritage and historic landscape. The review did not identify any designated heritage assets within the site. Two designated assets were identified approximately 130m north of the site. Whilst there was some potential for non-designated heritage assets to be present on the site, it is not anticipated that this would necessarily preclude development. Furthermore, any potential impact on the setting of any nearby assets (designated or nondesignated) could be suitably addressed through appropriate mitigation as part of the overall masterplan. 7.4 In this context, RPS considers the Haye Lane, East of Redditch site would score either ‘Green’ or ‘Amber’ against the HSSA methodology as any potential heritage impacts can be suitably mitigated, as evidenced in the updated Vision Document submitted for the site (Appendix A).