Issue and Options 2023

Q-S2: Please select all options which are appropriate for South Warwickshire Option S2b: Have a policy with ‘in principle’ support for intensification development, applicable across South Warwickshire; and develop design codes. This would provide a policy basis for intensification to come forward, where suitable, with guidance from generic design code, which would set the standard for the quality of development but still allow the design of development to respond a specific site location and context and local needs. Q-S3.2: Please select the option which is most appropriate for South Warwickshire Option S3.2c: None of these The Urban Capacity Study has identified a significant shortfall of 7,400 dwellings therefore it is clear that a combination of brownfield and greenfield sites will need to be relied on in order to meet the needs of the Plan area (and what may be required from the adjacent Housing Market Areas). A policy to prioritise only brownfield land is therefore likely to hinder development coming forward on greenfield sites when it is vital that they come forward, and in a timely manner, to meet local need. On this basis, we consider that neither of the options to prioritise brownfield development are appropriate in this circumstance, and the absence of recognition that MRC’s, especially those that are non-Green Belt, are both sustainable locations with good sites available for this purpose. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes, especially Kineton where it is not in Green Belt, has suitable sites, and has taken the least growth of any MRC. Q-S9: Please select the option which is most appropriate for South Warwickshire It is not considered that either of the options suggested are appropriate. Settlement boundaries should be reviewed and, where appropriate amended, as part of both the Part 1 and Part 2 Plan processes. There is a clear need to review boundaries to take account of strategic allocations as part of the Part 1 Plan process. However, this does not mean that boundaries cannot be reviewed again in respect of non-strategic allocations during the Part 2 process, as alluded to within the options provided. In the interim whilst awaiting the Part 2 Plan boundary reviews, it is considered that there would be a negligible impact on differing approaches to remaining settlement boundaries within the separate Stratford-on-Avon and Warwick Local Plans. Q-S10: Please add any comments you wish to make about the development distribution strategy for South Warwickshire Kineton is a sustainable settlement with a number of existing facilities and amenities (including a post office, village hall, public house, bakery, café, sports and social centre, garden centre, co-op, restaurants, various shops, surgery, vets, primary school and secondary school) as set out in our accompanying Vision Document. Kineton also has a good network of movement routes, including a range of public transport services within easy access. There are also regular bus services providing access to Leamington Spa, Banbury, Wellesbourne and Stratford-upon-Avon. Under the current Local Plan, it has not taken anywhere near the same quantum of development as other villages of comparable status. It is not Green Belt; it is in a sustainable location with a good range of local services and facilities and the Neighbourhood Plan is now nearly 7 years old and s hould no longer provide protection against meeting future housing need. Kineton is identified as a Main Rural Centre in the Adopted Core Strategy. As already stated, there are other Main Rural Centres which are Green Belt and there are numerous Local Service Centres (third tier settlements) which are constrained by environmental designations such as the Cotswolds AONB, Special Landscape Areas and Conservation Areas. To provide further context, the settlements of Alcester, Studley and Henley -in-Arden are constrained by the Green Belt. Kineton has no such designation however, it has a disproportionately lower level of proposed growth compared with similarly sustainable villages, and indeed the less sustainable ones. Site Selection Process A SHLAA update was published in April 2020. The update replaces the previous SHLAA published in 2019. The Site Evaluation Criteria sets out the three key stages of assessment – Suitability, Availability and Achievability together with the criteria for each stage. In the case of Kineton, the two proposed reserve sites identified as “safeguarded” land as identified in the KNP (to be released for up to 200 dwellings if further housing need arose) were necessarily assessed in considerably more detail than the NDP process undertook to reserve them for this capacity. This process identified that these sites were very sensitive in landscape terms, more so than other potential sites in the village such as Sites 7 and 8, and also scoring much lower on many other counts and overall. The SHLAA scoped down the development potential of those reserve sites down to just 60 (site 4) and 45 (site 5) dwellings, leaving a shortfall of some 95 dwellings on what the KNP envisaged as reserve housing capacity of the village. With sites 7 and 8 being assessed as available and more sustainable, it is only logical that even within the confines of what the NDP envisaged to accept as growth, irrespective of the SDA, that they are considered suitable to “balance up” the reserve allocation of housing for the village which should accept more growth as envisaged by the KNP. Assessment of SHLAA site 7. Sharba Homes site is identified as Site 7 on the Kineton Land Parcel Map. The site is broadly square in shape and extends northwards from Banbury Road. The parcel is currently in arable use and contains some limited built form, consisting of areas of hardstanding, gravel tracks, a metal building housing radio receiving equipment along with a separate PMR mast, pylons for overhead High Voltage electricity cables and some sheds. An existing vehicular entrance is located along Banbury Road, extending along the eastern boundary of the parcel and provides a farm connection to the agricultural fields to the north and to a single adjacent farmhouse. At present, there are no Public Rights of Way which run through the Site. Due to the arable use of the Site, there is limited vegetation. This is confined to the boundaries and comprises semi-improved grassland margins, existing trees and hedgerows. There are no listed buildings located within, or directly adjoining the Site. It is noted that the registered Battlefield of Edgehill (List Entry 1000009) extends to the south of Banbury Road. The Site is located wholly within Flood Zone 1, an area which has the lowest possible risk from flooding (i.e. less than a 0.1% chance) – as confirmed by the Environment Agency’s consultation response to the application. Surrounding Area The Site is contained along the majority of three boundaries by the existing built form of Kineton. This includes Kineton High School (and associated development) to the west and residential dwellings to the east and south. It is noted that the residential properties to the east, located at Walton Fields, extend only part-way along the boundary of the Site. Agricultural fields extend to the east of the Site from the northern section. Similarly, along the western boundary, the built -form of Kineton High School only extends partway along the Site. However, playing fields set out as a variety of sports pitches associated with the school run alongside the western boundary of the Site. It is noted that the sport pitches include a newly constructed artificial playing pitch along the north-west boundary of the Site with high metal fencing and 15m high floodlighting. Site Suitability The Council will be aware that the Site was dismissed on appeal in 2016. However, the site area was double the size of that currently proposed and indeed, there are several factors which now warrant consideration of this Site in the context of a revised smaller scheme. It is noted that the 2020 SHLAA also considers the potential for a smaller site area the size of that currently being promoted. The Site is identified in the SDC Landscape Sensitivity Study 2011 as a possible location for development, at a scale which is now being submitted for consideration. A detailed assessment of the site was undertaken in the context of a Landscape Sensitivity Assessment (LSA). It is deemed to lie within a pattern of small to medium scale regular fields in mixed agricultural use amongst trimmed, or sometimes outgrown, hedges and scattered trees. There are distant views towards Edgehill to the south-east and, beyond the local ridge, to the higher sylvan ridgeline that ends at Pittern Hill (to the north-west) forming a sylvan backdrop to the local skyline. The main sensitivities derived from the immediate surroundings are described as the stream corridor and associated ridge and furrow fields, the minor ridge skyline to the north-east and the openness of the countryside to the north and east. It is suggested that there is potential for housing along Banbury Road between the college and the cul-de-sac at Walton Fields, but no further north than the latter to ensure that the settlement edge if ‘stepped and well below the minor ridge top’. The revised scale of development that is proposed and assessed in the SHLAA, remains on the lower contours and stops short of the rise in topography that typifies the northern half of the site to comply with this constraint to the limited form of development that is assessed as suitable by both the LSA and SHLAA and as quoted by the Parish Council. Indeed, the LSA identifies the site as the only “medium sensitivity” landscape around Kineton, the rest being “high sensitivity”, and is a particularly rare occurrence of that lower sensitivity in any village. With regard to any potential conflict with the more detailed policies within the Kineton NP, the site area has been reduced from that assessed previously to also ensure that none of the site falls within the ‘Valued Landscapes’ policy (E2) as identified in the Kineton NP. Paragraph 12.9 of the Inspector’s Report confirms that the key issue previously was the protrusion above the local ridge line by virtue of the proposed dwellings on the higher slopes. It was considered that this would form a discordant edge to the settlement. These matters are completely removed with the revised scheme put forward and thus the previous concerns have been overcome. The appeal Inspector concluded that the proposal would not alter the setting of the battlefield sufficiently to adversely affect the significance of the registered battlefield site. It is therefore simply incorrect to identify ‘non designated heritage’ assets as a ‘red’ constraint to development , an Appeal decision of ‘no adverse effect in this regard should in fact render this a matter “green” . A further note in this regard, the land on the opposite/south side of Banbury Road, between the subject site and the battlefield, was considered suitable for a housing allocation despite being closer to the battlefield. There are only two ‘amber’ sites identified within the village in the SHLAA. The other ‘amber’ site is the land immediately adjoining the eastern boundary of Site 7. However if a simple ranking exercise were undertaken, while both sites have the same number of ‘green’ elements (i.e. elements which make the site ‘definitely deliverable ’), Site 7 has only two ‘red’ elements (although these are disputed as above), Site 8 has 4 ‘red’ elements, and would be “isolated” if developed on its own. Site 7 is also closer to the village centre and therefore more locationally sustainable than any other possible suitable sites in Kineton. Kineton is also the closest MRC to the growth areas of Gaydon/Lighthorne making it again the most suitable MRC to target for growth, especially given how little it has taken in recent years as set out above. On this basis, it is self-evident from the Council’s own evidence base that Site 7 is the most sustainable site in Kineton, would make up the reserve allocation shortfall, and assist with the overall Plan shortfall. We firmly believe that the site is capable of accommodating a scheme of 40-50 dwellings at a density which is compatible with the character of the surrounding area and which respects existing policy designations. As detailed above, we would recommend the Council proceed with a dispersed approach to housing across the Plan area to ensure that all sustainable settlements will have an opportunity to grow and support their services and facilities. This will also ensure that much needed affordable housing is dispersed across the Plan area, including the more rural settlements, in accordance with the NPPF. In addition, there is also a clear need for greenfield sites (in addition to brownfield sites) to come forward in order to meet the recognised housing need, and suitable greenfield sites such as Banbury Road in Kineton would enable housing to come forward in a sustainable settlement and grow and support their services and facilities.

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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? 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. 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. 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). 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). 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 based on a new trend based model, whilst seeking to retain the need for Stratford and Warwick suggested by the older Standard Method – model consistency is required.

Table 10 of the Issues and Options consultation document identifies a need for 1,386 affordable dwellings per annum to be delivered across the South Warwickshire Plan area. Table 9 identifies an overall housing need of 1,679 dwellings per annum. Assuming that a 40% affordable housing threshold is applied, as currently exists within Stratford-on-Avon and Warwick Districts, this would equate to an affordable housing provision of 672 dwellings per annum. This falls significantly below the identified affordable housing need identified. It is not considered appropriate to introduce an out of proportion affordable housing threshold as this would have a significant impact on scheme viability. Whilst a rural exceptions policy may assi st in remedying the shortfall in affordable housing need, the only way to actively resolve this issue is to build more dwellings, over and above the identified need. As such, it is recommended that the housing requirement for South Warwickshire is increased to take account of the significant affordability issue across the two Districts.

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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. 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. Sharba Homes broadly supports this approach, although no clear justification or rationale has been provided to justify the range of homes to be ‘tested’. 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.

It is considered that any unmet housing need arising from either the Greater Birmingham HMA or from elsewhere within the Coventry and Warwickshire HMA (or indeed any other HMAs in need) should be met in locations accessible to those HMAs, in accordance with the established growth strategy (disbursed approach). This is likely to result in directing additional growth to the north of the Plan area and adjacent to the administrative area of Coventry to meet unmet housing need. As such, in order to avoid any additional pressure on this part of the Plan area, it is considered that local housing need should be focussed on the remainder of the Plan area, in accordance with the growth strategy (disbursed approach).

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Q-H2-2: Please select the option which is most appropriate for South Warwickshire It is considered that Option H2-2b to include separate affordable housing requirements for Stratford-on-Avon and Warwick Districts is the most appropriate. This will ensure that different markets and affordable needs between the two Districts, as well as local viability issues can be taken account of. It is not considered that Option H2-2c would be appropriate as this will generate uncertainty for developers seeking to invest in the South Warwickshire housing market. It will be important that any affordable housing threshold set within policy is subject to viability to ensure that specific site conditions are taken account of and that the need for affordable housing does not threaten the delivery of housing overall within the South Warwickshire area. Q-H3: Please select all options which are appropriate for South Warwickshire It is considered that Option H3a not to include minimum space standards in a policy in the SWLP is the most appropriate option. Footnote 49 to Paragraph 130, part f) of the NPPF states that policies should only make use of nationally described space standards “where the need for internal space standards can be justified .” No justification for considering the use of national space standards has been included within the Issues and Options consultation document, or its evidence base. As such, it is not appropriate to include a policy on space standards within the South Warwickshire Local Plan. Notwithstanding the above, the consideration of space standards is not a strategic matter for consideration within the Part 1 Local Plan. Q-H5: Please select all options which are appropriate for South Warwickshire It is considered that Option H5b is the most appropriate solution for self and custom build homes IF a need can be demonstrated. It is considered that introducing a threshold would provide certainty to developers. However, the suggestion of a threshold of 100 dwellings is not supported. There is no evidence located within either the Issues and Options document or its evidence base to support either the need for self and custom build homes or the viability of the suggested threshold. Evidence must be provided to support both of these matters. Notwithstanding the above, any policy should be caveated that following a 12 month marketing period, any plots which have not been taken on may be delivered by the developer. Q-H7: please add any comments you wish to make about delivering homes in South Warwickshire. The Urban Capacity Study shows a very substantial shortfall in identified sites for housing, which may be considerably worse if the new trend-based housing projections are applied. Either way, brownfield land alone will not solve the local housing supply shortfall, this will need substantial releases of greenfield land, which should be focussed around sustainable settlements, each taking a fair share for good sustainable dispersed growth. In Stratford District, outside of the main conurbation, there are 8 MRC’s of which only 5 including Kineton are outside Green Belt. Kineton should therefore plays it part in meeting the housing numbers, especially as the KNP identified an allowance of 200 reserve plots for this very purpose. Now that a more detailed study of those sites identifies a shortfall of 95 dwellings, then the land on Banbury Road, identified as more suitable and with a capacity of up to 50 by the SDC Landscape Sensitivity Study 2011 and Appeal decision 2016, should be the natural replacement as set out above.

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It is considered important for the South Warwickshire Authorities to develop a carbon off-setting approach to new developments where carbon offsetting cannot be achieved. This will ensure flexibility and assist in limiting impacts on viability.

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Any threshold needs to be realistic and supported by evidence, with transitional arrangements to ensure the development industry is able to take account and adapt to these requirements.

Q-C4.1: Please select all options which are appropriate for South Warwickshire It is considered that Option C4.1 which does not seek a policy in respect of net zero carbon buildings and to allow compliance with Building Regulations is most appropriate. Applying standards in excess of Building Regulations, or standards which change part way through the Plan Period is considered wholly inappropriate and would create uncertainty and viability issues. By relying on Building Regulations, this will ensure a consistent approach and certainty for developers / housebuilders when calculating development costs. Q-C6.1: Please select the option which is most appropriate for South Warwickshire Option C.6.1.b – Include a policy that has different whole lifecycle reduction targets for different scales and types of developments and for different time periods As stated, this would allow time for the development industry to take account of and adapt to these requirements and ensure that developments are fully viable so that they can come forward to meet the area’s development needs. Any policy requiring these assessments to be completed would need to reflect and be proportionate to different scales of development. There are also references to both a reduction of 55% and 100% and it is unclear what the Council are seeking to achieve. We consider it is appropriate to have a high level policy that is then supported by more specific guidance in a future LPG (for example, how they have approached this with the London Plan 2021).