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 could 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. Option S2b – not enough land in urban capacity study. Does it identify my two settlements as some inconsistency. 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. Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Yes, especially Bishops Tachbrook where it is a larger settlement not within Green Belt and has suitable sites that could come forward. 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 Bishop’s Tachbrook is a sustainable settlement with a number of existing facilities and amenities (including local shops, surgery, primary school and public house) as set out in our accompanying Design and Access Statement. Bishop’s Tachbrook also has a good network of movement routes, including a range of public transport services within walking distance. There are also regular bus services providing access to Leamington Spa, Banbury, Wellesbourne and Stratford -upon-Avon. 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 Oakley Wood Road in Bishop’s Tachbrook would enable housing to come forward in a sustainable settlement and grow and support their services and facilities.

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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 nonetheless 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 assist 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 identif ied 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 Warwick District, outside of the main conurbation, there are 8 major villages, of which Bishops Tachbrook is one of only 3 that are not within the Green Belt. If the village landscape is consistently re-assessed, the land to the South East would be the next logical choice for a suitable allocation 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 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).