Issue and Options 2023

Issue 7 Refined Spatial Growth Options QS7.1 For each growth option, please indicate whether you feel it is an appropriate strategy for South Warwickshire: Option 1 – We consider it appropriate to consider rail corridors as part of refined spatial growth options. Rail has the potential to contribute to sustainable development and we would support further considering this option as the SWLP advances. We note that the high-level Sustainability of Growth Options sets out the likely effects of each of the Growth Options. Option D (Enterprise Hubs) has identified 1 Significant Negative effect in relation to Health. Options E (Socio- Economic) and F (Main Urban Areas) both identify 2 Significant Positive effects, both in relation to Transport and Housing. All other options have been attributed with a similar number of positive and negative effects. Although the work so far undertaken is high level, it is already apparent that each option has advantages and disadvantages. We consider that it is too soon to discount any of the Growth Options at this stage without understanding which individual sites or areas of land have the potential to come forward as a result of the Call for Sites. It may only become apparent at this stage, once details of any other site constraints and opportunities are fully understood that the Growth Options are further refined or discounted completely. We are currently of the view that in order to provide housing which meets the needs of the population (to all sectors), the development strategy should seek to provide new dwellings in a variety of sustainable locations across the Districts. The final strategy therefore could result in a combination of certain Options or a mixture of all five options as currently drafted. Option 2 – We consider it appropriate to consider sustainable travel as part of refined spatial growth options. Sustainable travel has the potential to contribute to sustainable development and we would support further considering this option as the SWLP advances. We note that the high-level Sustainability of Growth Options sets out the likely effects of each of the Growth Options. Option D (Enterprise Hubs) has identified 1 Significant Negative effect in relation to Health. Options E (Socio- Economic) and F (Main Urban Areas) both identify 2 Significant Positive effects, both in relation to Transport and Housing. All other options have been attributed with a similar number of positive and negative effects. Although the work so far undertaken is high level, it is already apparent that each option has advantages and disadvantages. We consider that it is too soon to discount any of the Growth Options at this stage without understanding which individual sites or areas of land have the potential to come forward as a result of the Call for Sites. It may only become apparent at this stage, once details of any other site constraints and opportunities are fully understood that the Growth Options are further refined or discounted completely. We are currently of the view that in order to provide housing which meets the needs of the population (to all sectors), the development strategy should seek to provide new dwellings in a variety of sustainable locations across the districts. The final strategy therefore could result in a combination of certain Options or a mixture of all five options as currently drafted. Option 3 – We consider it appropriate to consider economy as part of refined spatial growth options, however we are less supportive of this option – especially in relation to strategic scale development sites which are likely to bring forward their own suite of employment opportunities and as such would be less reliant upon existing employment opportunities. We note that the high-level Sustainability of Growth Options sets out the likely effects of each of the Growth Options. Option D (Enterprise Hubs) has identified 1 Significant Negative effect in relation to Health. Options E (Socio- Economic) and F (Main Urban Areas) both identify 2 Significant Positive effects, both in relation to Transport and Housing. All other options have been attributed with a similar number of positive and negative effects. Although the work so far undertaken is high level, it is already apparent that each option has advantages and disadvantages. We consider that it is too soon to discount any of the Growth Options at this stage without understanding which individual sites or areas of land have the potential to come forward as a result of the Call for Sites. It may only become apparent at this stage, once details of any other site constraints and opportunities are fully understood that the Growth Options are further refined or discounted completely. We are currently of the view that in order to provide housing which meets the needs of the population (to all sectors), the development strategy should seek to provide new dwellings in a variety of sustainable locations across the Districts. The final strategy therefore could result in a combination of certain Options or a mixture of all five options as currently drafted. Option 4 – We consider it appropriate to consider sustainable travel and economy as part of refined spatial growth options, however as per Option 3 we are less supportive of this option – especially in relation to strategic scale development sites which are likely to bring forward their own suite of employment opportunities and as such would be less reliant upon existing employment opportunities. We note that the high-level Sustainability of Growth Options sets out the likely effects of each of the Growth Options. Option D (Enterprise Hubs) has identified 1 Significant Negative effect in relation to Health. Options E (Socio- Economic) and F (Main Urban Areas) both identify 2 Significant Positive effects, both in relation to Transport and Housing. All other options have been attributed with a similar number of positive and negative effects. Although the work so far undertaken is high level, it is already apparent that each option has advantages and disadvantages. We consider that it is too soon to discount any of the Growth Options at this stage without understanding which individual sites or areas of land have the potential to come forward as a result of the Call for Sites. It may only become apparent at this stage, once details of any other site constraints and opportunities are fully understood that the Growth Options are further refined or discounted completely. We are currently of the view that in order to provide housing which meets the needs of the population (to all sectors), the development strategy should seek to provide new dwellings in a variety of sustainable locations across the Districts. The final strategy therefore could result in a combination of certain Options or a mixture of all five options as currently drafted. Option 5 – We consider it appropriate to consider a dispersed approach as part of refined spatial growth options. This has the potential to contribute to sustainable development and we would support further considering this option as the SWLP advances. It is to be noted that the current development plans for the two Districts are founded upon a strategy of ‘balanced dispersal’ which has been an effective and deliverable strategy, it is therefore a strategy which has been successful in the past and should be given serious consideration in the SWLP. We note that the high-level Sustainability of Growth Options sets out the likely effects of each of the Growth Options. Option D (Enterprise Hubs) has identified 1 Significant Negative effect in relation to Health. Options E (Socio- Economic) and F (Main Urban Areas) both identify 2 Significant Positive effects, both in relation to Transport and Housing. All other options have been attributed with a similar number of positive and negative effects. Although the work so far undertaken is high level, it is already apparent that each option has advantages and disadvantages. We consider that it is too soon to discount any of the Growth Options at this stage without understanding which individual sites or areas of land have the potential to come forward as a result of the Call for Sites. It may only become apparent at this stage, once details of any other site constraints and opportunities are fully understood that the Growth Options are further refined or discounted completely. We are currently of the view that in order to provide housing which meets the needs of the population (to all sectors), the development strategy should seek to provide new dwellings in a variety of sustainable locations across the Districts. The final strategy therefore could result in a combination of certain Options or a mixture of all five options as currently drafted.

Yes

Yes. We consider that it is appropriate for small scale development to come forward outside of the chosen strategy. This allows for unidentified development (windfall) to come forward over the plan period, which has the potential to support the vitality and viability of existing communities. New development in this circumstance should not be determined by a threshold. By setting a threshold, the suggestion would be that any specific settlement has some form of capacity or limit, and therefore any development exceeding the notional threshold would be inconsistent with the plan strategy. That cannot be the case. The ability for a settlement to accommodate new development will change over time (and noting that the plan period for the SWLP is extensive, to 2050), new development has the potential to increase the ability for a settlement to absorb growth (for example bringing with it new facilities, either on site or via the S106 regime). In any event development requirements should be expressed as a minimum with no ceiling or cap.

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Affordable housing is a significant issue for the SWLP. It is firstly important to have in mind that delivering housing to meet identified needs will assist in keeping affordability ratios in check, since demand will meet need and will avoid housing prices rising due to elasticity of supply issues. Even in circumstances where housing need is being identified and met, there is an acute need for affordable housing in South Warwickshire. The public sector is unable to deal with this issue, it is therefore for the private sector to deliver necessary affordable housing provision. Exception type housing will deliver a proportion of affordable provision, this however will be very low. The most effective way of delivering affordable housing is via allocations and windfall development over the plan period, by way of an appropriate – viability tested – threshold and percentage delivery requirement. The SWLP should maximise the delivery of market housing delivery, so as to correspondingly maximise the opportunity to deliver affordable housing. This is singularly the only way in which meaningful quantities of affordable housing will come forward in the plan period. Q-H2-2a We consider that with a single plan for South Warwickshire, combined as a unified policy area, there should be a single South Warwickshire wide affordable housing requirement – both in terms of threshold and percentage requirement. This would allow the requirement to be applied consistently across both Districts.

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Q-H4-2 Please add any comments The Black Country is a HMA which requires the export of housing. It is complicated by the collapse of the Black Country Core Strategy Review, which means that each of the Black Country authorities will need to prepare individual development plans, albeit to some extent based upon the evidence base already prepared. The extent of export from the Back Country is likely to increase over time. Through the Solihull plan examination in 2021 and 2022 it became clear that the Black Country authorities had set a very low bar in terms of ‘sustainability’ so as to minimise the extent of export, we consider that the Black County authorities will revisit this approach and raise the ‘sustainability’ bar, and if this occurs the extent of housing export will increase, and potentially substantially so. The wider HMA issues will need to be factored in to future iterations of the SWLP. It is suggested that the current working assumption of between 5,000 to 10,000 houses (which excludes Coventry) is too low and runs the risk of the SWLP proceeding, undershooting its contribution, and having to be paused to increase the quantum of housing it is delivering. Better to test and assess a bigger contribution now, to allow the SWLP to proceed on its anticipated timeline.

Q-H4-3 If we are required to meet housing shortfalls from outside of South Warwickshire, how best and where should we accommodate such shortfalls? The extent of the shortfall from the wider HMA’s is so significant that by ring fencing its delivery there risks a plan strategy which is driven by HMA issues rather than being developed in the context of sustainable development. Delivering growth to meet the wider HMA housing issues in the northern section of the SWLP area – such as at Hockley Heath – would ensure that wider HMA needs are met as closely as possible to the geographical area where the need arises. This is an inherently sustainable approach and should be the starting point for the SWLP.

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