The South Warwickshire Local Plan
Why are we writing a Local Plan?
As the local planning authorities for Stratford-on-Avon and Warwick Districts, it is our legal responsibility to ensure that we prepare and keep up-to-date a local plan that manages development proposals and ensures that we meet our future development needs in as sustainable a way as possible. This does mean building more homes and providing more land for employment. It also means addressing issues around infrastructure and tackling climate change.
In preparing the local plan we must take account of:
- Legal requirements such as the Duty to Co-operate
- National planning policy and guidance
- Technical evidence
- The views of stakeholders, businesses and our communities
What is the South Warwickshire Local Plan?
A Local Plan is a legal document that Councils are required to prepare, which sets out the future land use and planning policies for the area over a set period of time. Stratford-on-Avon and Warwick District Councils are working together to create a new South Warwickshire Local Plan for the two areas - which we refer to as South Warwickshire. This is the first time that we will have a plan for South Warwickshire, and it will ensure that there is a consistent approach to planning and building across both areas over the years to come.
What is the process for preparing the Plan?
There is a statutory process that the preparation of all Local Plans have to comply with, general guidance on plan-making is available on the following government website: https://www.gov.uk/guidance/plan-making
What is the role of elected Councillors in developing and approving the Plan?
As this Plan is being prepared on behalf of both Stratford-on-Avon and Warwick District Councils, we have set up a joint South Warwickshire Local Plan Advisory Group. This Group is made up of elected councillors from both Councils, and which will have a key role in the development of the Plan throughout the plan-making process. While there will be some key stages of Local Plan preparation that require formal approval by the Full Council of each authority , a joint Executive Committee has been created which is made up of Councillors from both Councils. This Committee will make many of the decisions relating to the South Warwickshire Local Plan, these decisions will be binding on both Councils.
Why are Stratford and Warwick District Councils working together to produce a joint Plan?
The geography of South Warwickshire means that Stratford-on-Avon and Warwick Districts have a strong relationship in relation to infrastructure (M40/A46/rail links/etc), the economy (JLR, Tourism, commuting), population migration, social and cultural offer, and environmental assets (such as the River Avon and canal network). For these reasons there is a strong planning case for closer working on strategic planning issues. A single plan will enable us to tackle the strategic and cross-boundary issues together to create a strong strategic framework for the area. Given these economic, social and geographic synergies between the two Districts and the fact that both Councils are keen to commence an early review of their adopted Local Plan/Core Strategy, it makes sense to work together to produce a single plan that covers the whole of South Warwickshire.
Why do we need to produce the Plan now and when will it be completed?
Councils are required to review their Local Plans every five years. The Stratford-on-Avon District Core Strategy was adopted in 2016 and the Warwick District Local Plan was adopted in 2017. As such, there is a need for both Councils to review their Plans in the near future. The timetable for future stages of the South Warwickshire Local Plan can be found on the South Warwickshire Local Plan timetable page.
What will happen to the existing Stratford-on-Avon Core Strategy and Warwick District Council Local Plan?
The new Local Plan for South Warwickshire is expected to replace the strategic policies within the existing adopted Plans which run to 2031 (Stratford-on-Avon Core Strategy) and 2029 (Warwick Local Plan). It is anticipated that the more detailed policies will be saved for a period of time and then reviewed at a later date in a more detailed plan or plans.
When will people be able to get involved and have their say on the Plan?
Community and stakeholder involvement will be crucial in developing the Plan, and there will be a number of opportunities for people to contribute at the various stages of the preparation of the plan.
Will the Plan be affected by the proposed reforms to the planning system?
The Government consulted on its 'Planning for the Future' White Paper and 'Changes to the current Planning System' consultation during 2020, setting out a package of proposals for fundamental reform of the planning system, including the scope of Local Plans. The government has not yet announced when changes will be brought into effect; however there may be interim measures for Local Plans which are in preparation. Once the Government announces what and when any changes will be introduced, we will assess how this will affect the South Warwickshire Local Plan. The Government has advised that the proposed reforms should not be seen as an opportunity to pause the preparation of plans and address the development challenges facing local areas.
How will the Covid-19 pandemic affect the content of the Plan?
It is too soon to know yet what the effect of the pandemic will be on future land use planning across South Warwickshire. As the Plan evolves we will use emerging evidence on the impact of Covid-19 to inform how it should influence the approach that we take.
Issues and Options
Why are you consulting for a second time?
The first "Scoping" consultation asked about the broad shape the SWLP should take and the topics it should cover. This "Issues and Options" consultation looks in more detail at each topic, identifying the key issues faced in South Warwickshire and presenting options for how these could be approached. The next round of consultation, "Preferred Options" will further narrow this down to a set of draft policies and a single proposed spatial growth strategy.
Why is the consultation happening later than suggested in the published timetable?
There was a delay in the availability of a key piece of evidence to inform the Plan - the Housing and Economic Development Needs Assessment (HEDNA) - which was affected by delays in the release of relevant 2021 Census data.
Does the delay to the Issues and Options consultation mean the rest of the timetable will also be delayed?
We are still working to the timetable as previously published. The local plan process is dependent on a number of inter-related factors, many of which are outside of the control of the SWLP team. This makes it difficult to be precise with dates, especially when looking months and years into the future. If there are changes to the timetable in future, this will be published on our website here.
How have you arrived at the options presented in this consultation?
The SWLP team have gathered evidence from a range of different sources to help suggest possible options. This includes responses to the previous round of consultation, talks with specialists for each topic area, commissioning evidence from experts, and conducting research in-house. This is an ongoing process, and further study of the evidence will happen as we narrow each topic down to our preferred options - which we will present in the next round of consultation. The evidence base for the SWLP can be seen here.
What is the impact of these options on the environment and climate change?
A key part of the SWLP evidence base is a Sustainability Appraisal (SA). This piece of work by specialist, independent consultants will assess each policy option, each spatial growth option, each potential new settlement location, and potential growth at a number of settlements in South Warwickshire. For each of these options, the SA considers the impact on a wide range of environmental, landscape, heritage, public health, community and economic factors. The findings of the SA will be considered by the SWLP team as we move towards a set of draft policies and a single proposed spatial growth strategy. The SA can be found here.
What is a spatial growth option?
Spatial growth options show different ways that homes and employment land could be distributed within the South Warwickshire area. They provide a broad indication of potential locations, rather than specific sites.
Why are you putting forward these spatial growth options and potential new settlement locations?
One of the core functions of a Local Plan is to determine where we should locate the homes and employment land that we need. It is important that we make sure development happens in the most sustainable locations - places that work best for people, for businesses and for the environment. This will only happen if we plan where growth should happen, rather than relying on ad hoc responses to planning applications. The spatial growth options and the potential new settlement locations are one of the steps on the way to determining which land will ultimately be used for development.
Do I need to read and respond to the whole document?
You are welcome to read and respond to as much or as little of the document as you like. We appreciate that this Issues and Options consultation document is lengthy, and that many of the topics are quite specialist in nature. It is perfectly acceptable to concentrate on topics that particularly interest you, or where you have particular knowledge that will help us as we prepare the SWLP. If you don't have an opinion on a particular topic, please just leave those questions blank.
Do I have to live in South Warwickshire to respond to this consultation?
No, anyone can respond. We would like to hear from as many people as possible, whatever their connection to South Warwickshire.
Can I comment on a topic that hasn't been covered in this consultation?
There may well be topics that you feel are relevant but which are not covered. Each chapter ends with a broad "is there anything else" question, so feel free to add your thoughts to whichever chapter where you feel this is appropriate. It's worth double checking whether this is a topic we are proposing to 'save' for the Part 2 plan - please see Chapter 12 for details of these. There will also be topics which are important, but which are not within the scope of a Local Plan, or outside of a Council's control.
How can I comment on the suitability of a particular piece of land for development?
While you are welcome to provide comments on anything you feel is relevant, please note that at this stage of the plan process, we are not looking at specific sites. All the spatial growth options and potential new settlement locations are broad indications rather than detailed locations.
When will Call for Sites submissions be assessed?
We are running a second Call for Sites with the Issues and Options consultation. Sites submitted through both Calls for Sites will be assessed in a single process. This is likely to happen during 2023, with the results ready before the next round of consultation.
How do Call for Sites submissions relate to the chosen spatial growth strategy?
Knowing what land is available for development is an important factor in developing a suitable spatial growth strategy for South Warwickshire. However, to find the most sustainable locations for growth, it is important that the spatial growth strategy is not led by land availability. Following this consultation, the SWLP team will assess the Call for Sites submissions, and the spatial growth options, in separate but parallel exercises. We will then check whether our preferred spatial growth option is deliverable - i.e. whether there is sufficient suitable land available in the right locations. This land may have come through the Call for Sites exercise, or may have been identified through other sources.
What will happen to my response to this consultation?
The consultation responses will be assessed by the SWLP team. This will help us to understand which options are most appropriate for South Warwickshire, as well as alerting us to any issues or constraints that will influence decision-making. The consultation responses form one piece of evidence which will be considered alongside evidence from other sources, to help us reach a set of draft policies and a single proposed spatial growth strategy. Consultation responses will also be published on our website.
I submitted a site during the previous Call for Sites - do I need to submit it again?
You only need to tell us if there is a change to the red line boundary or the proposed use, or if you wish to withdraw the site. We are not asking for re-submission of sites that we already know about, nor for further information about existing sites unless this materially changes how we should assess them.
Housing & Economic Development Needs Assessment
What is a HEDNA?
The purpose of a HEDNA is to provide a joint and integrated assessment of the likely future needs for housing and employment land, taking into account the economic potential and needs of all households in South Warwickshire for the period up to 2050 (the proposed end date of the SWLP). It is a vital part of the evidence base of the SWLP. It is good practice to commission such studies jointly with other authorities because housing needs should be considered across wider "Housing Market Areas". South Warwickshire lies in the Coventry & Warwickshire Housing Market Area. This HEDNA has therefore been commissioned jointly by all the local authorities across Coventry and Warwickshire. It has been undertaken by a team of independent consultants led by Iceni Projects. The HEDNA will be available as a background paper to the Issues & Options document. It is a lengthy document however there is a helpful Executive Summary which is attached to this note.
Why do we need to produce a HEDNA?
The need for the HEDNA stems from the need to prepare a local plan. The local plan is based upon the conclusions of key pieces of technical evidence such as the HEDNA. Understanding the amount of growth that South Warwickshire will need to accommodate is vital if we are to have a sound development strategy in the SWLP. Inevitably, preparing a new Local Plan will prompt questions about how much growth should be taking place, both from those who consider South Warwickshire should take less growth and from those who believe it should take more. It is important that the Councils have a robust and independent assessment to underpin the SWLP.
What are the key conclusions in the HEDNA?
The HEDNA identifies:-
- As shown on table 1 below, a need for 345 ha of land for office and general industrial development in South Warwickshire to 2050. In addition, all authorities will need to contribute to meeting a need for sub-regional strategic warehousing/ logistics.
Table 1: Employment Land Needs 2021-2050 (ha)
|Coventry||North Warks||Nuneaton & Bedworth||Rugby||Stratford-on-Avon||Warwick||Total|
|Strategic warehousing/ distribution (B8)||709|
- As shown on table 2 below, a need for South Warwickshire to deliver 1,679 new homes per year to meet our needs. This is a higher figure than has previously been estimated in the "2014-based projections" (see also below).
Table 2: Overall Housing Need (dwellings per annum)
|Coventry||North Warks||Nuneaton & Bedworth||Rugby||Stratford-on-Avon||Warwick||Housing Market Area|
- A total need for affordable housing across South Warwickshire of c1,388 per year. This includes both those in need of social/affordable rented homes and those with affordable home ownership needs. This figure does not mean that the SWLP should seek to meet this need in full through new dwellings, as there are different ways in which this need can be met. For example, the figure includes a large number who are in existing households (eg in the private rented sector) but are identified as being in need of affordable rented housing.
- the suggested mix of houses of different sizes (1-bedroom, 2-bedroom, etc) across different tenures (social/affordable rented, affordable home ownership and market housing).
- levels of specialist housing need including housing with support, housing with care, residential and nursing care.
- Levels self and custom build housing.
- Some of the key issues around meeting student housing needs.
It should also be noted that the above figures represent levels of need - they do not reflect any assessment of whether those needs can be met within each local authority area. In preparing the South Warwickshire Local Plan, we are bound by our responsibilities under the Duty to Co-operate. This is a legal test we must pass in order for the plan to pass successfully through the examination process, adopted and come into force. The Duty to Co-operate requires us to work proactively and positively with other councils and statutory bodies to effectively address strategic cross-boundary matters. The issue of housing shortfalls is one such matter.
How are housing projections calculated, and why have the figures for both Stratford and Warwick Districts increased?
The Government has set out a standard method for assessing housing need. This takes 2014-based Household Projections (produced by the Office for National Statistics (ONS)) as its starting point. (The 2014-based Household Projections are household numbers based on long-term demographic trends over a 25-year period.) The standard method then uses a prescribed approach which applies an uplift to this based on the relative housing affordability position of individual local authorities. For cities such as Coventry, a further 35% uplift is also applied. The standard method, as applied across Coventry and Warwickshire, is shown on the table 2 above. As can be seen, across the Housing Market Area, using the 2014-based projections, gives a higher overall housing figure than the HEDNA is projecting, however a lower figure for Stratford and Warwick Districts.
Why is the HEDNA not simply applying the 2014-based Household Projections?
The reason is because the recent initial outputs from the 2021 census have revealed that previous household projections produced by the ONS, particularly as they relate to the population of Coventry, have overestimated the population of the city. As such, there are concerns about any projections of future population based on these old projections. The HEDNA has also applied more up-to-date (and therefore accurate) assumptions about fertility, mortality and household formation rates. The 2021 census is a more robust and reliable basis for considering population projections.
The projections of housing need in the HEDNA are challenging. The following points, however, should also be borne in mind:-
- The total amount of housing that the SWLP will need to provide will also include an agreed proportion of any need from Greater Birmingham and Coventry that those councils are unable to accommodate within their areas. In the current Warwick District Local Plan, 332 homes per year need to be provided to meet Coventry's housing needs. As the figures in table 2 show, the overall housing need in Coventry falls in the HEDNA (compared to the previous 2014-based projections). Therefore, it follows that the SWLP will be likely to need to accommodate fewer additional homes from Coventry based on these figures.
- Both the Stratford-on-Avon District Core Strategy and the Warwick District Local Plan include housing allocations which have yet to be built. Very many of these will contribute towards meeting the level of housing need identified in the HEDNA.
The HEDNA figures are based on the most up-to-date evidence available which seeks to directly address previous concerns regarding the figures currently used by the ONS. Based on the previous experience of both authorities in plan-making, having a robust understanding of housing need which can be defended at Public Examination is critical to the success of being able to deliver the South Warwickshire Local Plan.
Therefore, whilst it may be tempting to want to apply the 2014-based figures because they are lower for South Warwickshire, this would perpetuate the errors in the population figures for Coventry. The HEDNA corrects this error. Given that Coventry looks unable to accommodate all of its own housing needs, it would most likely fall to South Warwickshire to accommodate a significant quantum of that need. The overall outcome may then most likely be similar levels of housing overall.
What does this mean for housing allocations made in the previous Local Plan / Core Strategy?
This is particularly an issue in Warwick District in view of the concerns over the population figures and projections for Coventry noted above. The legal position is that the allocations in the Local Plan remain in place until such time as the policies in the Local Plan are replaced. In the case of major strategic housing allocations, this will be when the SWLP is adopted. In any event, the following should also be noted. Firstly, there are now planning permissions in place for most of the major sites allocated in the Local Plan, and so even if the Council wished to revoke the planning policies in the Local Plan this would not affect extant planning permissions that have been granted. Secondly, given the higher forecast need for housing identified in the HEDNA for Warwick and Stratford Districts, it is likely that both districts will need to find similar (or higher) numbers of new housing than previously. The land will still need to be provided for new housing, irrespective of whether that need comes from population growth within the Plan area, or from unmet need elsewhere as agreed through Duty to Cooperate. That said, where the development strategy in the SWLP proposes a pattern of growth which is significantly different to that in the current Local Plan, it will have the opportunity to review any allocations in current Plans which have not been implemented. To repeat, however, this would not affect those allocations which already have an extant planning permission.
Neighbourhood Plans and the SWLP
Can a Neighbourhood Plan come forward before the emerging Local Plan?
A Neighbourhood Plan can be developed before or during preparation of the emerging Local Plan. It is important that the Local Planning Authority works closely with Neighbourhood Plan groups to ensure that there aren't any conflicts between Neighbourhood Plan policies and Local Plan policies. Section 38 (5) of the Planning and Compulsory Purchase Act requires conflict to have been resolved in favour of the policy contained in the last document that has become part of the Development Plan.
Does a Neighbourhood Plan need to be in conformity with the draft emerging South Warwickshire Plan?
No, not until the South Warwickshire Local Plan has been through examination and has been formally adopted. Any emerging Neighbourhood Plan policies need to continue to be in conformity with the adopted Local Plan or Core Strategy. However, it should be noted that Neighbourhood Plans should be aware of new evidence that is being used to help prepare the South Warwickshire Local Plan that may supersede older evidence.
Will a Neighbourhood Plan need to be updated once the South Warwickshire Local Plan has been adopted?
There will not be a requirement to do so. However, if Neighbourhood Plan policies conflict with Local Plan policies they may become out of date for a Neighbourhood Plan area if they were adopted before the Local Plan is adopted. Where this is the case, the most recent adopted plan takes precedence. This would not necessarily mean that the whole of the Neighbourhood Plan is out of date but just those specific policies that are superseded by Development Plan policies.