BASE HEADER

No

ID sylw: 106577

Derbyniwyd: 06/03/2025

Ymatebydd: The Umberslade Estate

Asiant : Sworders

In terms of housing delivery, we believe Draft Policy Direction 1 is too broad and lacks precision. It should be more certain of providing the number of homes required under the new standard method. The difference in provision between the old and the new standard method is significant. The aim of the Government planning reforms and the revised NPPF para 36 a) says the strategy must “as a minimum seek to meet the area’s objectively assessed needs”.
The wording of Draft Policy 1 must be amended such that the Local Plan will make provision for the delivery of at least 2,188 dwellings per annum not 1,679. The use of the HEDNA figures is not in accordance with Paras 36(a) and 62 of the NPPF which detail that “strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance.” The current wording has not been positively prepared and is not considered to be sound in
accordance with Para 36(a).
We would question the assumed Windfall allowance over the plan period. This suggests 17% of housing need will come from windfall sites which seems very excessive.
We object to the overall strategy of solely relying on the Strategic Growth Areas and New Settlements to bring forward the districts housing requirements, as it takes more time for larger strategic sites like those proposed to come forward for development and as such will fail to meet the housing need in the short term. Due to their scale and complexity larger sites will take time to plan and require significant upfront capital investment resulting in the housing need not being met within the next five year period. This will result in housing shortfall and the potential for an influx of speculative housing applications in areas that are less suitable for development.
In order to have a five year housing land supply upon adoption of the new South Warwickshire Local Plan should allocate a greater number of small and medium sized sites. Sites 41 and 58 to the South West of Hockley Heath and forming part of SG24can contribute to delivery of housing in the early years of the plan. Under the new method the shortfall in delivery will then be carried forward into the next five year period. Without the allocation of smaller sites on edges of existing settlements the housing and employment land provision will risk being in deficit for a significant part of the plan period.