BASE HEADER

No

ID sylw: 107505

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

a) Housing Numbers

It is considered that the policy direction as drafted is not positively prepared, justified, or consistent with national policy, in relying on out-of-date evidence to suggest that 1,679 dpa would be an acceptable annual housing requirement, and incorrectly treating the Standard Method’s 2,188 dpa as a maximum figure, secondary to the ageing HEDNA. To remedy this, the emerging policy should state that provision will be made for at least 2,188 dpa, requiring a minimum of 54,700 dwellings over the plan period. The evidence demonstrates that this is deliverable, with in excess of 2,188 completions in six of the last eight years across South Warwickshire, and opting for this higher figure would not undermine the effectiveness of the plan. Notwithstanding, planning for an even greater number of homes is encouraged and would be strongly supported, to provide sufficient flexibility to allow for higher-growth scenarios as set out in the Further Advice on Housing & Employment Land Needs report (up to 2,808 dpa), unmet need from neighbouring authorities, potential uncertainty in the number of dwellings which will be delivered on windfall sites, and the delivery of sufficient affordable homes to meet local need (from 2,772 dpa - discussed further under Policy Direction 10). Such an approach would ensure that the objectively assessed housing need for South Warwickshire can be met in full. This is supported by the SA, which concludes that providing at least 2,188 dpa will have the most positive effects compared to the reasonable alternatives in terms of housing and supporting economic growth. Planning for this number of homes will align with the aspirations of the NPPF, including those set out in Paragraphs 61 and 83.

b) Housing Land Supply

The updated Standard Method has significantly increased the annual housing requirement within Stratford, from 553 dpa to 1,126 dpa (a 103.6% increase). The latest analysis from Landstack indicates that using the new Standard Method results in a housing supply of just 2.96 years.

In an appeal decision related to the Warwickshire Police Headquarters in Long Wootton (ref. APP/T3725/W/23/3319752), dated 24 May 2024, the Inspector determined that Warwick only had a 4.01-year land supply, and a shortfall of 665 dwellings. The appeal decision clarified that Warwick should be assuming a 45% discount on their supply which is to meet Coventry’s needs, based on the spatial strategy of the adopted Warwick District Local Plan. Taking that position into account, the Inspector concluded that Warwick’s supply was 4,914 dwellings. Under the new Standard Method’s minimum local housing need (1,062 dpa), based on a five-year supply of 4,914 dwellings, Warwick only has a 4.62-year housing land supply at the present time.

c) Spatial Growth Strategy

There is insufficient previously developed land within South Warwickshire to accommodate the level of housing required.

The Councils clearly have an opportunity to allocate additional sites which will deliver housing that extends beyond the minimum local need, to absorb any unmet needs from neighbouring authorities, in line with Paragraphs 24 and 62 of the NPPF, allow for higher- growth scenarios, deliver enough affordable homes, and provide flexibility to avoid potential future shortfalls in delivery.

It is contended that the SA undervalues the positive contribution that residential development in South Warwickshire can make towards biodiversity, particularly if sites are currently in arable use, as such land generally has a low ecological value.

The Site forms part of the ‘South of Wellesbourne Group’ Strategic Growth Location (SG16) and is split across Priority Areas 1 and 2. Its inclusion and Priority Area designation is strongly supported. This highlights that the Site is a sustainable and suitable location for growth, with development here aligning with the spatial strategy for South Warwickshire. Development would also assist with sustaining facilities and services in Wellesbourne, which is a smaller settlement. SG16 has been assessed against the SA Framework and generally performs favourably.