BASE HEADER

No

ID sylw: 108109

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

As per the December 2024 NPPF, there is no validity in the SWLP responding to the HEDNA derived housing need figure. It must take as a baseline the new Standard Method derived figure of 2,188 units per annum (combining the figures for Stratford on Avon and Warwick DC). Accordingly, we do not support the inclusion of Table 2 within the draft SWLP, given that this sets out the housing calculation using the HEDNA method.
• Windfall Development
Table 3 (Housing calculation 2024 NPPF standard method) identifies a total housing need across the plan period of 54,700 for South Warwickshire, with assumed windfall allowance across the plan period contributing 9,375 to this figure, or 17.1% of the total need.
Such an overreliance on windfall provision is simply unacceptable and would render the SWLP unsound. Leaving almost one fifth of housing land supply to chance is not plan-led. As such, additional allocations are required to respond to housing need. Furthermore, the identified quantum of windfall housing fails to incorporate a lapse rate and is taken from 2025 rather than from the anticipated Plan commencement date, effectively resulting in double counting. In our view, the inevitable consequence of these matters is to further compound the need for the identification of additional site allocations in the face of likely shortfall of provision.