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ID sylw: 108618

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 10 – Providing the Right Tenure and Type of Homes
5.1.
The Policy Direction offers very little direction at all, solely stating that the Councils will have regard to the latest evidence when drafting this policy in full.
a)
Affordable Housing
5.2.
There is an acute affordability problem across the South Warwickshire Plan area, as recognised in the Further Advice on Housing & Employment Land Needs report (February 2024). Warwick District Council’s latest Authority Monitoring Report for 2022-23 identifies a requirement of 374 affordable dwellings per year, yet only 291 dwellings were delivered in 2022-2023, and the annual need has only been met three times since the start of the plan period in 2011. Meanwhile, Stratford’s Authority Monitoring Report for 2022-23 identifies that in the current Core Strategy plan period of 2011-2031, 3,744 affordable dwellings have been provided out of a total 11,459 dwellings (net) built. This equates to 32% of all dwellings, which is below the Core Strategy’s affordable housing policy requirement for 35% of all dwellings to be affordable.
5.3.
The HEDNA considered the affordability issue across South Warwickshire. It identifies at Table 8.45 that the estimated annual need for affordable housing (rented and affordable home ownership) across Stratford-on-Avon and Warwick is 1,386 dwellings per annum. The Further Advice on Housing & Employment Land Needs report suggests that the affordable housing need has worsened, with the number of households on the two authorities housing registers having climbed from 7,048 in April 2021 to 7,684 in April 2023.
5.4.
Paragraph 2A-024 of the National Planning Practice Guidance makes provision to encourage local authorities to consider increasing planned housing numbers where this can help to meet the identified affordable need:
“The total affordable housing need can then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probably percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the strategic plan may need to be considered where it could help deliver the required number of affordable homes.” (emphasis added)
5.5.
The Further Advice on Housing & Employment Land Needs report states that “the affordable housing need provides a clear basis for housing provision above the standard method (and indeed at or above the HEDNA level)” (§6.32). Table 6.10 of the report indicates that at least 2,772 dpa should be delivered in order to meet South Warwickshire’s affordable housing needs in full. It is imperative for the Councils to consider this when determining the total number of homes to plan for, as per the PPG. The SWLP Part 1 must address the acute affordability issue and boost the supply of affordable homes, to ensure that Stratford and Warwick can consistently meet their own affordable housing need, as well as the need of neighbouring authorities if appropriate, throughout the plan period.
5.6.
The policy should specify the type of affordable housing required (including the minimum proportion of Social Rent homes required), having regard to local need identified in the evidence base, in line with NPPF §64. This will ensure that the policy is justified and sound.
b)
Housing for Older People
5.7.
The HEDNA identified a need for 4,200 units of specialist housing, including retirement housing and extra care homes, as well as a need for around 1,450 care and nursing home bedspaces. This specialist accommodation accounts for 13% of overall housing need. The Further Advice on Housing & Employment Land Needs report does not provide updated figures, but states that the provision of retirement housing, extra care and residential care/nursing home spaces will all be necessary to meet the needs of an ageing population. Any policy requirements for housing for older people must be justified and underpinned by the latest evidence on this matter.