BASE HEADER

No

ID sylw: 108726

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We object to Draft Policy Direction 1 because, as currently written, it does not comply with the requirement for Local Plans to be positively prepared and consistent with national policy, as set out in paragraph 36 of the NPPF.
NPPF paragraph 62 requires strategic policies to be “informed by a local housing need assessment, conducted using the standard method”. Planning Practice Guidance1 supports this further, stating that: “The National Planning Policy Framework expects strategic policy-making authorities to follow the standard method in this guidance for assessing local housing need. The standard method uses a formula that incorporates a baseline of local housing stock which is then adjusted upwards to reflect local affordability pressures to identify the minimum number of homes expected to be planned for.
The standard method set out below identifies a minimum annual housing need figure, and ensures that plan-making is informed by an unconstrained assessment of the number of homes needed in an area. It does not produce a housing requirement figure”.
Draft Policy Direction 1 states that the SWLP will make provision for at least 1,679 dwellings per annum in line with the findings of the Coventry and Warwickshire Housing and Economic Development Needs Assessment (HEDNA) 2022, with the flexibility to accommodate up to 2,188 dwellings per annum in line with the revised 2024 standard method. The HEDNA was prepared over 2 years ago and does not reflect amendments to the standard method which have given rise to significant increases in local housing need for both Warwick district (+62%) and Stratford-on-Avon district (+103%).
We consider that, in order for the policy to comply with national policy as set out above, the standard method figure of 2,188 dwellings per annum should be the starting point for identifying the housing requirement for the SWLP. We also consider that the Councils should consider whether to make provision for additional housing beyond this figure, particularly in order to assist other LPAs within the Greater Birmingham & Black Country and Coventry and Warwickshire Housing Market Areas towards meeting any unmet needs. We note that the 24 Strategic Growth Options and 12 potential new settlements have a combined capacity of 156,549 dwellings, as set out in the Preferred Options Sustainability Appraisal (Appendix B, Table B.1.1 and Appendix C, Table C.1.1). This means that there is likely to be sufficient capacity for South Warwickshire to meet its own development needs, in addition to contributing towards those of other authorities (for example Birmingham).