Yes

ID sylw: 105475

Derbyniwyd: 03/03/2025

Ymatebydd: Manor Oak Homes Limited

Asiant : Jeremy Flawn

The wider Spatial Growth Strategy: in particular the objectives of concentrating greenfield development into fewer, larger areas of strategic growth; using locations which are within reach of existing facilities, or providing new facilities on site; considering the potential for one or more new settlements; and building at densities that make efficient use of land. Land at Long Marston is an excellent location for a new settlement and the Site that is the subject of these representations can support the delivery of that new settlement over the Plan
period.
Figures 5 and 6: The Spatial Growth Priority Areas and Strategy Options are noted and
supported in principle

Other

ID sylw: 105697

Derbyniwyd: 03/03/2025

Ymatebydd: Warwickshire Property Development Ltd

Asiant : Carter Jonas

We support the proposed 25-year plan period from 2025 to 2050 in the South Warwickshire Local Plan Preferred Options Consultation, aligning with the Council's goal to adopt the Plan by December 2027. This allows for a 23-year period post-adoption, meeting the minimum 15-year requirement. However, given that the plan includes larger scale developments, we recommend amending the vision to extend to a 30-year period to comply with national policy, as outlined in paragraph 22 of the NPPF (2024).

Other

ID sylw: 105699

Derbyniwyd: 03/03/2025

Ymatebydd: Warwickshire Property Development Ltd

Asiant : Carter Jonas

We understand that the South Warwickshire Local Plan was drafted before the government released the revised NPPF (2024), which changes the housing need calculation methodology. The new standard method requires a 0.8% increase in housing stock and includes an affordability adjustment, eliminating the previous urban uplift. The updated figures show a significant increase in housing need for both SDC and WDC, amounting to a total of 2,188 dwellings per annum. While we support the Council's approach of using the new standard method, we recognise that this is a minimum and should account for factors like economic growth and infrastructure

Other

ID sylw: 105701

Derbyniwyd: 03/03/2025

Ymatebydd: Warwickshire Property Development Ltd

Asiant : Carter Jonas

We believe the Plan should incorporate flexibility to address potential delays in site development, particularly with larger strategic sites. South Warwickshire faces significant affordable housing challenges, with high prices and many households unable to afford private rentals. The Housing and Economic Needs Assessment indicates a requirement for 1,398 affordable homes per annum across the area. If the proposed housing need of 2,188 dpa is to be met, around 64% must be affordable, which seems unviable. We recommend an uplift in housing need to ensure affordable housing delivery. An economic uplift appears unnecessary at this time but should be kept under review.

Other

ID sylw: 105702

Derbyniwyd: 03/03/2025

Ymatebydd: Warwickshire Property Development Ltd

Asiant : Carter Jonas

The Consultation Document states that since the publication of the HEDNA, the West Midlands Strategic Sites Study (WMSESS) has identified an overall need for strategic sites across the West Midlands, for B2 and B8 use and identified opportunity areas for strategic sites, assigning them a notional quantum.

In addition to Road Opportunity Areas, where 75-125ha. of strategic employment need is identified in Road Opportunity 8 (located entirely within South Warwickshire), the WMSESS (2024) also identifies a Study-area wide need for 67 ha to 135 ha for rail needs. This indicates a likely need for a new strategic rail freight interchange (SRFI) site within the study period (2022 – 2045).

We support the proposed upper threshold employment need figure being used, but do not believe that it should be regarded as a ceiling.

Other

ID sylw: 105703

Derbyniwyd: 03/03/2025

Ymatebydd: Warwickshire Property Development Ltd

Asiant : Carter Jonas

Draft Policy Direction 1 aims to meet South Warwickshire's housing needs through existing commitments, windfall, and new allocations. SDC and WDC have 17,068 existing commitments, but I recommend a full review to ensure these are deliverable. The proposed windfall allowance of 375dpa may need reassessment based on factors like housing land supply and market demand. I believe we should be cautious about relying on recent windfall rates, as new Local Plan allocations may decrease this provision. The WPDG site can contribute around 500 dwellings and additional facilities towards meeting the housing

Other

ID sylw: 105707

Derbyniwyd: 03/03/2025

Ymatebydd: Warwickshire Property Development Ltd

Asiant : Carter Jonas

We support the proposed 25-year plan period from 2025 to 2050 in the South Warwickshire Local Plan Preferred Options Consultation, aligning with the Council's goal to adopt the Plan by December 2027. This allows for a 23-year period post-adoption, meeting the minimum 15-year requirement. However, given that the plan includes larger scale developments, we recommend amending the vision to extend to a 30-year period to comply with national policy, as outlined in paragraph 22 of the NPPF (2024).

Other

ID sylw: 105709

Derbyniwyd: 03/03/2025

Ymatebydd: Warwickshire Property Development Ltd

Asiant : Carter Jonas

We understand that the South Warwickshire Local Plan was drafted before the government released the revised NPPF (2024), which changes the housing need calculation methodology. The new standard method requires a 0.8% increase in housing stock and includes an affordability adjustment, eliminating the previous urban uplift. The updated figures show a significant increase in housing need for both SDC and WDC, amounting to a total of 2,188 dwellings per annum. While we support the Council's approach of using the new standard method, we recognise that this is a minimum and should account for factors like economic growth and infrastructure

Other

ID sylw: 105711

Derbyniwyd: 03/03/2025

Ymatebydd: Warwickshire Property Development Ltd

Asiant : Carter Jonas

I believe it is essential to assist neighbouring Authorities in addressing unmet housing needs, aligned with the duty to cooperate and national policy soundness tests. WDC and SDC are part of two housing market areas, and there is an indication of potential unmet need that requires further investigation. The South Warwickshire Local Plan should be flexible enough to accommodate this need as it develops. I recommend that the information on housing needs be made publicly available to ensure transparency and that South Warwickshire continuously reviews its capacity to meet these needs effectively.

Other

ID sylw: 105712

Derbyniwyd: 03/03/2025

Ymatebydd: Warwickshire Property Development Ltd

Asiant : Carter Jonas

The Consultation Document states that since the publication of the HEDNA, the West Midlands Strategic Sites Study (WMSESS) has identified an overall need for strategic sites across the West Midlands, for B2 and B8 use and identified opportunity areas for strategic sites, assigning them a notional quantum.

In addition to Road Opportunity Areas, where 75-125ha. of strategic employment need is identified in Road Opportunity 8 (located entirely within South Warwickshire), the WMSESS (2024) also identifies a Study-area wide need for 67 ha to 135 ha for rail needs. This indicates a likely need for a new strategic rail freight interchange (SRFI) site within the study period (2022 – 2045).

We support the proposed upper threshold employment need figure being used, but do not believe that it should be regarded as a ceiling.

Other

ID sylw: 105713

Derbyniwyd: 03/03/2025

Ymatebydd: Warwickshire Property Development Ltd

Asiant : Carter Jonas

Draft Policy Direction 1 aims to meet South Warwickshire's housing needs through existing commitments, windfall, and new allocations. SDC and WDC have 17,068 existing commitments, but I recommend a full review to ensure these are deliverable. The proposed windfall allowance of 375dpa may need reassessment based on factors like housing land supply and market demand. I believe we should be cautious about relying on recent windfall rates, as new Local Plan allocations may decrease this provision. The WPDG site can contribute around 500 dwellings and additional facilities towards meeting the housing

No

ID sylw: 105747

Derbyniwyd: 06/03/2025

Ymatebydd: HG Hodges Ltd

Asiant : Ridge and Partners LLP

Draft Policy Direction 1 addresses housing needs for the new SWLP, referencing the 2022 Coventry & Warwickshire HEDNA and the Standard Method as outlined by the NPPF. However, it lacks a firm commitment to the required housing level. The SWLP should adhere to the Standard Method for determining housing need to ensure compliance with national policy and soundness. It is therefore recommend to plan for at least 2,188 dwellings per annum, with any deviations needing robust justification to avoid the plan being deemed unsound at examination.

Other

ID sylw: 105755

Derbyniwyd: 06/03/2025

Ymatebydd: Berrys

Draft Policy Direction 1 outlines the need for 54,700 dwellings over 25 years in South Warwickshire, with a shortfall of 37,632 after accounting for 17,068 committed dwellings. I believe the Council's calculations lack a necessary buffer and fail to justify a windfall allowance of 9,375. I suggest that the Council consider additional sites, particularly Lodge Farm, which could provide around 720 dwellings, including affordable and retirement housing. This site is well-connected and aligns with spatial growth priorities, thus addressing local housing needs effectively.

Yes

ID sylw: 105762

Derbyniwyd: 07/03/2025

Ymatebydd: Wates Developments Ltd

Asiant : Savills

Wates Developments support Draft Policy Direction 1, which identifies a non-strategic industrial need of 217ha in the SWLP area, mainly in Stratford-on-Avon district. The 32ha site at Coppington Farm, within Strategic Growth Option SG15, is well-suited for non-strategic employment development due to its proximity to the M40 and Wellesbourne. The development aligns with local economic strategies and is expected to enhance economic growth, diversify employment, and support sustainable infrastructure improvements. Overall, Coppington Farm is an ideal location for B-class employment development to support local need and continued growth. See Appendix 1 for more details.

No

ID sylw: 105917

Derbyniwyd: 06/03/2025

Ymatebydd: Sworders

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 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 is very excessive.
Regard should be taken to how the delivery of new settlements provides a more sustainable community and economy with the provision of new infrastructure, schools and amenities being included as part of such developments.
Under the new method the shortfall in delivery will then be carried forward into the next five-year period. Without the allocation of new settlements, the housing and employment land provision will risk being in deficit for a significant part of the plan period,
as such we would like to emphasise our client’s land’s availability, suitability and deliverability to deliver the significant housing numbers required by the new methodology which should be used

No

ID sylw: 105979

Derbyniwyd: 06/03/2025

Ymatebydd: Nick Chambers

The housing “needs” set out in Table 2 (HEDNA method) and Table 3 (2024 NPPF standard method) have little in the way of justification. The Opportunity Areas identified in WMSESS are primarily clustered in North Warwickshire and counties further north; whilst those Areas 7 (Coventry & Rugby), 8 (M40/A46), and 9 (Redditch & Bromsgrove) closer to South Warwickshire are much less favourable and therefore unlikely to attract business investment. Their projected level of employment is small, and relevant only to the northernmost areas of Stratford-on-Avon. With a need for housing to be located close to employment, it is inappropriate and unreasonable to group all of South Warwickshire into a single region.

Indeed, South Warwickshire is noted as having “a more service-orientated economy and higher housing costs”, in line with its more rural nature and much lower population density.

The 2014-based projections for Stratford-on-Avon given in Table 3.1 of the HEDNA Executive Summary 171122 is for 564 houses. Section 3.6 goes on to state that “it is reasonable and expected that any alternative trend-based projection would show a lower need” and Section 3.7 argues that employment growth is slowing and that “there is therefore no case for adjusting upwards overall housing need.”

However, this conflicts with Table 2 (HEDNA method) that seeks to increase the housing needs from 564 to 868 houses, an increase of over 50% ! The only justification given is “unmet needs from Birmingham and Coventry & Warwickshire”. However, as stated on page 43, “Until there is greater certainty regarding the quantum of unmet needs from neighbouring housing market areas, it is premature to allocate reserve housing sites. The latest evidence and further discussions with neighbouring authorities will inform the Regulation 19 Submission policies on unmet housing need. If reserve housing sites are needed, the SWLP process will consider suitable sites which may include draft reserve housing allocations in Stratford-on-Avon District Council’s Site Allocation Plan (SOADC SAP).”



Furthermore, given the lack of sustainable transport infrastructure between South Warwickshire and Birmingham/Coventry, then it is completely unreasonable to argue that housing in South Warwickshire should meet the needs of Birmingham/Coventry. These areas are closer to other county districts than to South Warwickshire, particularly when enabling road infrastructure is taken into consideration.

It is therefore even more unreasonable in Table 3 (2024 NPPF standard method) to propose a target of 1126 houses within Stratford District, which is DOUBLE that of the 2014-based projections. This level of housing demonstrably cannot be supported by local employment opportunities. Indeed, reference is made to Abbey Park in the Warwick District that “has faced deliverability challenges since consent and questions remains around the market attractiveness of the site in terms of its rural locations”. This observation is a clear market signal around the problems of creating employment opportunities in rural locations.

The housing needs for Stratford-on-Avon should be based upon figures much closer to the 2014-based projections of 564 houses per annum. This can be met from existing commitments and windfall allowance, and therefore reduces the To-Find figure for Stratford-on-Avon to zero.

No

ID sylw: 106015

Derbyniwyd: 03/03/2025

Ymatebydd: Chris Dix

As a long term resident of Kenilworth I wish to register my disapproval of any further development in Kenilworth and Warwickshire in general.
The massive over development in the town has led to a level of degradation I never envisaged taking place.
Combined with the HS2 debacle and the inability to sustain and improve road surface conditions Warwickshire CC have demonstrated that they are not fit for purpose.
Repeated temporary traffic lights, road closures and misguided spending on inappropriate schemes has led to a feeling of frustration by many in the town.
Recent diversions due to road closures illustrates a total lack of joined up thinking and a failure to recognise the wishes and concerns of residents.

No

ID sylw: 106141

Derbyniwyd: 07/03/2025

Ymatebydd: Julian and Emma Philcox

Nifer y bobl: 2

The 5 year housing land supply (5YLS) for SuA District at April 2024 was 24.65 years. Frankly, this is a ridiculous figure and more than hints at a position of over-supply and with that the position that infrastructure is likely lagging behind supply. By comparison, in April 2023 Warwick District had 7.16 years (the latest update published).

Has this truly been factored in when projecting forward likely housing need?

Secondly, are there enough checks in place to ensure that surrounding authorities are rigorously trying to meet their own housing need, such that it doesn’t unnecessarily fall on SuA/Warwick District to meet.

No

ID sylw: 106185

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

The SWLP does not set out firm proposals. It lists 12 potential new settlements and yet it is implied only a handful will be taken forward. By implication most new development will be accommodated on large strategic sites, each having to build a range of services and facilities from scratch. This is unsustainable as it as it will leave older established towns (and villages) where services may be struggling, to decline and wither on the vine. This may be convenient for politicians to avoid objections from local people but towns and villages need to grow ‘organically’ to survive and thrive.

In practice any growth option will need to be a hybrid of all 5 options (and others). The choices are not mutually exclusive and the practical solution must reflect all needs across the two districts. The Councils have apparently rejected No.5 ‘Dispersal’ because a marginally larger proportion said it would be inappropriate rather than appropriate, but It would be catastrophic to abandon Warwickshire’s villages from new development just because a theoretical question produced a ‘wafer thin’ preference for a more concentrated strategy. This will lead to a cycle of decline in rural areas and move towards mediocrity elsewhere.

No

ID sylw: 106186

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

The December 2024 NPPF and the new Standard Method figures have completely altered the context for the Plan’s housing requirements. Authorities cannot submit figures which don’t conform to the Standard Method without clear justification. The housing proposals will need to conform with Table 3 of the Plan, subject to additional unmet need from other authorities (such as Birmingham and the Black Country) which have yet to be factored in. Draft Policy Direction 1 needs to be adjusted accordingly and Table 2 should be deleted. This is important since the new standard method figures are 30% higher.

We would expect most of South Warwickshire’s housing needs to be accommodated within Priority Areas 1, 2 and 3 and accompanied by associated infrastructure. This should not preclude development in smaller settlements. Some development is essential to meet market demand and local needs in communities and use existing infrastructure more efficiently. Paragraph 77 of the NPPF provides an option, not an instruction. The Growth Locations and Potential New Settlements should not ‘soak up’ all residual housing and investment – provision of new infrastructure and facilities is a very expensive option.

The Government has signalled a new approach to Green Belt, including introducing ‘grey belt’. This should trigger green belt reviews at strategic level and locally where necessary within smaller communities – such as Offchurch, where the local pub has closed partly due to a lack of modest organic growth. Elsewhere shops are closing, bus routes are being withdrawn and schools are at risk.

Other

ID sylw: 106204

Derbyniwyd: 07/03/2025

Ymatebydd: Sir Richard Hamilton Will Trust

Asiant : Carter Jonas

Planning for the right number of new homes is vital to the sustainable future of South Warwickshire. This is to meet the needs of all parts of the community, including key workers, older people, and those who cannot afford market housing.

The Trust believes that the Councils should accept the Standard Method as the minimum housing requirement; the Councils’ evidence demonstrates that this minimum figure is achievable, and any flexibility should be built on top of the Standard Method number. It is unlikely that a strategy which does not set the Standard Method as the minimum housing need figure will be found ‘sound.’

Paragraph 62 of the NPPF explains that:

“To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance.”

The Trust would be open to a discussion with the Council about how to deliver sustainable growth in the long term, focusing on creating place and connected communities. The Trust believes that its land could have a strong role to play in this strategic vision.

No

ID sylw: 106342

Derbyniwyd: 27/02/2025

Ymatebydd: Neil Francis

Any new housing should be proportionate in scale to the existing settlements for the reasons set out above.
To reiterate
Development of the suggested scale would be totally out of character for a semi-rural village like Hockley Heath.
There are currently around 1900 residents in Hockley Heath and around 500 households. The suggested proposals are to add 2,875 houses with 6 parcels across 133.51 hectares. This is more than five times the size of the existing village which is entirely disproportionate.
Development of the suggested scale is therefore not sustainable and would place a significant and unacceptable demand on local services. Your Sustainability Appraisal (para 5.6.1) acknowledges the potential impact to Grade II Listed Buildings. Parcel HOH1 is adjacent to properties 2301 and 2303 Stratford Road and parcels HOH3 and HOH4 are adjacent to St Thomas’s Church, Nuthurst Lane. The proposals are likely to cause significant harm to the setting of these designated heritage assets.
The Sustainability Appraisal also places Hockley Heath within the bottom five in terms of its negative scores for access to A&E services, GP surgeries and leisure facilities. It views the primary school being within 800m of the parcels as a positive impact but this school has 215 pupils on the school roll, with children from ages 2 to 11. It is a village school and is not going to be able to meet the needs of the additional residents. In terms of mitigation in respect of the health impacts, your appraisal notes that the new infrastructure would require a significant level of investment in health services and leisure facilities which (as noted in the appraisal) is likely to be difficult to achieve. These local services are already under considerable pressure and placing further demands on them would be totally unfair and unacceptable.
The parcels are all in the Green Belt and parcels 1 and 3 are identified as having a moderate contribution. However, it could be argued that some parcels have a strong contribution, notably HOH1 which would bring Hockley Heath significantly closer to Dorridge.
Whilst the suggested allocations are not consistent with the Green Belt review, having regard for the linear form of the village, limited development to parcel HOH6 could retain that form whilst providing a more modest contribution to housing.

No

ID sylw: 106364

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium (WMHAPC)

Asiant : Tetlow King Planning

Draft Policy Direction 1 proposes that the South Warwickshire Local Plan (“SWLP”) will make provision for at least 1,679 dpa in line with the HEDNA (February 2024), with sufficient flexibility to accommodate up to 2,178 dpa, in line with the proposed new Standard Method. This equates to at least 41,975 dwellings over a 25-year plan period between 2025 and 2050, with sufficient flexibility to accommodate up to 54,450 dwellings.
In order to deliver this level of housing growth, the policy direction explains that after accounting for
existing commitments and an assumed windfall allowance, the SWLP will need to accommodate the
delivery of 15,532 dwellings (HEDNA) or 28,257 dwellings (2024 Standard Method). Given the scale of
these figures, it is essential that the Local Plan allocates sufficient sites for development and contains
strategic and detailed policies that do not unduly frustrate the delivery of homes where it is shown there
is significant need.
The HEDNA (2024) identifies that there is an affordable housing need of 1,386 dpa. This equates
affordable housing need equates to 83% of the total housing need of 1,679. Given this significant
proportion of affordable housing need, the WMHAPC is disappointed that this figure has not been addressed as part of the draft Policy Direction 1. We encourage the Council to explicitly include an affordable housing requirement as part of the forthcoming draft policy in order to ensure enough affordable housing is delivered across SW.

No

ID sylw: 106504

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We object to Draft Policy Direction 1.
As drafted, the policy refers to meeting housing requirements as expressed in the HEDNA, with sufficient
flexibility to accommodate the housing requirements as set out in the 2024 Standard Method. We have
some sympathy for the Council; at the time of preparing the Preferred Options SWLP the revisions to the
NPPF, and associated update to the Standard Method, were in draft form only and subject to change.
However, with the revisions to the NPPF and Standard Method now finalised the SWLP should commit to
the Standard Method requirement and make no reference to the HEDNA.
As such, the SWLP should be taken forward having regard to Table 3, which we support. We also support
the housing requirement being expressed as a minimum, to be interpreted as having a floor but not a
ceiling.
Progressing the SWLP based upon the Standard method would be consistent with NPPF paragraph 62,
whilst delivering housing above the Standard Method is acceptable in principle having regard to NPPF
paragraph 69

No

ID sylw: 106537

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Edward Muntz

Asiant : Sworders

In terms of housing delivery, we believe Draft Policy Direction1 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.
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 over-reliance on 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 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, the new South Warwickshire Local Plan
should allocate a greater number of small and medium sized sites. The site at South West of Hockley Heath can contribute to 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.

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.

Other

ID sylw: 106618

Derbyniwyd: 07/03/2025

Ymatebydd: Mac Mic Group

Asiant : McLoughlin Planning

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 not justified and would render the SWLP unsound. This is a point explored in the recent Shropshire Local Plan examination, where the reliance on windfall sites was lower. Paragraph 15 of the NPPF requires the planning system to be ‘genuinely plan-led’. Leaving almost one quarter of housing land supply to chance is not plan-led. As such, additional allocations are required to respond to housing need.

No

ID sylw: 106634

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

No. The policy needs amending so that it is consistent with the NPPF (December 2024), and its stated requirement for use of the "Standard Method" the government-mandated formula to calculate the minimum number of new homes a local area needs to plan for in order to boost housing delivery.
The draft SWLP should have also acknowledged that the proposed ‘Housing Need’ figure is only the starting point and additional housing may be required to facilitate economic growth, the delivery of affordable housing and / or to assist in meeting housing needs that cannot be met within neighbouring areas.
The pre-amble to Draft Policy Direction 4 - Accommodating Growth Needs Arising from Outside South Warwickshire states: ‘It is yet to be established to what extent and what uses (e.g. housing and/or employment) there will be any unmet need from elsewhere within these housing market areas [Coventry and Warwickshire Housing Market Area (HMA) and the Greater Birmingham and Black Country HMA]. Some of this need will be met by other constituent Local Planning Authorities within both HMA’s; however, through Duty to Co-operate discussions; the Councils will commit to continually consider this need and work with those authorities on how this can be achieved.’
the SWLP should provide, as a minimum, the new Standard Method housing requirement for the Plan area. We stress a minimum because other factors indicate that a further uplift in the housing requirement will be required in order to provide the level of affordable housing need identified in the HEDNA and to take account of allocated sites lapsing, non-implementation and the fact that the capacity of sites can often reduce between the outline and reserved matters stages.

No

ID sylw: 106697

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Ben Pick

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 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 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. . 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. Avon Dassett can 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.

No

ID sylw: 106705

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Raymond Randerson

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 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 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. 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. Avon Dassett can 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.