Other

ID sylw: 103222

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Kineton Road, Wellesbourne

Asiant : Turley

Richborough has no objection to the emerging policy direction and agrees that density should be considered in accordance with different types of locations of development.

With regard to the reference to Design Codes, it is recommended that the future policy text for Draft Policy Direction 8 should cross refer to Draft Policy Direction 26 ‘Design Codes’ and the supporting text. Richborough have provided more detailed comments in relation to Design Codes within their response to Draft Policy Direction 26.

Other

ID sylw: 103224

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Wellesbourne Road, Wellesbourne

Asiant : Turley

Richborough has no objection to the emerging policy direction and agrees that density should be considered in accordance with different types of locations of development.

With regard to the reference to Design Codes, it is recommended that the future policy text for Draft Policy Direction 8 should cross refer to Draft Policy Direction 26 ‘Design Codes’ and the supporting text. Richborough have provided more detailed comments in relation to Design Codes within their response to Draft Policy Direction 26.

Other

ID sylw: 103226

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Plough Lane, Bishop's Itchington

Asiant : Turley

Richborough has no objection to the emerging policy direction and agrees that density should be considered in accordance with different types of locations of development.

With regard to the reference to Design Codes, it is recommended that the future policy text for Draft Policy Direction 8 should cross refer to Draft Policy Direction 26 ‘Design Codes’ and the supporting text. Richborough have provided more detailed comments in relation to Design Codes within their response to Draft Policy Direction 26.

Yes

ID sylw: 103358

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Stephen Norrie

I support this policy with a bit of hesitation, and I think density levels in specific design codes could be underpinned by a more general minimum density level.

Yes

ID sylw: 103439

Derbyniwyd: 07/03/2025

Ymatebydd: Mrs Christine Easton

I would have thought it obvious that density would be a factor. We would all like less but handled sympathetically would be key.

No

ID sylw: 103482

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Neal Appleton

Density measurements as used currently lead to creeping over-urbanisation. Pockets of settlement historically have high density, with spaces between. Filling in those spaces at the same density ruin the character of a place. Development patterns with varying density should be encouraged.

No

ID sylw: 104203

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Kenneth Chitty

The required minimum density of dwellings should be clearly defined and clearly allow for multiple occupation buildings - e.g. Correctly designed High Rise buildings. Not specifying a minimum density will merely lead to rows of four bedroom detached houses being built.

Yes

ID sylw: 104207

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Rachel Pope

There are now lots of examples of good practice in densification, including from other countries such as the Netherlands. As such this provides an exciting opportunity for innovative and sustainable design.

Other

ID sylw: 104368

Derbyniwyd: 07/03/2025

Ymatebydd: South Warwickshire Foundation trust

We would seek assurance that development density will have due regard for both avoiding any exacerbation or creation of inequalities in the new and incoming populations, whilst also creating communities with good access to infrastructure, as well as minimising the footprint of new buildings.

Yes

ID sylw: 104440

Derbyniwyd: 07/03/2025

Ymatebydd: Mr ROLAND CHERRY

In general greater density in existing urban areas is much preferable to building on our pastoral landscape. Great emphasis must be placed on repurposing brown field sites within urban areas which has the advantage of improving the urban landscape and provides aspirational housing for people close to their place of work - a win win. Many cities have done this very well - noteworthy are the regenerated docks in both London and Liverpool. More areas of West Midlands conurbations should be developed in such a way rather than "exporting" houses as overspill, thus forcing people to commute great distances.

No

ID sylw: 104529

Derbyniwyd: 07/03/2025

Ymatebydd: Mrs Mary Harman

Too vague, open to increase or decrease density at will and forego impact on rural areas, focussing more on the numbers game for sake of meeting targets.

No

ID sylw: 104683

Derbyniwyd: 07/03/2025

Ymatebydd: Mrs Sarah Whalley-Hoggins

Density will inevitably cause developments to be less desirable than others . Residents still need to be able to park cars and this should be off road. There is not enough detail about the implications of density and what is meant by this in terms of design and living conditions.

No

ID sylw: 104686

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Ian Dunning

Finally you're talking about density., but it is weak.

"areas that would be more suited to higher density development"
"respects and enhances the existing neighbourhood character"

This is weak. Build density everywhere. Parents of kids killed by cars will not be comforted by your "respect for neighbourhood character"

Other

ID sylw: 104766

Derbyniwyd: 07/03/2025

Ymatebydd: Stratford-on-Avon Town Council

Densification for its own sake should be avoided. There is a lot to be said in favour of green spaces within towns and urban environments and they should be preserved wherever possible. An alternative to be encouraged is increasing the occupancy of existing buildings, for example by converting unused floors above shops and commercial buildings into residential use.

Yes

ID sylw: 104840

Derbyniwyd: 07/03/2025

Ymatebydd: Fern Arnold

I'm in favour of densification BUT with wildlife corridors. It is important to consider if infilling will affect biodiversity. Places for bats, birds, foxes, hedgehogs, insects etc. Do look at B lines and consult with Plantlife, Buglife and Warwickshire Wildlife Trust etc.

No

ID sylw: 106195

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

This policy doesn’t actually say anything and therefore serves no real purpose. The case for densification has not been made within the text, it simply states that a Design Code will be produced. This is not a policy.

Other

ID sylw: 106218

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Cala broadly agrees with the approach laid out in Draft Policy Direction 8 to maximise use of land in line with the NPPF but recognises that density ranges may need to vary at different locations to ensure appropriate levels of development, compatible with site characteristics, are delivered across different sites. As stated in relation to DPD 2, it is important that capacity of different land ownerships across the settlement is clearly defined to ensure delivery of the existing, allocated LMAGV is not compromised.

Para 129 of the NPPF notes that planning policies should support development that makes efficient use of land and Para 130 states that is especially important for policies and decisions to avoid low-density building where there is a shortage of land for meeting identified housing needs.

Cala supports the approach of identifying appropriate density ranges in design codes only on the basis that it recognised one size does not fit all. The currently adopted Long Marston Garden Village Framework Masterplan SPD specifies a range of densities according to specific location ranging from 25-55 dph and recommends any design codes which come forward for proposed new settlement E1 carefully consider the densities of the adopted SPD to ensure that the codes do not hinder or conflict with development on the already allocated site. Forthcoming densities should also explore the opportunity to further maximise use of brownfield land where possible.

Yes

ID sylw: 106368

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

The WMHAPC supports the approach outlined in draft Policy Direction 8, as it aims to optimise land use effectively. Accordingly, the WMHAPC welcomes further guidance through a design code to ensure
that densification maximises affordable housing delivery while maintaining high quality homes that respect the local vernacular.
Future policies on density should allow for flexibility and nuance, considering the relationship between density, dwelling size (including implications of optional space and accessible/adaptable home standards), housing mix, and developable land. Future policies should be viability tested to take these factors into account.
Additionally, future policies should consider that when determining applications, the impact on delivering
a diverse range of housing typologies to meet the needs of different groups should be carefully evaluated, with scope for site specific considerations and case by case assessments where appropriate.

Other

ID sylw: 106509

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We consider that policy should avoid expressing specific densities, but instead should make reference to
the NPPF and the need to utilise land efficiently and effectively.
This is in the context of a highly material consideration; that being that density is not an indicator of urban
quality, some of the Councils highest valued urban areas deliver densities at what might be considered to
be very high. By way of worked example, a maisonette doubles the density of a building over a traditional
house but has no material effect on the urban environment.
In any event, it is not considered appropriate to defer densities to Design Codes. These will, according to
the SWLP, follow after the SWLP is progressed. This means that the Councils are unable to establish whateach spatial growth site might deliver in terms of housing yield, which in turn makes it impossible to
robustly set out what sites are required to meet the Standard Method and duty to co-operate. It also means
that site viability, and thus deliverability, cannot be established with promoters since the infrastructure
requirements will be fixed by the SWLP based upon sites with an unquantified yield.

Yes

ID sylw: 106645

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Draft Policy Direction 8 is broadly consistent with the NPPF (Chapter 11 - Making effective use of land) and we recognise that increasing housing densities can have play a positive role in helping meet local housing needs, address affordability concerns, and ultimately promoting sustainable forms of development by making effective use of land.
For a future policy on densities and associated design codes to be effective, a careful balance needs to be struck between seeking to optimise the density of development and ensuring that other development considerations are appropriately considered.
when the Councils are setting density standards we consider that it is also important density levels are realistic and that they take into consideration: • the Councils own housing mix requirements; • the need for developers to also meet other policy requirements that influence the how much development can be delivered on a site, e.g. green infrastructure and open space standards, the mandatory 10% net gain in on-site biodiversity; and, • the nationally described space standard for housing should the Councils decide that this should also become a policy requirement on the SWLP.
Furthermore, developing and implementing design codes requires significant time and expertise. We therefore have concerns about their use and effectiveness, when planning departments are resource and financially constrained.

Other

ID sylw: 106768

Derbyniwyd: 02/03/2025

Ymatebydd: ms louisa graham

Density of building will be inappropriate and its impact on the character of any area will be detrimental.

There will be overshadowing and loss of privacy. Development will not fit with established building, destroying the look of an area. Density of building will be maximised. Profit over all.

Other

ID sylw: 106963

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We support the provision of broad density requirements being proposed and areas suitable for higher density development being indicatively identified. However, the NPPF (paragraph 129) is clear that there are a number of factors which should be considered when assessing whether a scheme makes the most efficient use of land. When it comes to the implementation of minimum density standards, a range should be used to reflect accessibility and potential of different areas (NPPF paragraph 130). Fundamentally, densities should be determined on a site by site basis.
In regards to the production of Design Codes, it is important that these are produced in conjunction with the Sites’ landowners/ promoters / developers to ensure they are deliverable.

Other

ID sylw: 107021

Derbyniwyd: 06/03/2025

Ymatebydd: Ministry of Defence

DTC RESPONSE:

Section 4.10, Policy Direction 8 – Density
The MOD recognises the need for quality design within the planning system. However, there may be
occasions where specific operational or technical requirements of buildings and structures required for
defence purposes can restrict MOD’s ability to change the density of developments to meet local design
2
criteria. It is important therefore that local design codes are not too restrictive and that they recognise the need
for flexibility in such cases.

No

ID sylw: 107513

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We consider that policy should avoid expressing specific densities, but instead should make reference to the NPPF and the need to utilise land efficiently and effectively.
This is in the context of a highly material consideration; that being that density is not an indicator of urban quality, some of the Council’s highest valued urban areas deliver densities at what might be considered to be very high. By way of worked example, a maisonette doubles the density of a building over a traditional house but has no material effect on the urban environment.
In any event, it is not considered appropriate to defer densities to Design Codes. These will, according to the SWLP, follow after the SWLP is progressed. This means that the Councils are unable to establish what each spatial growth site might deliver in terms of housing yield, which in turn makes it impossible to robustly set out what sites are required to meet the Standard Method and duty to co-operate. It also means that site viability, and thus deliverability, cannot be established with promoters since the infrastructure requirements will be fixed by the SWLP based upon sites with an unquantified yield.

Other

ID sylw: 107602

Derbyniwyd: 07/03/2025

Ymatebydd: National Highways

National Highways believes that this is an LHA matter and have no further comments
to provide.

Yes

ID sylw: 107659

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Cala broadly agrees with the approach laid out in Draft Policy Direction 8 to maximise use of land in line with the NPPF but recognises that density ranges may need to vary at different locations to ensure appropriate levels of development, compatible with their site characteristics, are delivered across different sites. As stated, in relation to DPD 2, it is important that capacity of the different land ownerships across the settlement is clearly defined to ensure that delivery of the existing, allocated LMAGV is not compromised.
Cala supports the approach for “Appropriate density ranges for different types and locations of development to be indicated in design codes” in the Draft Policy Direction on the basis that this recognises that ‘not one size fits all.’

Other

ID sylw: 107695

Derbyniwyd: 04/03/2025

Ymatebydd: Pete Frteeman

Densification should only be considered in the case of "quality" low rise buildings, "cheek by jowel sprawl” should by avoided at all costs. The recreation of "Los Angeles" in South Warwickshire should not be a desirable objective!

Other

ID sylw: 107738

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We support the provision of broad density requirements being proposed and areas suitable for higher density development being indicatively identified. However, the NPPF (paragraph 129) is clear that there are a number of factors which should be considered when assessing whether a scheme makes the most efficient use of land. When it comes to the implementation of minimum density standards, a range should be used to reflect accessibility and potential of different areas (NPPF paragraph 130). Fundamentally, densities should be determined on a site by site basis.
In regards to the production of Design Codes, it is important that these are produced in conjunction with the Sites’ landowners/ promoters / developers to ensure they are deliverable.

Yes

ID sylw: 107816

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy is broadly supported as it recognizes a flexible approach to density should be taken. This is consistent with national policy as the NPPF states that densities should be appropriate to the character of the area. Paragraph 130 states that density should reflect the accessibility and potential of different areas. The approach is justified The Guide to Existing Housing Densities Topic Paper provides evidence of the varying existing densities in South Warwickshire.

Yes

ID sylw: 107857

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey has no objection to the emerging policy direction and agrees that density should be considered in accordance with different types of locations of development.
In respect of any overarching Design Code to be adopted by the Council, this should give a degree of flexibility to allow consideration on a site-by-site basis and to ensure it remains adaptable to a changing market.