Other

ID sylw: 106370

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

Draft Policy Direction 10 currently states that proposed developments should follow the latest housing needs assessment which is currently the HEDNA (2022). While this provides a good baseline, the WMHPAC advises that the SW councils take a flexible and evidence-based approach. It would be beneficial if the SWLP incorporates wording into its policy that sets out various circumstances where it may not be appropriate to follow the housing mix set out in the latest needs assessment, including
viability constraints, physical constraints associated with smaller sites, locational issues etc. This may allow the opportunity for the delivery of more affordable housing in the authority area and would help to ensure the right kind of residential development is being delivered on a case-by-case basis.

Other

ID sylw: 106468

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

Proposed policies need to reflect the urgency and ‘critical’ need for Older Persons’ Housing as well as recognising the many additional benefits delivered when such housing is developed in an area.

RECOMMENDATION:
The updated plan should include a specific and dedicated policy supporting the provision of housing for older people. The policy should acknowledge the additional value gained by the provision of dedicated housing for older people which facilitates right sizing in the housing market as well as the potential to achieve significant savings for healthcare together with the social and economic value added to the lives of older people in the area.
The following is a suggested form of wording which may be useful as a starting position for the council to draft a dedicated policy.
“The Council will encourage the provision of specialist housing for older people across all tenures in sustainable locations.
The Council aims to ensure that older people can secure and sustain independence in a home appropriate to their circumstances by providing appropriate housing choice,
particularly retirement housing and Extra Care Housing/Housing with Care. The Council will, through the identification of sites, allowing for windfall developments,
and / or granting of planning consents in sustainable locations, provide for the development of retirement accommodation, residential care homes, close care, Extra
Care and assisted care housing and Continuing Care Retirement Communities. The council recognises the significant health and wider economic benefits associated
with the provision of dedicated housing for older people and will strongly encourage new provision of such housing in sustainable locations”

Yes

ID sylw: 106511

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We broadly support the principle that the SWLP should deliver a range of housing of differing sizes, types
and tenures.
However, housing mix policies are oft drafted in a rigid manner, with little opportunity for flexibility of
application to reflect site specific circumstances.
For example, a town centre site is rarely able to deliver family housing, and nor need it given that town
centre living is a housing market in and of itself. Conversely, with town centre sites delivering smaller
housing types those sites in edge of settlement locations should deliver larger family type housing. Put
simply, the policy should be drafted to allow for a range of housing types and tenures across the plan area,
rather than across individual sites. The Councils could keep an up to date annual monitor to establish in
each reporting year how the delivery is performing against the objectives of Policy Direction 10.
Insofar as housing tenures, the NPPF sets out what is now considered to be affordable tenures in meeting
affordable housing need. We strongly support first homes and other forms of discount from open market
level, which provides for ‘second tier’ affordable provision delivered by the private sector without the need
for any public intervention.

Other

ID sylw: 106571

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Edward Muntz

Asiant : Sworders

It is noted that Draft Policy Direction 10 is still clearly in the development stages and are policy directions with insufficient information on what the wording of the policy will be, along with several other policies within the plan. Interested parties should have the opportunity to consult on the draft policy wording within the plan before a submission version of the plan is published at Regulation 19.

Other

ID sylw: 106591

Derbyniwyd: 06/03/2025

Ymatebydd: The Umberslade Estate

Asiant : Sworders

It is noted that Draft Policy Direction 10 is still clearly in the development stages and are policy directions with insufficient information on what the wording of the policy will be, along with several other policies within the plan. Interested parties should have the opportunity to consult on the draft policy wording within the plan before a submission version of the plan is published at Regulation 19.

No

ID sylw: 106647

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

In its current form Draft Policy Direction 10 is not considered detailed enough for WPDG to be clear as to approach that will ultimately be pursued in the submission SWLP. For this reason we support the Draft Policy Direction in principle only, and reserve the right to comment further on this matter once the updated SHMA is published and the Councils have set out more clearly its approach to providing the right tenure and type of housing to meet the diverse needs of all residents in South Warwickshire.
We do, however, wish to restate our preference that separate affordable housing requirements are provided in the SWLP for Stratford-on-Avon and Warwick Districts; doing so would be appropriate in terms of reflecting local requirements and viability considerations.
Table 8.5 of the HEDNA highlights the income gap between private renting and buying. Table 8.45 of the HEDNA identifies a total need for affordable housing (rented and affordable home ownership) of 547 dwellings per annum in Stratford on Avon and 830 dwellings per annum in Warwick. Affordable housing delivery is therefore a key challenge for the South Warwickshire Local Plan and the best way to significantly increase the supply of affordable housing is to ensure that sufficient deliverable and developable sites are allocated for housing over the plan period. This should include a balanced portfolio of sites, in terms of their size and location. Over reliance in Part 1 of the SWLP on large sites (with issues associated with lead in times and build out rates) we believe would only inhibit the ability to deliver affordable housing and will fail to address affordability problems in South Warwickshire.

Other

ID sylw: 106702

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Ben Pick

Asiant : Sworders

It is noted that Draft Policy Direction 10 is still clearly in the development stages and are policy directions with insufficient information on what the wording of the policy will be, along with several other policies within the plan. Interested parties should have the opportunity to consult on the draft policy wording within the plan before a submission version of the plan is published at Regulation 19.

Other

ID sylw: 106710

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Raymond Randerson

Asiant : Sworders

It is noted that Draft Policy Direction 10 is still clearly in the development stages and are policy directions with insufficient information on what the wording of the policy will be, along with several other policies within the plan. Interested parties should have the opportunity to consult on the draft policy wording within the plan before a submission version of the plan is published at Regulation 19.

Other

ID sylw: 106718

Derbyniwyd: 06/03/2025

Ymatebydd: Mrs Maureen Randerson

Asiant : Sworders

It is noted that Draft Policy Direction 10 is still clearly in the development stages and are policy directions with insufficient information on what the wording of the policy will be, along with several other policies within the plan. Interested parties should have the opportunity to consult on the draft policy wording within the plan before a submission version of the plan is published at Regulation 19.

Other

ID sylw: 106819

Derbyniwyd: 27/02/2025

Ymatebydd: Pauline Prestt

I do not disagree in principle with new housing development but please ensure that adequate provision is made for social housing.
Please also provide a selection of bungalows for older people in the area.

Yes

ID sylw: 106947

Derbyniwyd: 03/03/2025

Ymatebydd: Coventry and Warwickshire ICB

The ICB is supportive of the policy direction that allow for new homes that meet the diverse needs of all residents, in
particular affordable housing, student accommodation, older persons and specialist housing, Health and Care workforce is key to our future clinical and delivery model, recognising that these staff groups need access to housing that is affordable for those in lower paid jobs.

No

ID sylw: 106964

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to draft Policy Direction 10 that providing the right tenure and type of homes will only have regard to the latest evidence. This should be one of a few factors. The latest evidence is the Coventry and Warwickshire HEDNA 2022, which, as already stated above, is based on the old standard method figures. Existing evidence will become out of date during the lifetime of the plan. Housing mix and tenures should be left to be agreed on a site-by-site basis and informed by market demand at the time of the application as that is the best indicator of need.

Other

ID sylw: 106999

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Wotherspoon

Asiant : Sworders

It is noted that Draft Policy Direction 10 is still clearly in the development stages and are policy directions with insufficient information on what the wording of the policy will be, along with several other policies within the plan. Interested parties should have the opportunity to consult on the draft policy wording within the plan before a submission version of the plan is published at Regulation 19.
We consider that the best way to significantly increase the supply of affordable housing across South Warwickshire is to provide the policy context which enables developments to come forward in a range of settlements, which provide a mix of affordable and market housing to meet local housing needs. This provides an incentive to developers to bring sites forward, ensures the viability of development proposals, and provides a mix of housing to meet an identified requirement. This strategy also increases the flexibility of the Plan to ensure consistent housing delivery in changing circumstances and avoids the issue of an over reliance on significant infrastructure provision before housing can be delivered.

Other

ID sylw: 107006

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Davies

Asiant : Sworders

It is noted that Draft Policy Direction 10 is still clearly in the development stages and are policy directions with insufficient information on what the wording of the policy will be, along with several other policies within the plan. Interested parties should have the opportunity to consult on the draft policy wording within the plan before a submission version of the plan is published at Regulation 19.

Other

ID sylw: 107120

Derbyniwyd: 06/03/2025

Ymatebydd: Mr and Mrs Marvelly

Asiant : Sworders

It is noted that Draft Policy Direction 10 is still clearly in the development stages and are policy directions with insufficient information on what the wording of the policy will be, along with several other policies within the plan. Interested parties should have the opportunity to consult on the draft policy wording within the plan before a submission version of the plan is published at Regulation 19.

Other

ID sylw: 107214

Derbyniwyd: 06/03/2025

Ymatebydd: Catesby Estates

Asiant : Mr Will Whitelock

We consider providing a separate affordable housing requirement for Stratford-on-Avon and Warwick Districts would be appropriate in terms of reflecting local requirements and local viability calculations. However, it is considered that the tenure and type of affordable homes sought should be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. Catesby Estates support a collaborative approach to identifying site-specific affordable housing requirements, including tenure and type of affordable homes to be provided on-site.

No

ID sylw: 107262

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

The Cotswolds National Landscape (CNL) Board considers that the current wording of Draft Policy Direction 10 is too vague for us to be able to say whether we agree with the approach laid out.
Policy CE15 of the CNL Management Plan states that ‘housing delivery in the Cotswolds National Landscape (CNL) should be focused on meeting affordable housing requirements, particularly housing that is affordable in perpetuity such as social rented housing’.14
The justification for this approach is set out in the Board’s Housing Position Statement.15
The emphasis on social rent housing is reflected in the National Planning Policy Framework (NPPF), which now requires planning policies to ‘specify … the minimum proportion of Social Rent homes required’.16 This new requirement was introduced to support the Government’s objectives around boosting delivery of Social Rent. The Government expects that many areas will give priority to Social Rent in the affordable housing mix they seek, in line with their local needs, and this is something that the Government strongly supports.17 We consider that identifying the minimum proportion of Social Rent homes required is a key, measurable component of demonstrating consistency with Policy CE15 of the CNL Management Plan.
We recommend that Draft Policy Direction 10 should explicitly reflect the approach advocated in Policy CE15 of the CNL Management Plan.

Other

ID sylw: 107324

Derbyniwyd: 07/03/2025

Ymatebydd: Stratford-on-Avon District Social Inclusion Partnership

Consideration should be made to whether the housing needs of more vulnerable, less mobile groups that rely most significantly on the provision or public and VCS services to maintain their health and wellbeing, access services and employment, should have housing in these more rural locations.

In addition to the above, too many homes in attractive rural areas are becoming holiday homes or holiday lets. Where properties are not primarily used as a fulltime home this can have implications for the social cohesion of a community. Steps should be taken through planning policies to ensure that this activity, is discouraged.

Yes

ID sylw: 107515

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We broadly support the principle that the SWLP should deliver a range of housing of differing sizes, types and tenures.
However, housing mix policies are often drafted in a rigid manner, with little opportunity for flexibility of application to reflect site specific circumstances and market demand.
For example, a town centre site is rarely able to deliver family housing, and nor need it given that town centre living is a housing market in and of itself. Conversely, with town centre sites delivering smaller housing types those sites in edge of settlement locations should deliver larger family type housing. Put simply, the policy should be drafted to allow for a range of housing types and tenures across the plan area, rather than across individual sites. The Councils could keep an up-to-date annual monitor to establish in each reporting year how the delivery is performing against the objectives of Policy Direction 10.
Insofar as housing tenures, the NPPF sets out what is now considered to be affordable tenures in meeting affordable housing need. We strongly support first homes and other forms of discount from open market level, which provides for ‘second tier’ affordable provision delivered by the private sector without the need for any public intervention, which are more deliverable given the lack of appetite from registered providers to purchase built S106 homes, as has been widely experienced nationally since the interest rate rises of 2022.

Other

ID sylw: 107618

Derbyniwyd: 07/03/2025

Ymatebydd: Network Rail

Asiant : CBRE

Network Rail does not object in principle to development, including housing and similar
allocations, close to the railway. It is important however such development does not restrict
existing or likely future operational rail requirements in line with the ‘agent of change’
principle established in paragraph 200 of the National Planning Policy Framework (“NPPF”).

It is therefore requested that any future new settlement and housing allocations, and general
policies concerned with the development of housing (e.g. pursuant to Policy Direction 25)
include a criterion that development should not impact on the railway or the ability to carry
out activities reasonably necessary for its ongoing operation. It is additionally recommended
that the Plan refers to the need for appropriate Asset Protection Agreements to be entered
into to protect railway infrastructure as part of future development.

Additionally, Network Rail requests that they be involved in discussions for any major new
settlement or similar proposals that could have implications in terms of requirements for new
and / or enhanced rail infrastructure.

Other

ID sylw: 107671

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Yes, Cala agrees with the general approach of Draft Policy Direction 10. Cala agrees that it is vital for new homes to meet the needs of both current and future occupiers to ensure that there is a wide range of tenures and types of homes that cater to the needs of the wider population of South Warwickshire.
Cala supports the council’s approach to have regard to the latest evidence in drafting policies relating to housing tenure and type but recommends that flexibility is factored into policy to account for new evidence, changing needs and site-specific characteristics to ensure the delivery of different tenures and types of homes reflects up to date needs.
Cala recommends that it is critical for South Warwickshire to test a variety of different affordable housing levels through Viability Assessment to ensure that the deliverability of the proposed SWLP is not undermined.

Other

ID sylw: 107689

Derbyniwyd: 04/03/2025

Ymatebydd: Pete Frteeman

It is my belief that the UK model of housing is deeply flawed and what is referred to as "The Housing ladder" should be deconstructed starting with the immediate removal of "buy to let" mortgages that underlie property speculation and hence house price inflation, thereby impacting on the ability of the young to purchase at a reasonable price. Get rid of these financial vehicles and by all means build a mix of housing to cater for those on a low budget. (Preferably on Brown field sites).

No

ID sylw: 107739

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We object to draft Policy Direction 10 that providing the right tenure and type of homes will only have regard to the latest evidence. This should be one of a few factors. The latest evidence is the Coventry and Warwickshire HEDNA 2022, which, as already stated above, is based on the old standard method figures. Existing evidence will become out of date during the lifetime of the plan. Housing mix and tenures should be left to be agreed on a site-by-site basis and informed by market demand at the time of the application as that is the best indicator of need.

No

ID sylw: 107789

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to draft Policy Direction 10 that providing the right tenure and type of homes will only have regard to the latest evidence. This should be one of a few factors. The latest evidence is the Coventry and Warwickshire HEDNA 2022, which, as already stated above, is based on the old standard method figures. Existing evidence will become out of date during the lifetime of the plan. Housing mix and tenures should be left to be agreed on a site-by-site basis and informed by market demand at the time of the application as that is the best indicator of need.

Other

ID sylw: 107829

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This provides little direction. It is solely a statement that the Councils will have regard to latest evidence when drafting this policy in full. The Further Advice on Housing & Employment Land Needs report concludes that there is an acute affordability problem in the area and housing provision above the standard method level would be needed to meet South Warwickshire’s full affordable housing needs. Stratford’s 22/23 AMR shows that 32% of net dwellings in the plan period have been affordable, below the 35% Core Strategy policy requirement. Warwick’s AMR identifies that the annual need for 374 affordable dwellings has only been met 3 times since the start of the plan period. The number of households on the two Councils’ housing registers has increased from 7,048 in April 2021 to 7,684 in April 2023.

The HEDNA identified a need for 4,200 units of specialist housing, and 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 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. Policy requirements for housing for older people must be justified by the latest evidence.

Yes

ID sylw: 107859

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey agree that the policy should reflect the most up to date evidence.
However, the policy should be flexible and able to respond to changes to evidence at any point after the policy is adopted.

Yes

ID sylw: 107904

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Yes, paragraph 63 of the NPPF states that the size, type and tenure of housing needed for
different groups (including those who require affordable housing) should be reflected in
planning policies. Paragraph 32 states that all policies should be “underpinned by relevant
and up-to-date evidence”, which “should be adequate, proportionate and focussed tightly
on supporting and justifying the policies concerned.” Terra therefore agrees that the SWAs
should have regard to the latest evidence in drafting policies relating to housing tenure and
type in due course, in accordance with the NPPF.
2.84 In addition, Paragraph 16(d) of the NPPF states that policies should be “clearly written and
unambiguous, so it is evident how a decision maker should react to development
proposals.” In addition, Paragraph 34 clearly states that:
“Plans should set out the contributions expected from development. This should include
setting out the levels and types of affordable housing provision required, along with other
infrastructure (such as that needed for education, health, transport, flood and water
management, green and digital infrastructure). Such policies should not undermine the
deliverability of the plan.”
2.85 The NPPF is also clear that planning policies should have regard to the economic viability of
sites (Para 72) and should not undermine the deliverability of the Local Plan (Para 35). Crucially, both the NPPF and PPG are clear that contributions should be tested through the
viability process, so as to ensure that they do not undermine the deliverability of the plan.
2.86 In this regard, it is acknowledged that the SWAs have not quantified a proposed affordable
housing requirement yet. The PPG7 is also clear that the SWLP should seek to meet as much
of its identified affordable housing needs as possible, albeit, the SWLP is not required to
meet its affordable needs in full.8 In this context, it will be critical for the SWAs to test
different requirements through the Viability Assessment to ensure that it would not
undermine the deliverability of the SWLP on the whole (i.e. Para 34) – this will particularly
be the case for allocations within the Green Belt within the context of the NPPF’s ‘Golden
Rules’ (Paras 67, 68 and 156a).
2.87 Notwithstanding the above, Terra would also support the inclusion of a viability caveat
within the future affordable housing policy to enable flexibility where it is required and can
be justified. The NPPF is clear that planning policies should be flexible enough to adapt to
unforeseen circumstances and changing economic conditions (Paragraph 82d). As such,
Terra considers that such a caveat would allow developers to react flexibly to changing
economic circumstances, and suggests the below wording:
“Lower proportions of affordable housing will only be accepted where a viability
assessment, prepared in accordance with national planning policy and guidance, clearly
demonstrates that the full policy requirement cannot be achieved.”

Other

ID sylw: 107929

Derbyniwyd: 07/03/2025

Ymatebydd: Barwood Land

Asiant : Pegasus Group

The Further Advice on Housing & Employment Land Needs report shows that there is an acute affordability problem in the area and housing provision above the standard method level would be needed to meet South Warwickshire’s full affordable housing needs. Stratford’s 22/23 AMR shows that 32% of net dwellings in the plan period have been affordable, below the 35% Core Strategy policy requirement. Warwick’s AMR identifies that the annual need for 374 affordable dwellings has only been met 3 times since the start of the plan period. The number of households on the two Councils’ housing registers has increased from 7,048 in April 2021 to 7,684 in April 2023.

To ensure the policy is sound, it should specify the type of affordable housing required (including the minimum proportion of Social Rent homes required), with reference to local needs identified in the evidence base, in line with NPPF Paragraph 64 of the NPPF. This will ensure that the policy is justified and sound. The HEDNA identified a need for 4,200 units of specialist housing, and 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 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. Policy requirements for housing for older people must be justified by the latest evidence.

Other

ID sylw: 107947

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

This provides little direction. It is solely a statement that the Councils will have regard to latest evidence when drafting this policy in full. The Further Advice on Housing & Employment Land Needs report concludes there is an acute affordability problem in the area and housing provision above the standard method level would be needed to meet South Warwickshire’s full affordable housing needs. Stratford’s 22/23 AMR shows 32% of net dwellings in the plan period have been affordable, below the 35% Core Strategy policy requirement. Warwick’s AMR shows the annual need for 374 affordable dwellings has only been met 3 times during the plan period. The number of households on the two Councils’ housing registers has increased from 7,048 in April 2021 to 7,684 in April 2023.

To be justified and sound the policy should specify the type of affordable housing required (including minimum proportions of Social Rent homes required), with reference to evidence of local need, in line with NPPF Paragraph 64. This will ensure that the policy is justified and sound.

The HEDNA identified a need for 4,200 units of specialist housing, and 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 provision of retirement housing, extra care and residential care/nursing home spaces will all be necessary to meet the needs of an ageing population. Policy requirements for housing for older people must be justified by the latest evidence.

Other

ID sylw: 108068

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

This provides little direction. It is solely a statement that the Councils will have regard to latest evidence when drafting this policy in full. The Further Advice on Housing & Employment Land Needs report concludes that there is an acute affordability problem in the area and housing provision above the standard method level would be needed to meet South Warwickshire’s full affordable housing needs. Stratford’s 22/23 AMR shows that 32% of net dwellings in the plan period have been affordable, below the 35% Core Strategy policy requirement. Warwick’s AMR identifies that the annual need for 374 affordable dwellings has only been met 3 times since the start of the plan period. The number of households on the two Councils’ housing registers has increased from
7,048 in April 2021 to 7,684 in April 2023.

The HEDNA identified a need for 4,200 units of specialist housing, and 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 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. Policy requirements for housing for older people must be justified by the latest evidence.