Other

ID sylw: 108170

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

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.
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.

Yes

ID sylw: 108192

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy Direction 10- Providing the Right Tenure and Type of Homes? 2.72 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.” St Philips 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. 2.73 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.” 2.74 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. 2.75 In this regard, it is acknowledged that the SWAs have not quantified a proposed affordable housing requirement yet. The PPG8 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.9 In this context, it will be critical for the SWAs to test different requirements through the Viability Assessment to ensure that the affordable housing requirement 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). 2.76 Notwithstanding the above, St Philips 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, St Philips 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.” 2.77 Notably, this approach would align with SOADC’s approach within the adopted Core Strategy (i.e. Policy CS.18).

No

ID sylw: 108212

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

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.

Affordable Housing

There is an acute affordability problem across the South Warwickshire Plan area. The HEDNA considered 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.

The Further Advice on Housing & Employment Land Needs 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 NPPG.

Housing for Older People

Any policy requirements for housing for older people must be justified and underpinned by the latest evidence on this matter.

Yes

ID sylw: 108275

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

We support recognition that the SWLP should provide the right tenure and the right type of housing. The Justification to policy advises that the Coventry and Warwickshire HENDA 2022 considers there a need for housing types, tenures and mix, including affordable housing. As referred to elsewhere in our Representations the affordable housing demand of the Plan area is significant. The housing requirement should be greater than the minimum Standard Method figure to help ensure that affordable housing requirements are met.
It is advised that the Councils are going to produce an updated SHMA 2025 that will include more updated information on affordable housing requirements. We reserve the right to comment further on this matter once the updated SHMA is published.

Other

ID sylw: 108356

Derbyniwyd: 07/03/2025

Ymatebydd: Lovell Strategic Land

Asiant : Carter Jonas

We are supportive of Draft Policy Direction 10 in providing a mix of types and densities that are appropriate to their location as it is imperative in order to delivery Strategic Objective 2 of “meeting the diverse needs of our residents.”

Notwithstanding this, to ensure the Plan meets the future housing needs as Strategic Objective 2 indicates, it is crucial that the wording of Draft Policy Direction 10 should maintain flexibility regarding affordable housing requirements and thresholds, as well as housing tenure and mix, which will allow housing provision to be based on the latest evidence of housing needs at the point of development.

Yes

ID sylw: 108369

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

9.1 Mackenzie Miller Homes agrees with the approach laid out in Draft Policy Direction 10 as
this is in line with Paragraph 63 of the NPPF which 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.
9.2 Additionally, 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.” As such, Mackenzie Miller Homes
agrees that the SWCs should have regard to the latest evidence in drafting policies relating
to housing tenure and type in due course, in accordance with the NPPF.
9.3 Furthermore, 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 is clear that:
9.4 “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.”
9.5 In Paragraph 72, the NPPF is also clear that planning policies should have regard to the
economic viability of sites. Paragraph 35 states that planning policies should not undermine
the deliverability of the Local Plan. Importantly, 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.
9.6 In this respect, it is recognised that the SWCs have not yet specified a proposed affordable
housing requirement. The PPG4 clearly states that the SWLP should aim to meet as much of
its identified affordable housing needs as possible, although it is not obligated to fulfil these
needs entirely.5 Therefore, it is crucial for the SWCs to test various requirements through
the Viability Assessment to ensure that the overall deliverability of the SWLP is not
compromised (Para 34). This is especially important for allocations within the Green Belt,
considering the NPPF’s ‘Golden Rules’ (Paras 67, 68, and 156a).
9.7 Nevertheless, Mackenzie Miller Homes 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. In Paragraph 82(d), the NPPF is clear that planning policies should be
flexible enough to adapt to unforeseen circumstances and changing economic conditions. Therefore, Mackenzie Miller Homes 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: 108407

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

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.

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.

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: 108438

Derbyniwyd: 06/03/2025

Ymatebydd: Mr R Wilding

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.

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.

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: 108488

Derbyniwyd: 03/03/2025

Ymatebydd: Lesley O'Connor

I am aware of the need for more houses in this country, but, they should be the type of housing that is needed; 3 & 4 bedroomed houses are not the only type of houses that we need in South Warwickshire. Starter homes that are affordable, social housing, shared ownership & smaller houses are necessary so that young people can buy or rent locally.

Other

ID sylw: 108496

Derbyniwyd: 03/03/2025

Ymatebydd: Sally Rees

Lack of Local Housing Solutions and Affordable Housing Strategy (Chapter 6)
• There is no clear strategy for ensuring that housing meets the needs of local residents, key workers, and low-income families.
• Developers are incentivised to build high-value properties, limiting the supply of genuinely affordable homes.
• NPPF Paragraph 62 requires that local plans reflect the housing needs of different income groups, which this Plan fails to achieve.
Conclusion: The Plan must implement a strong affordable housing requirement for all new developments

Other

ID sylw: 108510

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group 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. The Bird Group 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: 108570

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

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.

Affordable Housing

There is an acute affordability problem across the South Warwickshire Plan area. The HEDNA considered 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.

The Further Advice on Housing & Employment Land Needs 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 NPPG.

Housing for Older People

Any policy requirements for housing for older people must be justified and underpinned by the latest evidence on this matter.

Other

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.