Other

ID sylw: 105104

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

St Philips support the SWA's efforts to enhance housing standards through the Nationally Described Space Standards (NDSS), but emphasise the need for adequate justification for this requirement. The NPPF highlights the importance of relevant, up-to-date evidence to support planning policies, considering economic viability and the deliverability of the Local Plan. St Philips suggest the SWA produce a Topic Paper to evidence the necessity for NDSS and conduct a Viability Assessment to evaluate the impact on site viability. This evidence is essential to ensure the proposed policy approach is sound.

Other

ID sylw: 106199

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

It may be a laudable aim to strive to achieve the ‘right size of homes’ but the NDSS standards apply to all builders and therefore arguably do not need to be spelled out in Local Plans. If authorities wish to enlarge room sizes within new homes (currently some of the lowest in Europe) then they need to understand the tensions created by their parallel desire to achieve ever higher densities. Similarly, new Government requirements for 10% Biodiversity Net Gain (expressed in the SWLP) mean that greater proportions of existing sites need to be given to Biodiversity and public land – leaving private gardens ever smaller. (The policy makers within the SWLP need to examine and acknowledge the conflicts within the different policy directions).

Other

ID sylw: 106220

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Yes, Cala recognises it is important to provide the right size of homes and supports the requirement to provide dwellings which meet Nationally Described Space Standards, or any subsequent government space standard –provided that that standard has been robustly tested and does not have provision to restrict the ability to deliver new, high-quality homes.

Cala also supports the flexibility to recognise that in certain circumstances it may not be practicable and financially viable to deliver provisions or where requirements are incompatible with conservation/ historic character principles.

No

ID sylw: 106371

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

This draft policy A proposes the blanket application of Nationally Described Space Standards (NDSS) for all new residential developments. There are concerns that the blanket application of the NDSS across all residential development, including affordable tenures, will undermine the viability of many development schemes. This will potentially result in fewer affordable homes being delivered as optional technical standards have implications for build costs and sales values, with implications in turn for development viability.
We highlight that the Planning Practice Guidance (PPG) requires local authorities to justify the need for
NDSS through considering need, viability and timing.
In light of the above, it is not clear that the Council has provided evidence demonstrating the need for
NDSS across all new developments in SW. If the Council continues to seek the NDSS requirement, then it must do so in line with the PPG to ensure the policy is justified and found sound at examination.
It is also relevant that Homes England only requires affordable homes to meet 85% of the NDSS to receive funding. For affordable housing in particular, there may be instances where achieving NDSS is impractical and unnecessary, as it may result in for example, higher rental and heating costs.
On sites that deliver 100% affordable housing, NDSS presents issues in that it increases the risk of financial impairment.
With regards to accessible living standards, it is proposed that all new housing, including conversions and subdivisions, must meet accessibility and adaptability standards (M4(2)) and on developments of 10 or more homes, at least 10% of market homes and 25% of affordable homes must be wheelchair friendly (M4(3)). Whilst the WMHAPC accepts that there is a growing need for accessible and adaptable homes, there is however concern that the 10% requirement for M4(3) dwellings could have considerable implications on viability and overall affordable housing delivery in SW. Some sites and/or schemes do not lend themselves to the statutory provision of M4(3) units. In light of this, the WMHAPC requests that the Council exercises an element of discretion when considering proposals.

Other

ID sylw: 106470

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

It is common for Local Authorities to conflate the needs of ‘wheelchair users’ with the needs of older people in the community. A supportive local planning policy framework will be crucial in increasing the delivery of specialist older persons’ housing and it should be acknowledged that although adaptable and accessible housing can assist it does not remove the need for specific older person’s housing. Housing particularly built to M4(3) standard
may serve to institutionalise an older person’s scheme reducing independence contrary to the ethos of older persons and particularly extra care housing. Older people’s housing and particularly extra care housing should therefore be incorporated into the emerging Local
Plan separately to adaptable and accessible housing and not confused with it.
Adaptable houses do not provide the on-site support, care and companionship of specialist older persons’ housing developments nor do they provide the wider community benefits such as releasing under occupied family housing as well as savings to the public purse by reducing the stress of health and social care budgets.
We would also like to remind the council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the
plan” (Paragraph: 002 Reference ID: 10-002-20190509). M4 2 and 3 Housing has a cost implication and may serve to reduce the number of dwellings and further reduce viability. This should be a consideration within the plan.

Yes

ID sylw: 106517

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

Policy A – Providing the right size of homes.

We support the requirement that all new development should comply with the NDSS.
However, we make detailed objections to the provisions of Policy A.
It should not be a requirement that all 1 and 2 bedroom affordable homes be built with bedrooms capable
of accommodating 2 occupiers in each bedroom. The NDSS expressly provides for a 2 bedroom 3 person
home.
Furthermore, we object to 100% of all new open market housing achieving M4(2) standards. This is a
disproportionate requirement, it is not evidenced as being a requirement of the SWLP, and as a result we
would suggest a maximum of 50% of all new affordable housing achieving this standard.

No

ID sylw: 106572

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Edward Muntz

Asiant : Sworders

The requirement to provide at least 10% of market dwellings and at least 25% of affordable to M4(3) standards on all new build sites of 10 dwellings or more seems excessive, and we question what evidence this is based on. Whilst we support the need for the SWLP to provide a range of different types of housing to support different groups of the community, this should not be through overly onerous design requirements and should be justified.

Other

ID sylw: 106592

Derbyniwyd: 06/03/2025

Ymatebydd: The Umberslade Estate

Asiant : Sworders

The requirement to provide at least 10% of market dwellings and at least 25% of affordable to M4(3) standards on all new build sites of 10 dwellings or more seems excessive, and we question what evidence this is based on. Whilst we support the need for the SWLP to provide a range of different types of housing to support different groups of the community, this should not be through overly onerous design requirements and should be justified.

Yes

ID sylw: 106648

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

The approach laid out Draft Policy ‘A’ should help ensure new homes in South Warwickshire are of a sufficient size and layout to better meet the needs of future occupiers. This will be particularly important where high density development is proposed, which typically has less accessible outdoor space than detached and semi-detached houses. However, Government guidance says that LPAs cannot automatically use the nationally described space standard in a Local Plan.
Presently the Reg18 SWLP acknowledges that further assessment needs to be undertaken on the extent of non-compliance with NDSS and whether this is more prevalent for certain types of residential development. In addition we are informed that further viability testing is required to ensure the NDSS will not have a material impact on the deliverability of housing schemes, including affordable housing, within the districts.
Within this context we consider that the evidence base is not sufficiently robust to justify the NDDS requirements currently set out in Draft Policy A.

No

ID sylw: 106649

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

As evidenced by entries in self-build registers of both Councils, people wishing to commission or build their own homes have a clear preference for plots within and adjacent to smaller settlements across South Warwickshire. Therefore, within this context we consider that robust evidence must be provided explaining how the 5% requirement for all plots on large housing sites to be made available for custom and self-build homes has been established and how this relates to identified demand, before this requirement should be carried forward into the Pre-Submission SWLP

No

ID sylw: 106965

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to the requirements set out in Draft Policy A which introduced the requirement for all new residential dwellings to comply with Nationally Described Space Standards.
Additionally, the requirement for all 1 and 2 bed affordable homes to support double/twin occupancy is not justified as the HEDNA does not provide clear justification for the need for this additional bedroom requirement nor has any evidence been produced to assess the impact of this requirement on viability and the efficient use of land.
There is no justification within the SWLP evidence base for 25% of affordable dwellings to meet the M4(3) standard and so we consider this element of the policy to be unjustified.

Other

ID sylw: 107215

Derbyniwyd: 06/03/2025

Ymatebydd: Catesby Estates

Asiant : Mr Will Whitelock

The supporting text to Draft Policy A makes reference to the HEDNA to support the suggestion that an NDSS policy is required. However, the HENDA does not suggest that all of the housing requirement should be NDSS compliant. The HEDNA is out of date and therefore a refreshed study should be produced to determine whether there is a need for a 100% NDSS provision, in addition to a need for M4(2) and M4(3) compliant properties. 5.4 In any event, it is unnecessary to include an M4(2) and/or M4(3) requirement in the SWLP Part 1. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3)/M4 (3)(2)(a) dwellings in relation to wheelchair accessible housing. It is not necessary for this to be repeated in a development plan policy as developers are already aware of the requirement to meet these standards. It is hence concluded that reference to accessible living standards should be deleted from the draft policy.

Other

ID sylw: 107325

Derbyniwyd: 07/03/2025

Ymatebydd: Stratford-on-Avon District Social Inclusion Partnership

It is important that households have room to grow into their homes and that the design/size of the home can cope with the changes that households experience throughout their lives. This would include large bedrooms capable of being used for more than one child as families grow and the design foresight (lifetime homes/M4) to enable independence for an extended period of time.

No

ID sylw: 107524

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We support the requirement that all new development should comply with the NDSS.
However, we make detailed objections to the provisions of Policy A.
It should not be a requirement that all 1 and 2 bedroom affordable homes be built with bedrooms capable of accommodating 2 occupiers in each bedroom. The NDSS expressly provides for a 2 bedroom 3 person home. From experience, 1 bedroom properties are largely taken up by single occupants.
Furthermore, we object to 100% of all new open market housing achieving M4(2) standards. This is a disproportionate requirement, it is not evidenced as being a requirement of the SWLP, and as a result we would suggest a maximum of 50% of all new affordable housing being required to achieve this standard.

Yes

ID sylw: 107657

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Yes, Cala recognises it is important to provide the right size of homes and supports the requirement to provide dwellings which meet Nationally Described Space Standards, or any subsequent government space standard –provided that that standard has been robustly tested and does not have provision to restrict the ability to deliver new, high-quality homes.
Cala also supports the flexibility to recognise that in certain circumstances it may not be practicable and financially viable to deliver provisions or where requirements are incompatible with conservation/ historic character principles.

No

ID sylw: 107740

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

The PPG (Paragraph: 003 Reference ID: 56-003- 20150327) states ‘that Local Authorities should consider the impact of using these standards as part of their Local Plan viability assessment.’ We understand from the Preferred Options plan (page 62) that further viability testing will be undertaken, however this has not yet been done and therefore at this stage, the requirement is not evidenced.
Additionally, the requirement for all 1 and 2 bed affordable homes to support double/twin occupancy is not justified as the HEDNA does not provide clear justification for the need for this additional bedroom requirement nor has any evidence been produced to assess the impact of this requirement on viability and the efficient use of land. The PPG also states that where local authorities set additional requirements they will need to gather evidence to determine whether there is a need for additional standards in their area, and justify setting appropriate policies in their Local Plans (Paragraph: 002 Reference ID: 56-002-20160519). This proposed policy requirement is therefore not considered to be in accordance with NPPF paragraph 36(b).
We note that the 2022 HEDNA recommends at paragraph 14.74 that all dwellings are constructed to M4(2) standard and 10% are constructed to M4(3) standard, with the potential to require a higher percentage for affordable housing. However, there is no justification within the SWLP evidence base for 25% of affordable dwellings to meet the M4(3) standard and so we consider this element of the policy to be unjustified. The PPG also states that LPAs should take into account the overall impact on viability of M4(2)/(3). This will need to be a key consideration in the Viability Appraisal that the Councils intend to prepare to support the Regulation 19 SWLP.

No

ID sylw: 107830

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The justification for this policy is weak. No evidence is provided that the size of new homes is diminishing and only two appeal decisions have been considered. The Homes England Capital Funding Guide does not require NDSS compliance. 85% of NDSS is generally accepted as the benchmark for grant-led affordable homes. Robust justification, viability testing, and evidence will be required to justify this policy. If pursued, the policy should be flexible enough to allow well-designed house types slightly below NDSS, particularly on sites where most dwellings comply. There should be provision for additional flexibility for affordable housing as many registered providers have their own requirements.

The draft policy also states homes should be provided to M4(2) and M4(3) standards. This must be based on evidence to be justified as per Footnote 51 of the NPPF. The HEDNA recommends that all should meet M4(2) standards and 10% M4(3) but the HEDNA is now out of data so a refreshed study would need to look at this issue. Catesby Estates believe this policy is unnecessary as the Building Regulations Part M provides specific requirements for M4(2), M4(3) standards and these do not need to be repeated in development plan policy.

Other

ID sylw: 107860

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Requirements that go above and beyond the standard building regulation requirements as set out by the Draft Policy, applying the higher Building Regulations standard M 4(2) and M4 (3), should be justified and otherwise considered on a site-by-site basis, and on a needs basis. This will ensure that homes are being built in the most appropriate locations to meet needs at the time of development. A blanket approach is not considered to be appropriate

Other

ID sylw: 107906

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Terra is supportive of the SWA’s efforts to improve housing standards by requiring
developments to meet Nationally Described Space Standards [NDSS]. However, Terra
wishes to highlight that this requirement will need to be sufficiently justified.
2.93 Footnote 51 of NPPF paragraph 135(f) states that policies may “make use of the nationally
described space standard, where the need for an internal space standard can be justified.”
As noted above, the NPPF is clear that plans should be underpinned by relevant and up-todate
evidence that is adequate, proportionate and focussed tightly on supporting and
justifying the policies concerned (Para 32). In addition, 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) – this is supported by the PPG.9
2.94 Terra acknowledges that the PO’s supporting text states the SDC Housing Strategy 2021
evidence log notes that poor space standards on units on developer-led s106 sites (for
affordable housing) are an issue and that a further assessment is being undertaken on the
extent of non-compliance with NDSS and whether this is more prevalent for certain types of
residential development, alongside viability testing the NDSS requirement (Pg.62).
2.95 In this context, Terra would suggest that the SWAs publish a Topic Paper evidencing the
need for NDSS, alongside a Viability Assessment that tests the impact of policy
requirements on the viability of sites allocated in the SWLP in accordance with the NPPF
and PPG in due course. This would be critical evidence to underpin the SWLP’s proposed
policy approach and will be necessary to ensure that the policy is found to be sound.

No

ID sylw: 107948

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The justification for this policy is weak. No evidence is provided that the size of new homes is diminishing and only two appeal decisions have been considered. The Homes England Capital Funding Guide does not require NDSS compliance. 85% of NDSS is generally accepted as the benchmark for grant-led affordable homes. Robust justification, viability testing, and evidence will be required to justify this policy. If pursued, the policy should be flexible enough to allow well-designed house types slightly below NDSS, particularly on sites where most dwellings comply. There should be provision for additional flexibility for affordable housing as many registered providers have their own requirements.

The draft policy also states homes should be provided to M4(2) and M4(3) standards. This must be based on evidence to be justified as per Footnote 51 of the NPPF. The HEDNA recommends that all should meet M4(2) standards and 10% M4(3) but the HEDNA is now out of data so a refreshed study would need to look at this issue. Rainier Developments believe this policy is unnecessary as Building Regulations Part M provides specific requirements for M4(2), M4(3) standards, which do not need to be repeated in development plan policy.

No

ID sylw: 108069

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

The justification for this policy is weak. No evidence is provided that the size of new homes is diminishing and only two appeal decisions have been considered. The Homes England Capital Funding Guide does not require NDSS compliance. 85% of NDSS is generally accepted as the benchmark for grant-led affordable homes. Robust justification, viability testing, and evidence will be required to justify this policy. If pursued, the policy should be flexible enough to allow well-designed house types slightly below NDSS, particularly on sites where most dwellings comply. There should be provision for additional flexibility for affordable housing as many registered providers have their own requirements.

The draft policy also states homes should be provided to M4(2) and M4(3) standards. This must be based on evidence to be justified as per Footnote 51 of the NPPF. The HEDNA recommends that all should meet M4(2) standards and 10% M4(3) but the HEDNA is now out of data so a refreshed study would need to look at this issue. Seven Homes believe this policy is unnecessary as the Building Regulations Part M provides specific requirements for M4(2), M4(3) standards and these do not need to be repeated in development plan policy.

Other

ID sylw: 108113

Derbyniwyd: 07/03/2025

Ymatebydd: William Davis Homes

Asiant : McLoughlin Planning

Whilst we support the principle of the above, the Respondent would caution that the delivery of accessible units should be considered on a case by case basis, given the potential implications for the density of development and development viability.

Yes

ID sylw: 108179

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We support the requirement that all new development should comply with the NDSS.
However, we make detailed objections to the provisions of Policy A.
It should not be a requirement that all 1 and 2 bedroom affordable homes be built with bedrooms capable of accommodating 2 occupiers in each bedroom. The NDSS expressly provides for a 2 bedroom 3 person home.
Furthermore, we object to 100% of all new open market housing achieving M4(2) standards. This is a disproportionate requirement, it is not evidenced as being a requirement of the SWLP, and as a result we would suggest a maximum of 50% of all new affordable housing achieving this standard.

Yes

ID sylw: 108193

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft PolicyA- Providing the Right Size of Homes?
2.78 St Philips is supportive of the SWA’s efforts to improve housing standards by requiring
developments to meet Nationally Described Space Standards [NDSS]. However, St Philips
wishes to highlight that this requirement will need to be sufficiently justified.
2.79 Footnote 51 of NPPF paragraph 135(f) states that policies may “make use of the nationally
described space standard, where the need for an internal space standard can be justified.”
Furthermore, As noted above, the NPPF is clear that plans should underpinned by relevant
and up-to-date evidence that is adequate, proportionate and focussed tightly on supporting
and justifying the policies concerned (Para 32). In addition, 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) – this is supported by the
PPG.10
2.80 St Philips acknowledges that the PO’s supporting text states the SDC Housing Strategy 2021
evidence log notes that poor space standards on units on developer-led s106 sites (for
affordable housing) are an issue and that a further assessment is being undertaken on the
extent of non-compliance with NDSS and whether this is more prevalent for certain types of
residential development, alongside viability testing the NDSS requirement (Pg.62).
2.81 In this context, St Philips would suggest that the SWAs publish a Topic Paper evidencing
the need for NDSS, alongside a Viability Assessment that tests the impact of policy
requirements on the viability of sites allocated in the SWLP in accordance with the NPPF
and PPG in due course. This would be critical evidence to underpin the SWLP’s proposed
policy approach and will be necessary to ensure that the policy is found to be sound.

No

ID sylw: 108213

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The policy states that new residential development must comply with the Nationally Described Space Standards (NDSS). Footnote 51 of the NPPF is clear that planning policies should only refer to NDSS where the need for this can be justified. The attempted justification within the supporting text is weak and unconvincing. No evidence is provided to demonstrate that the size of new homes is diminishing, as alleged, and only two appeal decisions have been considered.

If the use of NDSS is subsequently justified and pursued, the policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below NDSS, will be acceptable. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements.

The draft policy also states that homes should be provided to M4(2) and M4(3) standards. This aspect of the policy must be based on evidence to be justified. The HEDNA does provide some support for this, but is now out-of-date.

Notwithstanding, Persimmon contend that it is unnecessary to include an M4(2) and/or M4(3) requirement in the SWLP Part 1. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements.

Other

ID sylw: 108276

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Whilst we have support the use of NDDS in principle we have concerns relating to the evidence base used to justify the NDDS requirements of Draft Policy A.
The policy supporting text advises that further viability testing is required to ensure the NDSS will not have a material impact or deliverability of housing schemes. This work needs to be completed as, at the moment, there is no uncertainty whether full NDSS compliance will be viable.
Footnote 51 to the NPPF advises that Local Authorities may include policies in their Plan requiring schemes to comply with NDSS where the need for internal space standards can be justified. The supporting text to draft Policy A makes reference to the HEDNA and SDC housing strategy to support the suggestion that an NDDS policy is required. However, neither of these documents suggest that all of the SWLP housing requirement should be NDSS compliant. In order for the Plan to include a policy that requires 100% NDSS provision there must be clear robust evidence that the equivalent of 54,700 additional NDSS dwellings are required. No such evidence is provided.

Yes

ID sylw: 108370

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

10.1 Yes, Mackenzie Miller Homes is supportive of the SWC’s efforts to improve housing
standards by requiring developments to meet Nationally Described Space Standards
[NDSS]. However, it is considered that this requirement will need to be sufficiently
justified.
10.2 Footnote 51 of NPPF paragraph 135(f) states that policies may “make use of the nationally
described space standard, where the need for an internal space standard can be justified.”
10.3 Moreover, as noted above, Paragraph 32 of the NPPF makes it clear that plans should be
underpinned by relevant and up-to-date evidence that is adequate, proportionate and
focussed tightly on supporting and justifying the policies concerned. Furthermore,
Paragraph 72 of the NPPF is also clear that planning policies should have regard to the
economic viability of sites and Paragraph 35 states that they should not undermine the
deliverability of the Local Plan, which is also supported by the PPG.6
10.4 Mackenzie Miller Homes recognises that the PO’s supporting text states the SDC Housing
Strategy 2021 evidence log notes that poor space standards on units on developer-led s106
sites (for affordable housing) are an issue and that a further assessment is being undertaken
on the extent of non-compliance with NDSS and whether this is more prevalent for certain
types of residential development, alongside viability testing the NDSS requirement (Pg.62).
10.5 Given the above context, Mackenzie Miller Homes would suggest that the SWCs publish a
Topic Paper evidencing the need for NDSS, alongside a Viability Assessment that tests the
impact of policy requirements on the viability of sites allocated in the SWLP in accordance
with the NPPF and PPG in due course. This would be critical evidence to underpin the
SWLP’s proposed policy approach and will be necessary to ensure that the policy is found to
be sound.

Other

ID sylw: 108413

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We support the requirement that all new development should comply with the NDSS.

However, we make detailed objections to the provisions of Policy A.

It should not be a requirement that all 1 and 2 bedroom affordable homes be built with bedrooms capable of accommodating 2 occupiers in each bedroom. The NDSS expressly provides for a 2 bedroom 3 person home.
Furthermore, we object to 100% of all new open market housing achieving M4(2) standards. This is a disproportionate requirement, it is not evidenced as being a requirement of the SWLP, and as a result we would suggest a maximum of 50% of all new affordable housing achieving this standard.

Other

ID sylw: 108444

Derbyniwyd: 06/03/2025

Ymatebydd: Mr R Wilding

Asiant : Cerda Planning Ltd

We support the requirement that all new development should comply with the NDSS.

However, we make detailed objections to the provisions of Policy A.

It should not be a requirement that all 1 and 2 bedroom affordable homes be built with bedrooms capable of accommodating 2 occupiers in each bedroom. The NDSS expressly provides for a 2 bedroom 3 person home.
Furthermore, we object to 100% of all new open market housing achieving M4(2) standards. This is a disproportionate requirement, it is not evidenced as being a requirement of the SWLP, and as a result we would suggest a maximum of 50% of all new affordable housing achieving this standard.

No

ID sylw: 108511

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The approach laid out Draft Policy ‘A’ should help ensure new homes in South Warwickshire are of a sufficient size and layout to better meet the needs of future occupiers. This will be particularly important where high density development is proposed, which typically has less accessible outdoor space than detached and semi-detached houses. However, Government guidance says that LPAs cannot automatically use the nationally described space standard in a Local Plan. Planning Practice Guidance (Paragraph: 020 Reference ID: 56-020-20150327) requires that LPAs must first consider the following to be able to include NDSS in plan policies:
• whether there is a need for additional standards in the LPA area;
• the viability of imposing the standards; and
• their timing to allow a reasonable transitional period.
Presently the Regulation 18 SWLP acknowledges that further assessment needs to be undertaken on the extent of non-compliance with NDSS and whether this is more prevalent for certain types of residential development. In addition we are informed that further viability testing is required to ensure the NDSS will not have a material impact on the deliverability of housing schemes, including affordable housing, within the districts.
Within this context we consider that the evidence base is not sufficiently robust to justify the NDDS requirements currently set out in Draft Policy A