No

ID sylw: 106838

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to Policy Direction 1 as the policy sets out both the Coventry and Warwickshire Housing and Economic Development Needs Assessment (2022 HEDNA) and Standard Method figures for the number of dwellings required for Warwick and Stratford across the plan period.

Other

ID sylw: 106960

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We note that a New Settlement is proposed to be allocated for strategic growth in a sustainable location. Although we do not object to a proposed new settlement, new settlements take a significant amount of time to deliver and it will therefore be important to allocate a sufficient number of sites which can be delivered in the short term, such as Site ID 106/150 within proposed Strategic Growth Location SG10.
The NPPF is clear that where new settlements are proposed in plans, the policies should be set within a vision that looks further ahead, at least 30 years, to take account delivery timescales (paragraph 22). The SWLP will only cover the period of 25 years up to 2050 and should therefore be extended.

No

ID sylw: 106961

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

The Policy states that the SWLP will be underpinned by housing need and availability evidence base. As stated in our response to Policy Direction 1, the HEDNA is required to be updated to reflect the updated Standard Method and the implications that this may have on the Coventry and Warwickshire Housing Market Area (‘HMA’) and the Greater Birmingham and Black Country HMA. The majority of authorities within the HMAs are seeing an increase in their minimum housing need.
The NPPF is clear that the housing needs of neighbouring authorities should be met over the plan period (paragraphs 11 and 69). In order to be positively prepared (NPPF paragraph 36), the SWLP should make a contribution to the both HMA shortfalls.

Other

ID sylw: 106962

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We generally support draft Policy Direction 5, however contributions requested need to be acceptable in planning terms, directly related to the development and fairly and reasonably related in scale and kind to the development in accordance with paragraph 58 of the NPPF. We note from the SWLP that a Viability Appraisal will be produced to support the Regulation 19 plan. This should ensure the policy requirements being proposed will not impact on the
delivery of development sites. The Viability Appraisal should be informed by a full and detailed review of all financial contributions which may be sought for development at the application stage.

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.

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.

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.

Yes

ID sylw: 106966

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Turley, Sustainability and ESG, have undertaken a review of Strategic Objective 6 and state that Bellway supports the need to deliver development which aligns with the UK’s Net Zero trajectory, and ensures development is designed to mitigate and adapt to the effects of climate change, incorporating climate resilient design.
We support the ambition set out in the requirements outlined within this objective, noting that there are likely to be challenges with elements of these which are reflected in responses to the draft Policies.

Other

ID sylw: 106967

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway supports the need to utilise low carbon heating for new development. However, further consideration needs to be given to the feasibility and suitability of including requirements for decentralised energy systems to provide heating and cooling.
Development coming forward after the introduction of the FHS and FBS will only be able to connect to heat networks where the energy demand of the new buildings is matched by equivalent low carbon heat, i.e. delivered through the use of a heat pump.
Further to the technical constraints noted above the Council’s evidence base supporting this particular policy does not adequately consider the implications of the FHS and FBS on the likely heating requirements and heat density of new development. Nor does it consider the cost and viability of this type of system at this stage.
In this context it is considered unlikely that the reduced energy demand of new development is unlikely to provide sufficient heat demand for a low carbon heat network to be feasible or viable for low destiny development. It is recommended the Council give further consideration to the technical feasibility of heat networks and costs as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.

Other

ID sylw: 106968

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway supports the transition to delivering Net Zero development, however has concerns over elements of the policy as currently drafted which go against national Government guidance, have design implications which have not been thought through, and will have viability issues not yet considered.
The WMS states, ‘the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale.’ In this context it is considered that as proposed Policy contradicts the Government’s WMS and as such the space heating, total energy use and energy performance requirements should be removed or reconsidered to align with the 2023 Future Homes and Buildings Standard Consultation and WMS which describes Net Zero Ready development.
It is recommended that the Policy only considers requirements which relate to regulated emissions only in line with the principles set out in the 2023 WMS and the recent examination and modifications to the Bristol Local Plan Review.
We support the provision of Solar PV to provide onsite energy generation, however, this expectation is not likely to be feasible across a development with a mix of housing including flats, bungalows and homes.
It is recommended that the Plan considers the approach and Policies set out in the Warwick District Council Net Zero DPD which requires development to achieve Net Zero Carbon in operation. This provides a route to achieving Net Zero this which aligns with the Governments 2025 FHS and FBS, and 2023 Written Ministerial Statement on setting requirements which exceed the requirements of the Building Regulations.