No

ID sylw: 108382

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We object to Draft Policy Direction 1 insofar as reference to the HEDNA, whilst supporting other aspects of the Policy Direction.

With the revisions to the NPPF and Standard Method now finalised the SWLP should commit to the Standard Method requirement and make no reference to the HEDNA. As such, the SWLP should be taken forward having regard to Table 3, which we support. We also support the housing requirement being expressed as a minimum, to be interpreted as having a floor but not a ceiling.

Progressing the SWLP based upon the Standard method would be consistent with NPPF paragraph 62, whilst delivering housing above the Standard Method is acceptable in principle having regard to NPPF paragraph 69.

Yes

ID sylw: 108394

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

In terms of the strategic growth options, we support the inclusion of Southam Group SG12 in the draft SWLP and in particular HELAA site reference 36.

Strategic Growth Location SG12 would deliver housing and associated infrastructure at one of the SWLP plan area’s largest towns, and thus would - in plan strategy and locational terms - be the most sustainable location for delivering growth.

HELAA site 36 is more closely aligned with the urban edge of Southam, has urban influences from the town, is a contained land parcel in both landscape and visual terms, and is better related to tie into existing infrastructure serving non car travel modes.

Yes

ID sylw: 108397

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We support the approach set out in Policy Direction 3. Built Up Area Boundaries should be reviewed to take account of committed development which has occurred since the adoption of the Core Strategy, and also to take account of new allocations proposed through the SWLP to ensure that ‘countryside’ policies do not apply to allocation sites.

Yes

ID sylw: 108401

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We support that the SWLP will be underpinned by a housing need and availability evidence base that considers the Coventry and Warwickshire Housing Market Area as well as the Greater Birmingham and Black Country Housing Market Area.

Additionally, the SWLP must integrate a robust duty-to-cooperate mechanism, reflecting the demographic, economic, and migration trends influencing South Warwickshire’s housing market.

Other

ID sylw: 108404

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We are very concerned that the SWLP is advancing with infrastructure requirements not yet identified, to be delivered by sites in spatial growth locations where yield and capacity is not specified. It is impossible at this stage to establish the viability – and thus deliverability – of sites in the spatial growth locations.

We consider that infrastructure requirements and site capacity be the subject of detailed work prior to any work progressing on the Publication draft SWLP. The detailed work should be in collaboration with site promoters so as to bring forward genuinely deliverable site options. The process should be workshop based, with a Statement of Common Ground prepared for the first workshop meeting and updated for each subsequent workshop – to get to an agreed position by way of an iterative process.

Other

ID sylw: 108405

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We consider that policy should avoid expressing specific densities, but instead should make reference to the NPPF and the need to utilise land efficiently and effectively.

In any event, it is not considered appropriate to defer densities to Design Codes. These will, according to the SWLP, follow after the SWLP is progressed. This means that the Councils are unable to establish what each spatial growth site might deliver in terms of housing yield, which in turn makes it impossible to robustly set out what sites are required to meet the Standard Method and duty to co-operate. It also means that site viability, and thus deliverability, cannot be established with promoters since the infrastructure requirements will be fixed by the SWLP based upon sites with an unquantified yield.

Other

ID sylw: 108406

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We broadly support the requirements to make efficient use of brownfield land. Recycling previously developed land can (though not always) achieve a series of sustainability objectives.

However, the scale of housing required in the plan area – even by the HEDNA evidence, which is significantly below the Standard Method and before adding in the duty to co-operate – is such that brownfield opportunities are insufficient to make even a small contribution to overall housing delivery in the plan area.

Furthermore, we object to any suggestion that a sequential approach should be taken to bringing forward brownfield sites ahead of green field opportunities.

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: 108408

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We recognise that the SWLP is to meet a range of needs across different sectors. Gypsies, travellers, travelling show people and boat dwellers are an important components to overall needs.

The Councils should consider the strategy for delivering such needs. Specific sites could be identified for these needs, as an alternative or in combination with delivery such needs on spatial growth sites. If spatial growth sites are intended to assist in delivering these needs, site size thresholds require careful consideration, we question whether the as drafted site size threshold of 500 units is appropriate and whether a higher threshold is justified.

Other

ID sylw: 108409

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We broadly support the application of Design Codes, in varying degrees of detail, consistent with the nature of the code itself - be it area wide or site specific.

Design Codes should however be prepared in consultation with promoters as key stakeholders, to ensure the code is proportionate and appropriate.

A skeletal Design Code could form part of a Statement of Common ground prepared between the Councils and site promoters, applying the approach we have set out in responding to Policy Direction 5.

In all cases Design Codes should have regard to NDMP’s introduced through the Levelling Up and Regeneration Act 2023.