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.

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: 108070

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

Self Build & Custom Housebuilding Register had 345 people on it as of 31st March 2024. Warwick’s Register had 95 people on it as of 2019, which is the latest published position. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum. Evidence exists to suggest a need for custom and self-build plots, and we therefore support in principle a policy relating to delivery of such plots, although the evidence needs to be refreshed.

The policy should be amended to provide flexibility rather than a 5% of developable area on schemes over 99 dwellings. There will also be separate self-build allocations and windfall sites. Areas should not be sterilised and prevented from delivering other forms of housing to contribute towards meeting a different need which may be more appropriate and with more demand in the area. There could be reference to a trigger for releasing self-build plots on sites where there is no demand for them.

Other

ID sylw: 108071

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

The Gypsy, Traveller, Travelling Showpeople and Boat Dwellers Accommodation Assessment identifies need of between 74 - 89 new permanent pitches over the plan period. This policy direction suggests pitches and plots will need to be provided as part of schemes of 500 dwellings or more. The Councils shouldn't rely on potential developments which may or may not come forward to meet the need for pitches. The Councils must identify the way in which this need will be met, with sufficient deliverable and developable gypsy and traveller sites in the pipeline, as stipulated by the Government’s Planning Policy for Traveller Sites. Identification of specific sites for pitches, such as the Leamington Football Club site, would be supported.

For large-scale residential schemes some sites may not be appropriate or desirable locations for a traveller site. If the Councils were to seek to retain this in the policy some flexibility should be provided, rather than as a blanket requirement. Any schemes which are to accommodate pitches would need careful design to cater for the needs of both settled and travelling occupiers, with amenity considerations taken into account.

Other

ID sylw: 108072

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

Paragraph 165(c) of the NPPF states plans should identify opportunities for development to draw its energy supply from decentralised energy supply systems. This is what the draft policy seeks to achieve. It does not make this obligatory and simply encourages use and development of such systems, with regard given to viability considerations. This is supported, as it means the policy will not risk undermining the effectiveness and deliverability of the plan where it is not possible for a scheme to comply with this.

The draft policy states developments will be required to demonstrate a ‘thermal master planning approach’ to maximise energy efficiency opportunities. Clarity should be provided on what this means for developers, along with clear justification for including this within the policy.

The draft policy will require an Energy Statement to be submitted as part of a planning application. It is acknowledged there is support for this requirement within the evidence base, with the Climate Evidence on Renewables and Decentralised Energy Opportunities (May 2024) report recommending this. The building performance standards which Energy Statements will need to demonstrate are met should not exceed the requirements of the national Building Regulations.

No

ID sylw: 108073

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

This policy stipulates new buildings should be designed and built to be net zero. This exceeds requirements in the Building Regulations. The Government’s response to the Future Homes Standard consultation in 2023 stated policy shouldn't be prescriptive on methodology and technology. Until there is an upgrade to the grid, developers only need to demonstrate dwellings are zero carbon enabled.

The Government don't expect plan-makers to set standards that go beyond current or planned Building Regulations. Existing standards don't have to be duplicated in planning policies. The Councils don't have a well-reasoned and robustly-costed rationale and haven't undertaken viability assessments. This policy is therefore unsound. Onerous energy efficiency requirements can severely undermine development viability. This should have been acknowledged in the SA.

The industry is moving towards zero-carbon ready housing as standard. Transitional arrangements must be in place to ensure this can be done smoothly. The plan must avoid onerous requirements which may jeopardise short-term delivery. Note that achievement of net zero is unlikely to be feasible for all developments, particularly urban brownfield developments. Policy should be flexible/deferential to changes in national standards.

The stepped change to zero carbon under the programmed future Building Regulation changes gives developers certainty and allows the industry to develop solutions collaboratively. Following this standard allows the industry to benefit from cost efficiencies and certainty associated with delivery of mass-produced proprietary products, which will better address viability and delivery of development to meet the Council’s planned housing trajectory.

The supporting text indicates relying on Building Regulations alone will be insufficient to achieve net zero by 2050. However, Building Regulations are under continuous review and the Government are aware of the need to meet net zero. Building regulations will continue to evolve when appropriate.

Other

ID sylw: 108074

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

It is proposed to address embodied carbon in the Building Regulations within a new Part Z. The Government’s Building to Net Zero: Costing Carbon in Construction (May 2022) report recommends embodied carbon and whole-life carbon assessments for buildings are established in the Building Regulations. Local Authorities are only encouraged to include such a requirement within Local Plans – the fact that this is not advised to be mandatory confirms that allowing Building Regulations alone to cover this is sufficient. In any event, viability will be an important consideration. We support the acknowledgment that applicants can submit a justification where achieving embodies carbon targets is unviable.

No

ID sylw: 108075

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

Again, these matters are already covered by the Building Regulations, and as such do not need to be addressed in a policy which goes beyond these. The Building Regulations will apply, and developers will need to adhere to these, securing climate resilient design with or without a development plan policy on this.

It is noted that the policy seeks to introduce a climate change checklist for South Warwickshire, which will need to be completed and submitted as part of planning applications. Further details should be provided on what this checklist covers, whether in the policy or within the supporting text. In addition, there should be a clear justification for referencing this within the policy, and the requirements which will need to be met. The checklist must not place onerous requirements on developers which exceed the requirements of the Building Regulations.

Other

ID sylw: 108076

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

The proposed water efficiency standard of 100 litres per person per day notably exceeds that in the Building Regulations (125 litres per day, with the option for authorities to reduce it to 110 litres per day). It is acknowledged that the evidence base, namely the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024), recommends a planning policy to require a water efficiency target of 100 litres per day to be achieved using a fittings- based approach, due to evidence of pressures on the environment, and on public water supply. Thus, such a policy, though unnecessary given that this is addressed in the Building Regulations, could be justified.

Yes

ID sylw: 108077

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

The policy is broadly supported, with it being underpinned and justified by the evidence and recommendations in the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024).