Yes

ID sylw: 98087

Derbyniwyd: 06/03/2025

Ymatebydd: William Davis Limited

Asiant : Marrons

The South Warwickshire Councils are justified in their approach to housing mix and tenure as it reflects the ambitions of Paragraph 63 of the NPPF, and the NPPF as a whole. The Councils should ensure they provide flexibility within their housing mix and tenure policies to account for circumstances where delivering a housing mix in-line with the identified mix is not feasible or logical.

No

ID sylw: 98089

Derbyniwyd: 06/03/2025

Ymatebydd: William Davis Limited

Asiant : Marrons

The NPPF at Footnote 51 is clear that optional technical standards and the Nationally Described Space Standard should only be enforced through planning policy where this would address an identified need and where it can be justified. Policies will need to be tested for their impact on viability.

No

ID sylw: 98092

Derbyniwyd: 06/03/2025

Ymatebydd: William Davis Limited

Asiant : Marrons

The best way to deliver self and custom build homes to meet identified needs is to allocate specific sites designed to cater for such homes. Sites will be smaller by their nature, and therefore more responsive to market demand and more likely to be attractive to those wishing to develop their own homes. Larger sites can only efficiently be developed by the major housebuilders, and the inclusion of self and custom build within their developments can create health and safety and operational difficulties when homes in areas are being built by multiple developers to different timescales and standards.

No

ID sylw: 98093

Derbyniwyd: 06/03/2025

Ymatebydd: William Davis Limited

Asiant : Marrons

A blanket requirement for provision of Gypsy, Traveller and Travelling Showpeople accommodation within all sites over 500 homes is not considered acceptable. The suitability of sites of this scale to accommodate the identified need should be assessed on a site-by-site basis; having regard to the scale and distribution of need, and the constraints and opportunities presented by the proposed allocations. Sites may also come forward elsewhere in the District through windfalls, and therefore the need and timing of provision will need to be kept under review.

No

ID sylw: 98097

Derbyniwyd: 06/03/2025

Ymatebydd: William Davis Limited

Asiant : Marrons

The Councils must monitor and ensure that the appropriate evidence is updated throughout the period of the Plan once adopted, and that policies can rely on this future evidence to quantify the need for different tenures and types of residential accommodation. Explicitly quantifying a level of tenures, mixes and types at the Plan’s adoption risks the Plan becoming quickly outdated, which would result in the Plan not being positively prepared or effective, as is required by Paragraph 36 of the NPPF.

No

ID sylw: 98100

Derbyniwyd: 06/03/2025

Ymatebydd: William Davis Limited

Asiant : Marrons

It is not considered that the draft Policy, in its current state, is effective in accordance with Paragraph 36 c) of the NPPF. The current definition of ‘major’ development means that it will not be realistic to expect the majority of such applications to demonstrate the use of decentralised energy systems. The Councils will need to ensure that any Policy at Regulation 19 stage evidences the feasibility of decentralised energy systems for development and expectations in relation to the scale of development. Any approach should be viability tested.

No

ID sylw: 98101

Derbyniwyd: 06/03/2025

Ymatebydd: William Davis Limited

Asiant : Marrons

The definition of net zero carbon buildings within draft Policy Direction 22 is unclear. A requirement for all new buildings to be designed and built to be Net Zero Carbon in operation is likely to come at the expense of housing delivery on some sites. In order to be sound, any Net Zero policy will need to ensure that it has been viability tested. With regards to Criteria 1, 3, 4, 5, and 6 of Part A, as per paragraph 164 b) of the Framework, the requirements in Local Plans should be in line with the requirements of Building Regulations.

No

ID sylw: 98102

Derbyniwyd: 06/03/2025

Ymatebydd: William Davis Limited

Asiant : Marrons

The importance of lowering embodied carbon in building materials is understood, and this being encouraged by policy is noted. The quantitative targets within Policy Direction 24 refer however to the Low Energy Transformation Initiative (LETI) and the Royal British Institute of Architects (RIBA) rather than specific analysis for the Plan area. A local analysis of the ability of different types and scales of development to meet an embody carbon policy should be prepared and subsequently tested through viability.

Yes

ID sylw: 98103

Derbyniwyd: 06/03/2025

Ymatebydd: William Davis Limited

Asiant : Marrons

The importance of climate resilient design in development is recognised, along with the cooling hierarchy, optimising the use of permeable surfaces and Green Infrastructure, mitigating flood risk, and incorporating water efficiency measures. It is appropriate for development in the Plan area to be accompanied by a completed Climate Change Checklist, in line with the existing development plan for Stratford-on-Avon.

No

ID sylw: 98104

Derbyniwyd: 06/03/2025

Ymatebydd: William Davis Limited

Asiant : Marrons

In our experience and analysis it is difficult to reduce water use to the levels described without compromising functionality, unless Rainwater Harvesting (RWH) for internal use is incorporated. RWH is rarely used on housing due to the cost, ongoing management issues and additional embodied carbon. Research also suggests that RWH increases CO² emissions at a time when we are seeking to reduce emissions. A target of 110 litres per person is considered more achievable and in line with the Government’s own guidance.