Yes

ID sylw: 106644

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

In principle, the proposed sequential approach to allocating strategic growth locations and any new settlement within the SWLP is supported.
Any development in Green Belt should only be justified if further evidence indicates that non-Green Belt locations are less sustainable, and other evidence is presented which demonstrates that they are viable and deliverable; these being particularly important consideration for new settlements and strategic growth locations that are dependent on major new infrastructure first being available to un-lock the sites and /or make them sustainable e.g. provision of a new train station.

Yes

ID sylw: 106645

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Draft Policy Direction 8 is broadly consistent with the NPPF (Chapter 11 - Making effective use of land) and we recognise that increasing housing densities can have play a positive role in helping meet local housing needs, address affordability concerns, and ultimately promoting sustainable forms of development by making effective use of land.
For a future policy on densities and associated design codes to be effective, a careful balance needs to be struck between seeking to optimise the density of development and ensuring that other development considerations are appropriately considered.
when the Councils are setting density standards we consider that it is also important density levels are realistic and that they take into consideration: • the Councils own housing mix requirements; • the need for developers to also meet other policy requirements that influence the how much development can be delivered on a site, e.g. green infrastructure and open space standards, the mandatory 10% net gain in on-site biodiversity; and, • the nationally described space standard for housing should the Councils decide that this should also become a policy requirement on the SWLP.
Furthermore, developing and implementing design codes requires significant time and expertise. We therefore have concerns about their use and effectiveness, when planning departments are resource and financially constrained.

Yes

ID sylw: 106646

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Yes, we support approach laid out in Draft Policy Direction 9.

No

ID sylw: 106647

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

In its current form Draft Policy Direction 10 is not considered detailed enough for WPDG to be clear as to approach that will ultimately be pursued in the submission SWLP. For this reason we support the Draft Policy Direction in principle only, and reserve the right to comment further on this matter once the updated SHMA is published and the Councils have set out more clearly its approach to providing the right tenure and type of housing to meet the diverse needs of all residents in South Warwickshire.
We do, however, wish to restate our preference that separate affordable housing requirements are provided in the SWLP for Stratford-on-Avon and Warwick Districts; doing so would be appropriate in terms of reflecting local requirements and viability considerations.
Table 8.5 of the HEDNA highlights the income gap between private renting and buying. Table 8.45 of the HEDNA identifies a total need for affordable housing (rented and affordable home ownership) of 547 dwellings per annum in Stratford on Avon and 830 dwellings per annum in Warwick. Affordable housing delivery is therefore a key challenge for the South Warwickshire Local Plan and the best way to significantly increase the supply of affordable housing is to ensure that sufficient deliverable and developable sites are allocated for housing over the plan period. This should include a balanced portfolio of sites, in terms of their size and location. Over reliance in Part 1 of the SWLP on large sites (with issues associated with lead in times and build out rates) we believe would only inhibit the ability to deliver affordable housing and will fail to address affordability problems in South Warwickshire.

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

Other

ID sylw: 106650

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Whilst it is recognised that it is relatively easy to integrate new development with renewable energy sources like solar panels, heat pumps, and battery storage from the outset, challenges still exist regarding grid connection, regulatory frameworks, and potentially complex system design depending on the chosen decentralized energy approach.
We therefore question the requirement in Draft Policy-F that all “major development” in South Warwickshire will be required to demonstrate a thermal masterplanning approach to maximise energy efficiency opportunities for the use of decentralised energy systems.
No information is provided in the draft policy, or supporting justification, as to what constitutes “major development” in this context .If “major development” represents residential developments of 10 or more dwellings, we consider the requirement to be unnecessarily burdensome for many developments. We, therefore, would like to see clarification provided in the Pre-Submission SWLP on what, in this context, is meant by “major development” i.e. a threshold in terms of unit numbers or floorspace.
The policy should also acknowledge that there might occasions where an existing system might be available but does not have enough capacity to accommodate the energy needs of planned new development. Furthermore, if the draft policy is to be taken forward into the Pre-Submission SWLP, to avoid any unnecessary ambiguity the policy should, as per the supporting justification, make clear that that detailed energy statements will be required, to include potential for connection to decentralised energy systems.

No

ID sylw: 106651

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Whilst we would agree with the Councils that there is a need to act to reduce carbon emissions, we disagree that this needs to be undertaken through the local plan given that there is already a national approach being taken forward to achieve the same goal, the Future Homes Standard (FHS). 8 Currently if the Councils choose to go beyond current or future standards the following stated requirements must be subject to viability testing as part of the Pre-Submission SWLP: • The requirement under Part A that residential buildings must be designed and built to be Net Zero Carbon in operation and that they must generate renewable energy on-site to at least match annual energy use; and • The requirement under Criterion 2 for heat pumps to be the primary heating system for houses unless in areas with low-carbon district heating networks. • Under Criterion 4, it is suggested that battery storage may be required for future residential development schemes. This should be viability tested and the implications for battery storage investigated in terms of space requirements and maintenance.Regarding the requirement under Criterion 4 for roof orientation that maximises PV generation options where possible. We consider it is important that the Councils first establish what impact this could potentially have on scheme density, and how this requirement if applied would align with the SWLP’s design policies. Similarly, Criterion relates to compact building forms and will have direct implications for scheme layouts. This requirement also needs to be considered alongside the SWLP’s design policies.

Other

ID sylw: 106652

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Whilst we are supportive of the Councils taking steps to reduce carbon emissions in new development, we question the focus placed solely on embodied carbon solely associated with buildings/ building materials. If embodied carbon is to be assessed, we believe that the overall impact of proposed a development should be considered at the planning stage e.g. the embodied carbon in any offsite supporting infrastructure that might be specifically required to make the development acceptable in planning terms such as new highways infrastructure. In such cases the embodied carbon impact would clearly be much greater than would be the case for a development which is well located to take advantage of existing infrastructure capacity and requires little of no supporting new infrastructure.

Yes

ID sylw: 106653

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

We recognise that water resources are under significant pressure and that this is likely to be accentuated as a result of climate change over Local Plan period. The implications of having to meet the BREEAM "excellent" standard for water consumption should though factored into the Viability Assessment produced with the Pre-Submission SWLP.