No

ID sylw: 107733

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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.
The draft Policy Direction considers basing the emerging plan’s housing need on either the figure from the HEDNA or using the Government’s standard method. We do not consider that it is consistent with national policy to consider a choice between these two methods. National policy states that the Standard Method should be used to identify a minimum annual housing need figure unless there are exceptional circumstances justify an alternative approach (Paragraph: 001 Reference ID: 68-001-20241212). No evidence has been provided to justify any exceptional circumstances and therefore, the standard method calculation should be used.
In order to accord with national policy, the SWLP should be planning for a minimum of 2,188 dwellings per annum across Warwick and Stratford Districts. The HEDNA (2022) should be updated to reflect this updated starting point and assess the need for the SWLP to plan for higher growth.
Once an appropriate housing requirement is confirmed, Table 3 should be amended to reflect the residual housing supply which needs to be identified in the SWLP. Table 2 should be deleted as it is based on the out of date HEDNA method.

Other

ID sylw: 107734

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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 334-336.
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: 107735

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We consider that settlement boundaries should not be revised in the SWLP as the SWLP is only seeking to allocate strategic sites, smaller scaled allocations will be required in the Part 2 plans and the location of those Sites should not be dictated by the BUAB.
The Policy also states that the SWLP will support Neighbourhood Plans allocating sites. We acknowledge that there may be a role for some growth to be identified in Neighbourhood Plans, however, the SWLP has no control on when NPs will be produced or reviewed to accommodate growth and therefore, there should not be an over reliance on NPs delivering growth. Major and small scale sites should be allocated as part of any future Part 2 plans.
The Policy needs to be updated to accord with changes in national policy relating to Green Belt development (NPPF paragraphs 154 – 159). In relation to non-Green Belt locations should include definition of small scale and a ‘threshold site size’ for growth adjacent to sustainable settlements. The policy as worded is not clear or justified (NPP paragraph 36). Long Itchington is a sustainable settlement but it does not fall within the SWLP Priority Area. We object to Priority Areas being used to direct small scale development. These areas are appropriate when considering strategic development but not small scale development.

No

ID sylw: 107736

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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: 107737

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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: 107738

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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: 107739

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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: 107740

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

The PPG (Paragraph: 003 Reference ID: 56-003- 20150327) states ‘that Local Authorities should consider the impact of using these standards as part of their Local Plan viability assessment.’ We understand from the Preferred Options plan (page 62) that further viability testing will be undertaken, however this has not yet been done and therefore at this stage, the requirement is not evidenced.
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. The PPG also states that where local authorities set additional requirements they will need to gather evidence to determine whether there is a need for additional standards in their area, and justify setting appropriate policies in their Local Plans (Paragraph: 002 Reference ID: 56-002-20160519). This proposed policy requirement is therefore not considered to be in accordance with NPPF paragraph 36(b).
We note that the 2022 HEDNA recommends at paragraph 14.74 that all dwellings are constructed to M4(2) standard and 10% are constructed to M4(3) standard, with the potential to require a higher percentage for affordable housing. However, 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. The PPG also states that LPAs should take into account the overall impact on viability of M4(2)/(3). This will need to be a key consideration in the Viability Appraisal that the Councils intend to prepare to support the Regulation 19 SWLP.

No

ID sylw: 107741

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We object to the proposed requirement development sites of over 100 dwellings to deliver 5% self-build and custom-build plots. There is no evidence to justify the requirements for allocating a percentage of plots on sites to provide custom-self build and whether there is a projected need to identify this level of provision. There is also no specific requirement in the PPG (reference 57-025-20210508) to require allocated sites to deliver self and custom build plots.
We are aware that Stratford on Avon District Council produce an annual position statement (December 2024) which sets out the demand for Self-build and Custom Housebuilding. The demand in Warwick District differs to the demand in Stratford District, therefore we object to the blanket approach of 5% for all developments of more than 100 dwellings. We consider that the LPAs should continue with the approach which provides overall support for self-custom build development but leaves it to the housing market to deliver plots when demands arises or allocate specific sites to deliver self and custom built plots to meet identified need where evidenced.

Yes

ID sylw: 107742

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

Strategic Objective 6
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.