Yes

ID sylw: 108275

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

We support recognition that the SWLP should provide the right tenure and the right type of housing. The Justification to policy advises that the Coventry and Warwickshire HENDA 2022 considers there a need for housing types, tenures and mix, including affordable housing. As referred to elsewhere in our Representations the affordable housing demand of the Plan area is significant. The housing requirement should be greater than the minimum Standard Method figure to help ensure that affordable housing requirements are met.
It is advised that the Councils are going to produce an updated SHMA 2025 that will include more updated information on affordable housing requirements. We reserve the right to comment further on this matter once the updated SHMA is published.

Other

ID sylw: 108276

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Whilst we have support the use of NDDS in principle we have concerns relating to the evidence base used to justify the NDDS requirements of Draft Policy A.
The policy supporting text advises that further viability testing is required to ensure the NDSS will not have a material impact or deliverability of housing schemes. This work needs to be completed as, at the moment, there is no uncertainty whether full NDSS compliance will be viable.
Footnote 51 to the NPPF advises that Local Authorities may include policies in their Plan requiring schemes to comply with NDSS where the need for internal space standards can be justified. The supporting text to draft Policy A makes reference to the HEDNA and SDC housing strategy to support the suggestion that an NDDS policy is required. However, neither of these documents suggest that all of the SWLP housing requirement should be NDSS compliant. In order for the Plan to include a policy that requires 100% NDSS provision there must be clear robust evidence that the equivalent of 54,700 additional NDSS dwellings are required. No such evidence is provided.

No

ID sylw: 108280

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

No. We support the section of Draft Policy B that facilitates self-build and custom build housing on unallocated sites, however, we do not support the proposal that 5% of all plots on large housing sites are made available for custom and self-build homes.
The potential new settlement allocations in the Plan will deliver over 6,000 dwellings. If a site of this size is expected to provide 5% custom and self-build provision this means that 300 self-build and custom-build plots will be required in single locations. There is no evidence to suggest that there is this level of demand for self and custom-build plots in such large clusters.
There is no evidence to justify the requirements for 5% provision. In order for this requirement to remain in Policy robust evidence must be provided explaining how the 5% requirement has been established and how this relates to identified demand. In this regard, it is noted that the Stratford Upon Avon District Council self-build and custom-build position statement (December 2024) advises that at 30th October 2024 there was a surplus of 18 self-build plots. Whilst there is an identified need for further 116 self-build plots by 2027, this is a relatively insignificant amount compared to the number of self-build and custom-build plots that can be generated by draft Policy D.
In addition, households seeking custom and self-build plots are, in our experience, unlikely to be attracted to individual plots in new build housing estates. Typically, they prefer self build and custom plots in and around the age of settlements. Unless the Councils can evidence specific demand for plots within large scale developments of this nature, it should not be included within the Policy.
It should also be noted that the introduction of a 5% self-build plots policy will, in all likelihood, have a direct impact on densities as typically self-build plots are larger than normal development plots.

Other

ID sylw: 108282

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

The Policy supporting text advises that there is a need for 89 pitches during the course of the Plan period for gypsies and travellers. There is a further requirement for 18 additional travelling show people plots.
The Policy suggests that one way this provision can be met is through large scale residential sites (500 dwellings or more) providing GTAA Accommodation. Alongside this there are other opportunities such as the reuse of Leamington Football Club.
Whilst there is an identified need for further GTAA pitches there are a number of issues associated with requiring sites of 500 dwellings or more to provide gypsy and traveller sites. There are likely to be a number of sites of 500 dwellings or more allocated in the Plan. There could be an issue of over provision. The location of the proposed allocations is yet to be established. These sites may be in the wrong locations for GTAA sites. There is no credible evidence to support the Councils proposed approach to GTAA provision.

Other

ID sylw: 108283

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Whilst we support the move towards the Net Zero Carbon Buildings we have a number of concerns with the draft policy.
Part A of the Policy requires residential buildings to be built to Net Zero Carbon in operation and must generate renewable energy site to at least match annual energy use. This requirement needs to be viability tested in order to see if it is achievable.
Criterion 2 requires heat pumps to be the primary heating system for houses. This needs to be viability tested.
Criterion 4 requires roof orientation that maximises PV generation options where possible. The Local Authorities should establish what impact this could potentially have on scheme density, and this will need to be an active consideration in the application of the SWLP’s design policies.
It is suggested that battery storage may be required for future residential development schemes. This has the potential to be a significant development expense. This requirement should be viability tested.
Criterion 5 relates to compact building forms and will have direct implications for scheme layouts. This requirement needs to be considered alongside the SWLP’s designed policies.

Other

ID sylw: 108284

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Draft Policy J largely reiterates the guidance contained in the NPPF and PPG on Flood Risk and the Sequential Test. It is unnecessary to repeat national policy in the SWLP. The SWLP should simply direct the reader to the NPPF and PPG.

Other

ID sylw: 108285

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

We support the design principles identified in Draft Policy Direction 25. However, it is noted that this is a “Policy Direction” that will be refined into a full draft policy in the Pre-Submission SWLP. It is, therefore, uncertain what the practical implications of the design principles will be at the present time. It is consequently difficult to comment further on the suitability or otherwise of a strategic design policy given the lack of detail and we reserve the right to comment on this at a later stage.

Other

ID sylw: 108286

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

We support the preparation of site specific Design Codes as appropriate to help guide development. These should be developed in conjunction with the developers of the new settlements and strategic allocations.
It is, however, noted that it is advised that “most, or all,” sites specific Design Codes will not be in place until after the adoption of the SWDP. The preparation of Design Codes should not delay the preparation and submission of planning applications. If a Design Code is in place planning applications should be prepared to be inconformity with its guidance. It should not, however, be necessary for developers to wait for Design Codes to be put in place before submitting planning applications or prior to their determination. This approach could cause significant delays to the delivery of housing.

Other

ID sylw: 108287

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

We are generally supportive of requirements of Draft Policy Direction 38, however, it is noted that the Policy makes reference to the SWLP exploring evidence to seek higher percentage of BNG than the statutory 10% requirement. There is no national policy requirement for this. Any proposal of this nature must be viability tested.
BNG provision can have significant implications on the viability of development sites and their capacity. In order for Councils to seek greater than 10% BNG, robust viability evidence must be presented. It must be demonstrated that the Councils have an understanding of the ability and potential of housing allocations to deliver 15% BNG without adversely affecting their capacity or compromising any other planning obligations.

Other

ID sylw: 108288

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Draft Policy Direction 40 has the potential to add additional development costs that must be factored into a viability assessment produced with the Pre-Submission SWLP. In order for this Policy to be included in the Plan the Councils must have an understanding of the impact of this Policy on scheme density, the net to gross development ratio of schemes, and the overall scheme costs.