Other

ID sylw: 107944

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Rainier Developments support a Green Belt review. The Green Belt in South Warwickshire Topic Paper shows several of the best-connected settlements are within or surrounded by Green Belt. So are most train stations. Half the SGLs are within Green Belt. The Topic Paper is correct that Green Belt options should be considered to ensure development is suitably distributed and directed to the most sustainable locations and that a full Green Belt review is essential.

Exceptional circumstances as required by NPPF Paragraph 145 exist because of the significant number of homes required and limited capacity in existing settlements as evidenced by the Urban Capacity Study. NPPF Paragraph 146 states that exceptional circumstances include when authorities cannot meet their identified housing need through other means. The December 2024 NPPF introduced the concept of ‘grey belt’. Paragraph 148 states that where Green Belt land needs to be released, plans should give priority to previously developed land, then grey belt, then other Green Belt locations. The Council will need to follow this sequential approach when considering sites to release.

The Green Belt Review Stage 1 doesn't consider grey belt but concludes only 9 out of 113 parcels made a strong contribution to the Green Belt purposes. With over 100 parcels not strongly contributing towards these purposes, Rainier Developments would expect that a significant number of grey belt sites can suitably accommodate development. The next stage of the Review should draw clear conclusions on this. The Green Belt policy should make reference to Grey Belt and acknowledge that development in Green Belt can be appropriate if the Paragraph 155 criteria are satisfied. The ‘Golden Rules’ for residential development may also be referenced.

The draft Policy Direction suggests areas of land may be safeguarded to meet longer-term needs. This is supported, and would align with NPPF Paragraph 149(c). This could be for future needs of the South Warwickshire authorities, or those in the two Housing Market Areas they fall within. Further discussions and evidence-gathering is required to ascertain the level of unmet need in the HMAs. ‘Safeguarded land’ would be in addition to ‘reserve sites’ referenced in Policy Direction 4. These would meet the shorter-term needs of neighbouring authorities over the plan period, not beyond it.

Yes

ID sylw: 107945

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

This policy is broadly supported as it recognizes a flexible approach to density should be taken. This is consistent with national policy as the NPPF states that densities should be appropriate to the character of the area. Paragraph 130 states that density should reflect the accessibility and potential of different areas. The approach is justified The Guide to Existing Housing Densities Topic Paper provides evidence of the varying existing densities in South Warwickshire.

Other

ID sylw: 107946

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

This is consistent with national policy. However, the Urban Capacity Study has shown there is insufficient brownfield land available within settlements to meet South Warwickshire’s development needs. While there are other brownfield sites outside of settlement boundaries in Stratford and Warwick, the Urban Capacity is clear that ‘significant greenfield development’ including Green Belt will be needed. It should be recognized that use of both brownfield and greenfield sites is required to meet South Warwickshire’s development needs.

Other

ID sylw: 107947

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

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 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 32% of net dwellings in the plan period have been affordable, below the 35% Core Strategy policy requirement. Warwick’s AMR shows the annual need for 374 affordable dwellings has only been met 3 times during 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.

To be justified and sound the policy should specify the type of affordable housing required (including minimum proportions of Social Rent homes required), with reference to evidence of local need, in line with NPPF Paragraph 64. This will ensure that the policy is justified and sound.

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 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: 107948

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

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. Rainier Developments believe this policy is unnecessary as Building Regulations Part M provides specific requirements for M4(2), M4(3) standards, which do not need to be repeated in development plan policy.

Other

ID sylw: 107949

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

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: 107950

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

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: 107951

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

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 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: 107952

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

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: 107953

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

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.