No

ID sylw: 106364

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium (WMHAPC)

Asiant : Tetlow King Planning

Draft Policy Direction 1 proposes that the South Warwickshire Local Plan (“SWLP”) will make provision for at least 1,679 dpa in line with the HEDNA (February 2024), with sufficient flexibility to accommodate up to 2,178 dpa, in line with the proposed new Standard Method. This equates to at least 41,975 dwellings over a 25-year plan period between 2025 and 2050, with sufficient flexibility to accommodate up to 54,450 dwellings.
In order to deliver this level of housing growth, the policy direction explains that after accounting for
existing commitments and an assumed windfall allowance, the SWLP will need to accommodate the
delivery of 15,532 dwellings (HEDNA) or 28,257 dwellings (2024 Standard Method). Given the scale of
these figures, it is essential that the Local Plan allocates sufficient sites for development and contains
strategic and detailed policies that do not unduly frustrate the delivery of homes where it is shown there
is significant need.
The HEDNA (2024) identifies that there is an affordable housing need of 1,386 dpa. This equates
affordable housing need equates to 83% of the total housing need of 1,679. Given this significant
proportion of affordable housing need, the WMHAPC is disappointed that this figure has not been addressed as part of the draft Policy Direction 1. We encourage the Council to explicitly include an affordable housing requirement as part of the forthcoming draft policy in order to ensure enough affordable housing is delivered across SW.

Yes

ID sylw: 106365

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium (WMHAPC)

Asiant : Tetlow King Planning

Policy Direction 4 - Accommodating Housing Needs Arising from Outside South Warwickshire Appeal decision 3319752 states that Warwickshire District Council’ can demonstrate 7.12 years of supply against the Standard Method; Stratford-on-Avon’s latest Five-year housing land supply statement states that at 1 April 2024, they can demonstrate 24.65 years of supply. Both respective
authorities exceed the five year housing land supply requirement significantly and when combined, is a
healthy sum for the SW area.
The WMHAPC is pleased to see that the SW authorities are taking a collaborative approach with neighbouring authorities to ensure affordable housing needs are met, sharing responsibilities amongst the authorities of Coventry, Warwickshire, Greater Birmingham and Black Country, all of whom are known to have a constrained housing market area with significant shortfalls in housing provision.
The draft Policy Direction 4 states that: “housing or employment need that cannot be met within the
administrative boundaries of the authority in which the need arises and part or all of the need could most appropriately be met within the South Warwickshire Local Plan, reserve sites will be released for this purpose, or when the relevant authority’s 5 year housing land supply calculation falls below the thresholds set out in national planning policy guidance.” The WMHAPC welcomes this approach although seeks further clarity on the monitoring and strategy to enforce the release of “reserve sites”.

Yes

ID sylw: 106366

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium (WMHAPC)

Asiant : Tetlow King Planning

The WMHAPC welcomes the prospect of developments which will help to deliver the necessary infrastructure to communities. However, as currently worded, the policy direction does not take into account the viability aspect of 100% affordable housing schemes. The WMHAPC recommends that the level of financial contribution towards the provision of infrastructure should be exempt or reduced on 100% affordable housing sites in order to practically deliver the affordable homes without compromising on viability.
The Council should explore joint approaches and alternative funding mechanisms such as S106
agreements of neighbouring developments to aid in the improvement and development of new infrastructure of 100% affordable housing projects.