No

ID sylw: 108212

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The Policy Direction offers very little direction at all, solely stating that the Councils will have regard to the latest evidence when drafting this policy in full.

Affordable Housing

There is an acute affordability problem across the South Warwickshire Plan area. The HEDNA considered that the estimated annual need for affordable housing (rented and affordable home ownership) across Stratford-on-Avon and Warwick is 1,386 dwellings per annum. The Further Advice on Housing & Employment Land Needs report suggests that the affordable housing need has worsened, with the number of households on the two authorities housing registers having climbed from 7,048 in April 2021 to 7,684 in April 2023.

The Further Advice on Housing & Employment Land Needs report indicates that at least 2,772 dpa should be delivered in order to meet South Warwickshire’s affordable housing needs in full. It is imperative for the Councils to consider this when determining the total number of homes to plan for, as per the NPPG.

Housing for Older People

Any policy requirements for housing for older people must be justified and underpinned by the latest evidence on this matter.

No

ID sylw: 108213

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The policy states that new residential development must comply with the Nationally Described Space Standards (NDSS). Footnote 51 of the NPPF is clear that planning policies should only refer to NDSS where the need for this can be justified. The attempted justification within the supporting text is weak and unconvincing. No evidence is provided to demonstrate that the size of new homes is diminishing, as alleged, and only two appeal decisions have been considered.

If the use of NDSS is subsequently justified and pursued, the policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below NDSS, will be acceptable. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements.

The draft policy also states that homes should be provided to M4(2) and M4(3) standards. This aspect of the policy must be based on evidence to be justified. The HEDNA does provide some support for this, but is now out-of-date.

Notwithstanding, Persimmon contend that it is unnecessary to include an M4(2) and/or M4(3) requirement in the SWLP Part 1. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements.

No

ID sylw: 108214

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

Evidence exists, though it needs to be refreshed, to suggest that there is a need for custom and self-build plots within South Warwickshire, and as such a policy relating to the delivery of such plots would be justified and supported in principle.

The policy states that 5% of the developable area of a site must be made available for custom and self-build on schemes comprising 100 dwellings or more. It is considered that this should be amended to provide flexibility; self-build plots should be delivered in line with the identified need, and provision will be made elsewhere, as noted in the policy, on allocated self-build sites, and windfall sites too. It is important to note that other types of housing need must equally be met within South Warwickshire, and areas of sites should not be sterilised and prevented from delivering other forms of housing which will contribute towards meeting a different need, in a location which may be more appropriate for this than for self-build, or for which there may be a greater demand. Reference could be made to a trigger for the release of self-build plots if there is no demand for these.

No

ID sylw: 108215

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

This policy direction suggests that pitches and plots for gypsies and travellers will need to be provided as part of schemes of 500 dwellings or more. The Councils should not rely on potential developments which may or may not come forward to meet the need for pitches – it is imperative for the South Warwickshire Councils to identify the way in which this need will be met. The identification of specific sites for pitches, such as the Leamington Football Club site, would be supported.

In addition, as part of large-scale residential schemes, it is important to highlight that the site in question may not be an appropriate or desirable location for a traveller site. As such, if the Councils were to seek to retain this within the policy, some flexibility should be provided, rather than this serving as a blanket requirement. Any schemes which are to accommodate pitches would need to be carefully designed to cater for the needs of both settled and travelling occupiers, with amenity considerations taken into account.

Other

ID sylw: 108216

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The fact that the policy does not make this obligatory and is simply encouraging of the use and development of such systems, with regard given to viability considerations, is supported, as it means that 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 that developments will be required to demonstrate a ‘thermal master planning approach’ to maximise energy efficiency opportunities. Clarity should be provided as to what this means for developers, and there should be a clear justification for including this within the policy.

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: 108217

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

This policy stipulates that new buildings should be designed and built to be net zero, which exceeds the requirements in the Building Regulations. The Government’s response to the Future Homes Standard (FHS) consultation in 2023 stated that any policy should not be prescriptive on methodology and technology and that until there is an upgrade to the grid, developers only need to demonstrate dwellings are zero carbon enabled.

Therefore, the Government do not expect plan-makers to set local efficiency standards for buildings that go beyond current or planned Building Regulations, and nor do existing standards have to be duplicated in planning policies. Crucially, here, the Councils do not have a well-reasoned and robustly costed rationale to justify a sound policy, with no viability assessment having been undertaken, and until then, this policy is unsound.

It is also important to note that the achievement of net zero is unlikely to be feasible for all developments. This is particularly the case in urban brownfield developments. The policy should accordingly be flexible/deferential to changes in national standards.

No

ID sylw: 108218

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

As referenced above in relation to Policy Direction 22, it is already 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 that 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. The fact that this is addressed within the policy direction, in allowing applicants to submit a justification where achieving embodied carbon targets is unviable, is supported.

No

ID sylw: 108219

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

These matters are already covered by the Building Regulations, and as such do not need to be addressed in a policy which goes beyond these. The Building Regulations will apply, and developers will need to adhere to these, securing climate resilient design with or without a development plan policy on this.

It is noted that the policy seeks to introduce a climate change checklist for South Warwickshire, which will need to be completed and submitted as part of planning applications. Further details should be provided on what this checklist covers, whether in the policy or within the supporting text. In addition, there should be a clear justification for referencing this within the policy, and the requirements which will need to be met. The checklist must not place onerous requirements on developers which exceed the requirements of the Building Regulations.

Yes

ID sylw: 108220

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The proposed water efficiency standard of 100 litres per person per day notably exceeds that in the Building Regulations (125 litres per day, with the option for authorities to reduce it to 110 litres per day). It is acknowledged that the evidence base, namely the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024), recommends a planning policy to require a water efficiency target of 100 litres per day to be achieved using a fittings- based approach, due to evidence of pressures on the environment, and on public water supply. Thus, such a policy, though unnecessary given that this is addressed in the Building Regulations, could be justified.

Yes

ID sylw: 108221

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The policy is broadly supported, with it being underpinned and justified by the evidence and recommendations in the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024).