Other

ID sylw: 108609

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Vision
3.1.
The draft vision for the SWLP Part 1 seeks to “meet South Warwickshire’s sustainable development needs and strengthen local communities”. The vision goes on to state that the plan will provide “homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time”. These representations are broadly supportive of the vision as presented, as this accords with NPPF §7, which states that the purpose of the planning system is to contribute to the achievement of sustainable development.
3.2.
Five overarching principles for the plan which are pursuant to the vision are then listed. Notably, these do not fully align with the draft vision, and this must be addressed. Indeed, none of the principles refer to the delivery of “homes and jobs”, despite the provision of new housing and economic growth being key to the achievement of sustainable development, as highlighted in NPPF §8. In order to ensure that the vision and its five principles are positively prepared and consistent with national policy, which emphasises the importance of planning to meet an area’s objectively assessed needs, it is imperative for reference to be made to this, to then feed into the Strategic Objectives which follow. These do reference housing and employment (SO 1, 2, and 4), but have no direct link to the five principles as drafted.
3.3.
The selected spatial growth strategy, ‘Sustainable Travel and Economy’, should also be referred to, and woven into the other principles, as this strategy is now a fundamental part of the SWLP and the vision for South Warwickshire, which will shape the strategic objectives and policies in the plan.
3.4.
The vision and first of the five principles place a significant emphasis on responding to the climate emergency. Although this is supported and it aligns with the Government’s aspirations for achieving net zero carbon emissions by 2050 (NPPF §161), it is also important that this does not dominate the Vision and Strategic Objectives of the SWLP to the detriment of securing a balanced, sustainable strategy which achieves the delivery of development to meet identified needs.
3.5.
The second principle refers to creating a ‘beautiful’ South Warwickshire. Whilst this aspiration is supported, and there is some reference to ‘beauty’ within national policy (NPPF §131), there
March 2025 | AG/KF | P23-1274 6
is concern that this is poorly defined and will need to be supported by more detailed
guidance on what beauty means in practice.
Strategic Objectives
3.6.
The twelve Strategic Objectives are comprehensive, covering the social, economic, and environmental dimensions of sustainable development set out in Paragraph 8 of the NPPF. It is thus considered that they are consistent with national policy. The Preferred Options Sustainability Appraisal (SA) (December 2024) finds that the Strategic Objectives will have negligible, minor positive, and major positive impacts on all SA Objectives.

Other

ID sylw: 108610

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 1 – Meeting South Warwickshire’s Sustainable Development Requirements
a)
Housing Numbers
4.1.
The policy direction indicates that provision will be made for the delivery of 1,679 dwellings per annum (dpa), with sufficient flexibility to accommodate up to 2,188 dpa. Factoring in existing commitments and an assumed windfall allowance, it is suggested that the SWLP will need to identify land for between 15,532 to 28,257 dwellings over the plan period, to 2050.
4.2.
The 1,679 hpa figure is derived from the Housing & Economic Development Needs Assessment (HEDNA) (November 2022), which identified this as the annual housing need for South Warwickshire based on demographic data, including initial 2021 census data. It has now been over two years since the publication of the HEDNA, and the HEDNA, and the data within it, no longer represents up-to-date evidence; NPPF §32 states that plans should be underpinned by the latest available evidence and the SA recommends that the HEDNA calculation should be updated.
4.3.
This has also been recognised by Iceni, who produced the HEDNA. Further Advice on Housing & Employment Land Needs was published by Iceni in February 2024. This report reviews the projections for housing need in South Warwickshire. Notably, the concluding recommendation is for the updated 10-year migration trend projection to be taken forward, requiring the provision of 1,919 hpa.
4.4.
Further, NPPF §62 states that local housing need should be calculated using the Standard Method (SM) set out in Planning Practice Guidance (PPG). Following the publication of the updated NPPF, the Standard Method now identifies a need for 2,188 hpa in South Warwickshire (1,126 hpa in Stratford and 1,062 hpa in Warwick); the policy direction appears to suggest that this is an absolute maximum, and that no further housing will be required beyond this. However, this is inconsistent with national policy, which is clear that the Standard Method establishes the minimum number of homes, not the maximum, needed per annum – it should be considered a starting point (NPPF §62). The Further Advice on Housing & Employment Land Needs
(February 2024) suggests, in Table 1.1, that 2,808 hpa may be required in South Warwickshire in the 5-year migration scenario, and Table 6.10 indicates that at least 2,772 hpa is needed to meet the total affordable housing need. Paragraph 2A-024 of the PPG states that higher housing figures may be needed where this could help deliver the required number of affordable homes (discussed further in Section 5). Therefore, the evidence base already highlights how a greater number of dwellings than 2,188 hpa may be required.
4.5.
Moreover, these figures do not factor in any unmet need from neighbouring authorities which may have to be accommodated in South Warwickshire under the duty to cooperate (NPPF §24) to ensure a positively prepared plan. NPPF §62 comments that needs which cannot be met within neighbouring areas should be considered in establishing the number of homes to plan for. This matter is discussed in more detail in relation to Policy Direction 4, but it underlines further with regards to Policy Direction 1, how the emerging policy must not treat 2,188 hpa as a maximum figure for housing delivery in South Warwickshire to 2050.
4.6.
For the SWLP Part 1 to be found sound, the plan will need to be effective, meaning that it must be deliverable over the plan period. It is thus necessary to establish whether 2,188 hpa is achievable in South Warwickshire. The evidence on past delivery in Stratford and Warwick suggests that this is the case, as shown in Table 1 below. In fact, completions across Stratford and Warwick have exceeded 2,188 hpa six times in the past eight years, peaking at 2,685 homes in 2021/22. This suggests that the Councils could, in fact, plan for more housing growth, which will help to meet the affordable housing need within South Warwickshire. Indeed, a failure to do so would be to fail to meet the Government’s prime housing objective of significantly boosting the supply of homes (NPPF §61).
4.7.
It is considered that setting a minimum figure of 2,188 hpa, equating to 54,700 homes over the plan period, in line with the SM and the provisions of national policy, would not undermine the deliverability of the plan. It will be critical for the Councils to identify and allocate a range of deliverable sites in the SWLP Part 1, to ensure a continuing rate of completions, which meet or exceed current local housing need, can continue to consistently be met over the plan period. 4.8.
Additionally, the policy direction assumes that 9,375 homes will be provided on windfall sites over the plan period. This is around a fifth of the overall supply. The Councils acknowledge, in Footnote 3, that the windfall figures are only “estimates [which are] subject to change”. A high-level analysis of recent monitoring reports indicates that the number of homes delivered on windfall sites significantly varies year-to-year. For example, Table 11 of the Authority Monitoring Report 2022-2023 for Stratford reveals that windfall delivery since 2011 has ranged from just 30 to 933dw/yr (albeit this covered a period where the Council had no 5YLS or up to date development plan policy and the ‘presumption’ applied). Sufficient land needs to be allocated for housing to provide flexibility in case fewer windfall sites are brought forward. To avoid the risk of any shortfalls in housing delivery, the Councils should avoid overreliance on a windfall allowance.
4.9.
To summarise, with regards to housing figures, it is considered that the policy direction as drafted is not positively prepared, justified, or consistent with national policy, in relying on out-of-date evidence to suggest that 1,679 hpa would be an acceptable annual housing requirement, and incorrectly treating the Standard Method’s 2,188 hpa as a maximum figure, secondary to the ageing HEDNA. To remedy this, the emerging policy should state that provision will be made for at least
2,188 hpa, requiring a minimum of 54,700 homes over the plan period. The evidence demonstrates that this is deliverable, with in excess of 2,188 completions in six of the last eight years across South Warwickshire,. Opting for this higher figure would support the effectiveness and Strategic Objectives of the plan.
4.10.
Notwithstanding the above, planning for an even greater number of homes is encouraged and would be strongly supported. The reasons for this are to:
1)
provide sufficient flexibility to allow for higher-growth scenarios as set out in the Further Advice on Housing & Employment Land Needs report (up to 2,808 hpa),
2)
address unmet need from neighbouring authorities,
3)
address potential uncertainty in the number of homes which will be delivered on windfall sites,
4)
secure the delivery of sufficient affordable homes to meet local need (from 2,772 hpa - discussed further under Policy Direction 10), and
5)
To significantly boost the supply of housing (NPPF§61)
4.11.
Such an approach would ensure that the objectively assessed housing need for South Warwickshire can be met in full. This is supported by the SA, which concludes that providing at least 2,188 hpa will have the most positive effects compared to the reasonable alternatives in terms of housing and supporting economic growth. Planning for this number of homes will align with the aspirations of the NPPF §§61 and 63.
b)
Housing Land Supply
4.12.
It is important to review the housing land supply within South Warwickshire in considering how many homes need to be planned for. The policy direction suggests that there are 17,068 existing commitments which will form part of the supply over the plan period.
Stratford District
4.13.
Stratford District Council claim to have a 24.65-year housing land supply as of 1st April 2024, as set out in their Information Sheet dated 16th October 2024. We strongly dispute the assertion that the Council can demonstrate this level of supply at the present time. As the current Core Strategy is over five years old from adoption, the five
-year housing land supply for Stratford needs to be measured against the housing need calculated using the SM, in accordance with the PPG. The updated SM has significantly increased the annual housing requirement within Stratford, from 553 hpa to 1,126 hpa (a 103.6% increase). The latest analysis from Landstack indicates that using the new Standard Method results in a housing supply of just 2.96 years.
4.14.
Stratford District Council have undertaken a Regulation 10A review which concluded that policies did not require updating provided the housing requirement was applied without reliance upon previous over-supply, such that Footnote 41 of the NPPF requires that the housing land supply is assessed against the adopted housing requirement. However, the Council are now deducting past over-supply when calculating the housing land supply position which is inconsistent with and undermines the conclusions of their Regulation 10A review. The review found that the adopted Core Strategy did not require updating on the provision that the adopted annual housing requirement for 637hpa continued to be applied from 2020 onwards, without being adjusted for past delivery.
4.15.
Regardless of this, there is a minimum local housing need of 1,126 hpa, which equates to a need for at least 5,630 homes over the period 2024-29. The latest assessment by Stratford suggests that 3,505 homes will be delivered from 2024-2029, meaning there is a demonstrable substantial need for 2,125 homes. This goes to highlight the need to plan for as much housing as possible, regardless of the Council’s latest putative housing land supply position.
Warwick District
4.16.
Meanwhile, Warwick District Council’s latest published position as of 1st April 2023 (published in their Housing Land Supply Position Document dated October 2023) suggests that there is a housing land supply of 7.16 years within the district. However, in an appeal decision related to the Warwickshire Police Headquarters in Long Wootton (ref. APP/T3725/W/23/3319752), dated 24 May 2024, the Inspector determined that Warwick only had a 4.01-year land supply, and a shortfall of 665 homes. The appeal decision clarified that Warwick should be assuming a 45% discount on their supply which is to meet Coventry’s needs, based on the spatial strategy of the adopted Warwick District Local Plan. Taking that position into account, the Inspector concluded that Warwick’s supply was 4,914 homes. Under the new Standard Method’s minimum local housing need (1,062
hpa), based on a five-year supply of 4,914 dwellings, Warwick only has a 4.62-year housing land supply at the present time.
4.17.
It is also important to emphasise that both Stratford and Warwick’s calculations are based on a number of assumptions regarding deliverability. The housing land supply figures may reduce further if sites do not deliver as expected, permissions expire without being implemented, or fewer windfall sites come forward than expected. This is acknowledged by Stratford District Council in paragraph 11 of their Housing Land Supply Information Sheet (October 2024).
4.18.
It is critical to ensure that a sufficient amount of housing is planned for in the SWLP Part 1. When measured against the new Standard Method in the 2024 NPPF, both Stratford and Warwick lack a five-year housing land supply (2.96 years and 4.62-years respectively), and as such the presumption in favour of sustainable development will apply, which may lead to a substantial number of speculative planning applications in locations which the Councils do not consider favourable for growth under the selected spatial strategy. Any under-delivery which may occur would result in an even lower supply. Specific and deliverable sites must be allocated for housing across South Warwickshire to ensure that there can be a steady supply of housing in Stratford and Warwick over the plan period, and certainly for five years following adoption, in line with NPPF §§ 72 and 78.
c)
Spatial Growth Strategy
4.19.
The Councils have confirmed that South Warwickshire’s housing need, as defined by Policy Direction 1, will be distributed across Stratford and Warwick through the ‘Sustainable Travel and Economy’ spatial growth strategy. Three ‘priority areas’ for growth are identified.
4.20.
There is a preference expressed to concentrate growth on brownfield sites and Priority 1 areas, prior to considering development elsewhere. However, it is important to emphasise that there is insufficient previously developed land within South Warwickshire to accommodate the level of housing and employment land required. The Urban Capacity Study (October 2022) highlights that there is only capacity for 6,145 dwellings on such sites – just 11% of the minimum housing need required over the plan period (54,700 dwellings). As such, the study concludes (on page 37) that it will be “impossible to meet development needs without significant greenfield development” in Stratford and Warwick (emphasis added). This is also acknowledged, to an extent, in the
Emerging Spatial Growth Strategy Topic Paper (November 2024).
4.21.
The identification of a myriad of Priority 2 and 3 areas, where development can occur in accordance with the spatial growth strategy, is supported, to ensure that needs can be fully met. Proportionate growth directed away from brownfield sites to settlements which are comparatively smaller than Stratford, Warwick, and Leamington Spa will also support their viability and vitality, whilst providing opportunities to enhance sustainable travel options at these locations, resulting in positive impacts on transport and accessibility (SA Objective 11), as acknowledged in Appendix E of the SA, §3.1.6.
4.22.
Twenty-four Strategic Growth Locations are identified, twenty-one of which would potentially accommodate housing. It is stated that these locations (which include Green Belt sites) could accommodate development which exceeds South Warwickshire’s housing need; Table 5.1 of the SA suggests that 74,521 homes could be provided – 46,264 above the highest ‘to find’ figure set out in Policy Direction 1. Three Strategic Growth Locations are identified to solely accommodate commercial development, amounting to 532.75 hectares of employment land, according to Table 5.1. These comprise Stoneleigh Park Employment (SG02), Coventry Airport (SG03), and Wedgnock Park Farm Employment (SG07).
4.23.
It is suggested that allocations will not be made in all areas given that this exceeds their housing and employment requirements. It is agreed that allocating land for 74,521 dwellings and 532.75 hectares for employment would be excessive, and the plan must be deliverable. Notwithstanding, the Councils clearly have an opportunity to allocate additional sites which will deliver housing and employment that extend beyond the minimum local need, to absorb any unmet needs from neighbouring authorities, in line with NPPF §§ 24, 62 which will allow for higher-growth scenarios, and provide flexibility to avoid potential future shortfalls in delivery. Until the need is fully identified, the Councils should keep all locations open for potential allocation.
4.24.
The SA assesses each of the Strategic Growth Locations against the SA Framework. All will have major positive impacts on SA Objective 9 (Housing), with the majority also having minor positive impacts on SA Objective 13 (Economy). Performance against the remaining objectives varies, but all Strategic Growth Locations will result in at least some minor and major adverse impacts, which inevitably arise from development on greenfield land, such as impacts on the landscape (SA Objective 4) and natural resources (SA Objective 7). 4.25.
The SA however, undervalues the positive contribution that residential development in South Warwickshire can make towards biodiversity (SA Objective 3) in providing an uplift over and above the existing baseline. The positive contribution towards transport and accessibility (SA Objective 11) is also not recognised for any of the options, despite the SA noting elsewhere, the benefits that development can bring in this respect. Those benefits include improving public transport options, thereby allowing for reduced car use, which in turn has positive impacts on Climate Change (SA Objective 1) (see Appendix E, § 3.1.6).
4.26.
The Site falls adjacent to the ‘East of Stratford-upon-Avon’ (SG19) Strategic Growth Location, whose identification is supported. It falls within Priority Area 3, which highlights that this is a sustainable and suitable location for growth, with development here aligning with the spatial strategy for South Warwickshire. SG19 has been assessed against the SA Framework and generally performs favourably. This is discussed in greater detail in Section 11 below.
4.27.
Land at Croft Farm has obvious potential to act as an extension to the SG19 allocation and form an integral part of it, displaying as it does, many of the locational sustainability benefits, which also accrue to SG 19.

Other

ID sylw: 108611

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 2 – Potential New Settlements
4.28.
In addition to the Strategic Growth Locations in Priority Areas 1, 2, and 3, the South Warwickshire Councils have identified twelve potential new settlements, and a policy direction is included which states that one or more will be considered for allocation. The New Settlements Assessment Topic Paper (November 2024) only identifies four of the potential new settlements as “more suitable”.
4.29.
New settlements can make an important contribution towards meeting South Warwickshire’s housing requirement. Indeed, NPPF §77 states that the supply of large numbers of new homes can often be best achieved through planning for new settlements, thus this approach would be consistent with national policy, and the provision of one or more new settlements is supported in principle. The Councils are reminded that where such large-scale residential development is proposed, NPPF §22 stipulates that strategic policies should be set within a vision that looks at least 30 years ahead (taking into account the timescales likely to deliver a new settlement). The vision in the SWLP Part 1 is currently restricted to its 25-year plan period, thus, if the Councils were to pursue a new settlement, this should be amended/addressed accordingly within the plan.
4.30.
New settlements have long lead-in times typically 6.6 years from first application to first home on site (source: Lichfield’s Start to Finish 3), which means that their contribution towards South Warwickshire’s housing supply would likely be in the latter part of the plan period, and possibly into the next. If too much of the supply depends on a new settlement, and delays arise in its delivery, the Councils risk significantly underdelivering housing. Therefore, it will be critical for the Councils to allocate a range of other sites across the Strategic Growth Locations, and these should form the majority of South Warwickshire’s housing supply, in addition to any new settlement(s). This aligns with NPPF §61, which states that a variety of land should be brought forward for housing, i.e. sites of different scales, ranging from minor development through to new settlements. It will also better meet the needs of SME housebuilders, who are able to respond more flexibly to meet short term requirements and provide variety and choice in the marketplace NPPF §73.
4.31.
The SA assesses the potential new settlement locations. Whilst they would all make a major positive contribution to housing (SA Objective 9), all options will generally result in minor adverse to major adverse impacts across most of the other SA objectives. The Emerging Spatial Growth Strategy Topic Paper recognises that new settlements will have a harmful impact due to the amount of land they would occupy in existing countryside locations. The SA suggests that the Strategic Growth Locations are therefore generally more sustainable, in terms of having lesser adverse impacts on the SA Objectives. However, it is important to note that this is only a high-level exercise, which has not taken potential mitigation, which could include ecological and landscape enhancements which would give rise to major positive impacts, into account. As with the Strategic Growth Locations, the positive impacts on transport and accessibility (SA Objective 11) and, as a result, Climate Change (SA Objective 1) have also not been recognised.

Yes

ID sylw: 108612

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 3 – Small Scale Development, Settlement Boundaries, and Infill Development
4.32.
This Policy Direction, in encouraging small-scale development, is generally supported; NPPF §73 notes that small-to-medium sized sites can make an important contribution towards an area’s housing supply, and opportunities should be sought to support small sites being brought forward. It is stated that the existing settlement boundaries will be reviewed, and this is encouraged by Kiely, since the Urban Capacity Study (October 2022) identifies that there is only scope for up to
6,145 dwellings within existing boundaries, a figure which is far below South Warwickshire’s housing requirement.
4.33.
The fact that the Councils will support small-scale development adjacent to settlement boundaries is welcomed, since these can be amongst the most sustainable locations for housing. Going forward, it will be important to define “small-scale”. The suggested ‘threshold site size’, below which developments are likely to be acceptable, is expected to be an appropriate approach, although this should only serve as guidance for developers and decision-makers, and not be overly restrictive, to ensure that this does not discourage the efficient use of land, which would be contrary to national policy (NPPF §124).

Other

ID sylw: 108613

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 4 – Accommodating Housing Needs Arising from Outside South Warwickshire
4.34.
NPPF §24 sets out the duty to cooperate, and §36 is clear that for a plan to be positively prepared, unmet need from neighbouring areas must be accommodated where possible. Stratford forms part of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) and both Stratford and Warwick are in the Coventry and Warwickshire Housing Market Area. The latest position on housing need in the GBBCHMA is dated July 2020; this identified an unmet need of 40,325 dwellings, and a shortfall of 29,260 dwellings post-2031 in the Black Country alone. More recently, in the Birmingham Local Plan Review Preferred Options consultation document (July 2024), a shortfall of 46,153 dwellings over the period 2020 – 2042 was identified, with §3.5 stating that “the city will continue to be reliant on other local authorities to assist in meeting Birmingham's housing shortfall”. The evidence on shortfalls in the HMAs is out-of-date and should be refreshed as a matter of priority. To deliver the housing the HMAs require will necessitate a clear delineation of responsibility under the duty to cooperate to address any shortfalls, including through the SWLP Part 1.
4.35.
In anticipation of there being significant shortfalls, in light of the scale of the previously evidenced work and the fact that various authorities in the HMAs have experienced significant increases in their housing requirements arising from the revised Standard Method, the Councils are encouraged to plan appropriately and allocate (reserve) sites for this purpose. It is considered that there is sufficient developable land in the South Warwickshire Plan Area to do so. This includes the Strategic Growth Locations and potential new settlements, which can accommodate a significantly greater number of homes than is required to meet Stratford and Warwick’s own needs. The Councils have a legal duty to cooperate
and a responsibility to help address unmet needs, and for the SWLP Part 1 to be found sound, it is expected that it will need to do so.

Yes

ID sylw: 108614

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 5 – Infrastructure Requirements and Delivery
4.36.
The provision of appropriate infrastructure is supported in principle; NPPF §20 is clear that strategic policies should make sufficient provision for infrastructure, and this is also key for the delivery of sustainable development. The Councils can seek developer contributions where it is not possible to address unacceptable impacts through conditions, in line with NPPF §56. In Stratford and Warwick, developer contributions can be secured via the Community Infrastructure Levy and Section 106 Agreements. The SWLP Part 1 should clearly define and distinguish between the two; developers should not be required to contribute towards the same items through each. In addition, the SWLP Part 1 should make it explicitly clear, including in relation to education contributions, that only proportionate infrastructure can be sought in line with the needs generated by a development – contributions must not extend beyond this to remedy any existing deficiencies which may exist in South Warwickshire. Indeed, The Council are reminded that planning obligations must meet the three tests established by CIL Regulation 122, and as referenced at NPPF §58, which require contributions to be:
a)
necessary to make the development acceptable in planning terms;
b)
directly related to the development; and
c)
fairly and reasonably related in scale and kind to the development.
4.37.
The emerging Policy Direction makes no reference to viability considerations. It suggests that “all development must provide appropriate on- and off-site infrastructure” (emphasis added), despite the fact that this may render a scheme unviable. The SA has not recognised the adverse impacts this omission could have on SA Objectives 9 (Housing) and 11 (Economy). NPPF §25 notes that whilst plans should set out the contributions and infrastructure expected from development, such policies should not undermine the deliverability of the plan. The Councils must undertake a viability assessment as part of the plan-making process, in line with the Planning Practice Guidance (PPG), to ensure that contributions for infrastructure would not undermine the viability of development on allocated sites. The policy should acknowledge that applicants may demonstrate whether particular circumstances justify the need for a viability assessment at the application stage
(NPPF§59). Such references to viability would ensure the policy is fully consistent with national policies, and an effective and deliverable plan which allows viable schemes to be brought forward on a variety of sites across South Warwickshire.

Other

ID sylw: 108615

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 6 – Safeguarding Land for Transport Proposals
4.38.
The Councils are proposing to carry forward the existing safeguarding measures for schemes which are yet to be completed. NPPF §111(c) does state that planning policies should identify and protect sites and routes which could be critical in developing infrastructure to widen transport choice. However, the NPPF is also clear, that policies should only seek to do this where there is robust evidence to justify it. The Councils acknowledge, in the supporting justification for the policy direction, that such evidence is still emerging, and further work is required in this respect. It will be necessary for the policy and safeguarding of land to be underpinned by appropriate evidence, to ensure that this is justified and sound.

Yes

ID sylw: 108616

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 8 – Density
4.39.
There are a range of densities throughout South Warwickshire, as highlighted in the Guide to Existing Housing Densities Topic Paper (January 2023), ranging from 6 dph in Alveston to 113 dph in central Leamington Spa. The Policy Direction is broadly supported as it recognises that a flexible approach to density should be taken. The NPPF emphasises the importance of achieving densities which are appropriate to the character of the area within which sites are located, with Paragraph 130 stating that a range of densities should be set out in policy to reflect the accessibility and potential of different areas. Such an approach would be consistent with national policy and justified, since the evidence base highlights the existing varying densities, and the need to consider the unique character of areas, some of which will be better suited to densification.

Other

ID sylw: 108617

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 9 – Using Brownfield Land for Development
4.40.
In encouraging the use of previously developed land, this Policy Direction aligns with NPPF, with §124 emphasising that as much use as possible should be made of brownfield sites. However, as discussed above, the Urban Capacity Study has already established that there is insufficient brownfield land available within settlements to meet South Warwickshire’s development needs. Whilst there are other brownfield sites located elsewhere in Stratford and Warwick, outside of settlement boundaries, the
Urban Capacity Study is still clear that “significant greenfield development” will be needed. It should be recognised that the use of both brownfield and greenfield sites will be required in order to meet South Warwickshire’s development needs.

Other

ID sylw: 108618

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 10 – Providing the Right Tenure and Type of Homes
5.1.
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.
a)
Affordable Housing
5.2.
There is an acute affordability problem across the South Warwickshire Plan area, as recognised in the Further Advice on Housing & Employment Land Needs report (February 2024). Warwick District Council’s latest Authority Monitoring Report for 2022-23 identifies a requirement of 374 affordable dwellings per year, yet only 291 dwellings were delivered in 2022-2023, and the annual need has only been met three times since the start of the plan period in 2011. Meanwhile, Stratford’s Authority Monitoring Report for 2022-23 identifies that in the current Core Strategy plan period of 2011-2031, 3,744 affordable dwellings have been provided out of a total 11,459 dwellings (net) built. This equates to 32% of all dwellings, which is below the Core Strategy’s affordable housing policy requirement for 35% of all dwellings to be affordable.
5.3.
The HEDNA considered the affordability issue across South Warwickshire. It identifies at Table 8.45 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.
5.4.
Paragraph 2A-024 of the National Planning Practice Guidance makes provision to encourage local authorities to consider increasing planned housing numbers where this can help to meet the identified affordable need:
“The total affordable housing need can then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probably percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the strategic plan may need to be considered where it could help deliver the required number of affordable homes.” (emphasis added)
5.5.
The Further Advice on Housing & Employment Land Needs report states that “the affordable housing need provides a clear basis for housing provision above the standard method (and indeed at or above the HEDNA level)” (§6.32). Table 6.10 of the 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 PPG. The SWLP Part 1 must address the acute affordability issue and boost the supply of affordable homes, to ensure that Stratford and Warwick can consistently meet their own affordable housing need, as well as the need of neighbouring authorities if appropriate, throughout the plan period.
5.6.
The policy should specify the type of affordable housing required (including the minimum proportion of Social Rent homes required), having regard to local need identified in the evidence base, in line with NPPF §64. This will ensure that the policy is justified and sound.
b)
Housing for Older People
5.7.
The HEDNA identified a need for 4,200 units of specialist housing, including retirement housing and extra care homes, as well as a need for 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 that the provision of retirement housing, extra care and residential care/nursing home spaces will all be necessary to meet the needs of an ageing population. Any policy requirements for housing for older people must be justified and underpinned by the latest evidence on this matter.