Preferred Options 2025

5. Delivering Homes that Meet the Needs of all our communities

Chapter 5 sets out various options as to how we might meet the housing challenges facing South Warwickshire to 2050.

The Plan needs to allow for new homes that meet the diverse needs of all our residents, including affordable housing, student accommodation, older persons and specialist housing, self and custom build housing, along with the accommodation needs of gypsy and traveller and travelling showpeople communities. Within Warwick District there is a younger demographic of people due to the proximity of the university and the gaming industry in the area. Some of these are in lower paid jobs and are travelling into the area from places such as Coventry as they can't afford to rent or live in Warwick or Leamington.

Providing new homes is important not only in South Warwickshire but nationally; it not only gives people a place to live but it also supports the local economy creating construction jobs, supporting existing facilities and services so they remain open, making the area more attractive to local employers and promoting additional spending in the local economy. New homes also provide contributions to improve and provide new infrastructure such as schools and open spaces.

5.1 Providing the Right Tenure and Type of Homes

It is important that the new homes delivered over the plan period are provided in sustainable locations, can provide a mix of types and densities that are appropriate to their location, and can help to meet local needs.

Affordable housing is an umbrella term that encompasses lots of different tenures of housing that are provided at a cost below market homes. It is important to understand and plan for what is most needed in South Warwickshire. Similarly, there is an ongoing need for a wide range of specialist types of housing across South Warwickshire, such as that for disabled people, older people, students and single people.

Current policy sets affordable housing requirements and thresholds, according to locally identified needs, as well as requirements in relation to housing tenure and mix.

What was said in the I&O

Consultees noted different approaches to affordable housing:

A single affordable housing requirement across the whole South Warwickshire area would provide a consistent approach across both Districts.

Separate affordable housing requirements for each District would go some way towards reflecting local requirements and local viability calculations.

A more localised approach could reflect with greater accuracy the variations of value, or variations in affordable housing demand, in different areas of the Districts.

Increasing the overall housing requirement significantly above the identified need was the most popular response for the best way of significantly increasing the supply of affordable housing. Increasing the proportion of affordable housing with each development also received significant support.

There were conflicting views regarding delivering affordable homes in rural/countryside and green belt areas, whilst noting the site costs that can be associated with brownfield development. A more localised approach was favoured for affordable housing requirements for different localities across South Warwickshire.

The definition of 'affordable' housing was queried as well as how this is calculated.

Regarding housing for older people, responses pointed out the benefits of sites solely for older people's housing, as well as the benefits of integrating older people's housing into general mixed use community developments. Requiring the integration of older persons housing into larger scale development allocations was favoured.

There was not a clear housing type preference, however, overall housing choice is needed, as different people want and need different things.

Justification

It is important that policies are based on the latest evidence of housing needs. The Coventry & Warwickshire Housing & Economic Development Needs Assessment (HEDNA 2022) considers the needs for housing type, tenure and mix across South Warwickshire, including for affordable and specialised housing. The forthcoming Strategic Housing Market Assessment (SHMA) work to be completed in 2025 will provide the latest data for affordable and specialist housing. The Government's revisions to the NPPF also directly impact emerging policy on affordable and specialist housing.

5.2 Providing the Right Size of Homes

It is vital that new homes meet the needs of their occupiers, and future occupiers, in terms of the internal space available in new dwellings. New homes should have adequately sized rooms and efficient room layouts which are functional and fit for purpose to meet the changing needs of occupiers.

There is currently no policy within either the Stratford-on-Avon District Core Strategy, or the Warwick District Local Plan, which specifies local minimum space standards across all new homes. Policy CS.9 of the Stratford-on-Avon Core Strategy does however make a reference to having 'a good standard of space', and CS.19.B requires 1 and 2 bed affordable homes to be built with bedrooms capable of satisfactorily accommodating two occupiers in each room.

The Nationally Described Space Standards (NDSS) were introduced by Government in October 2015 and set out technical internal space standards for new dwellings, being standards for the gross internal (floor) area of new dwellings at a defined level of occupancy as well as floor areas and dimensions. In 2020 they were made mandatory for permitted development. NDSS policy has since been adopted in many local plans across the country to secure accessible levels of internal amenity.

To ensure accessible living, the introduction of enhanced building regulations as policy would recognise the issues faced by our ageing population locally and enable people with disabilities/ poor health to remain in their own home. Planning policy guidance states the local planning authority will determine what standard of accessibility is required for each development.

• Building Regulations Part M4(2) - Accessible and adaptable dwellings - is a higher standard (similar to Lifetime Homes) that requires new dwellings to be more easily accessed and adapted should the need arise in future. Features include wider doorways, bathroom walls suitable for grab rails and stairs that will easily accommodate a stairlift.

• Building Regulations Part M4(3) - Wheelchair user dwellings – is a higher standard that requires new dwellings to be fully wheelchair adaptable or accessible. This includes two sub-categories:
  • M4(3) (a) meets the layout requirements for a wheelchair accessible property
  • M4(3) (b) fully fitted so a wheelchair user can occupy with minimal personalised adaptations.

Across the local authorities with the largest populations in the West Midlands, the M4(2) and M4(3) targets are being advanced through local plan processes.

What was said in the I&O

Both South Warwickshire Councils identified the benefits of having minimum internal space standards and, via a Notice of Motion in Warwick District Council, sought the Nationally Described Space Standard to be applied through a local plan policy. Both Councils also recognised the accessibility needs associated with an aging population, and the potential of the Plans to require enhanced accessibility standards via the Building Regulations.

Most individuals and landowners favoured introducing minimum standards for space and to a lesser extent accessibility, whereas developers and land promoters strongly favoured no new minimum standards unless local need and viability is shown.

Stratford District Council's housing policy specialists advocated for the introduction of NDSS, the enhanced building regulations, as well as the retention of the current SDC policy CS.19 Part B that seeks to ensure that affordable housing bedroom sizes are sufficient to sustain two-person occupancy. Space matters because there is an expectation for affordable homes that two children of the same sex up to age 16 years share a bedroom, and because many people with disabilities live in affordable homes and require adequate space to accommodate their needs.

Justification

Amenity Standards

National planning policy guidance sets out the approach for implementing the NDSS as policy and states that local planning authorities should consider Need, Viability, and Timing.

In terms of need, the HEDNA 2022 identifies high affordable housing needs in South Warwickshire. Due to the higher cost of housing in the districts, many households are being excluded from the owner-occupied sector. In order to reduce the cost of new market housing within South Warwickshire, there is a risk that the delivery of new homes in the district will be smaller than the 'nationally described space standards' and that an intervention is required to ensure that new homes deliver the appropriate amount of internal floor space and are well designed through a new policy.

The SDC Housing Strategy 2021 evidence log notes that poor space standards on units on developer led s106 sites (for affordable housing) are an issue and that some housing associations are refusing to take on sub-sized properties (i.e. those below NDSS). Current Homes England practice is generally to require NDSS to be met in new grant funded schemes.

Feedback from Council officers highlight the need for NDSS to prevent sub-standard living arrangements, for both new builds and conversion to HMOs. Recent planning appeal decisions at Gaydon Lighthorne Heath and Stratford on Avon highlight the issue of room size for amenity, confirming the NDSS act as a good guide or indictor of what comprises acceptable levels of space at a national level and for the assessment of a proposal.

Further assessment is being undertaken on the extent of non-compliance with NDSS and whether this is more prevalent for certain types of residential development.

Further viability testing will be undertaken to ensure the NDSS will not have a material impact on the deliverability of housing schemes, including affordable housing, within the districts.

It is considered the Local Plan preparation process provides sufficient time for developers to prepare for introduction of the standards, which have been national guidance for several years, and already been adopted as local planning policy by many other councils.

In addition to the NDSS, it is considered necessary to retain and make applicable to the whole of South Warwickshire, the existing SDC policy regarding 1 and 2 bed affordable homes being able to support double/twin occupancy, noting ongoing difficulties presented by the "bedroom tax", noting that stock is typically limited in smaller rural settlements.

Accessible Living Standards

Inclusive and accessible design approach in housing and the built environment can address the needs of both younger and older disabled / non-disabled people. Housing accessible standards are required to ensure fairness of access to housing. This is particularly important for affordable housing, which is typically provided on larger development schemes.

The enhanced Buildings Regulations are designed and built to a standard that meets the needs of occupants with differing needs, including some older or disabled people, and are only slightly more expensive to build than standard housing. They must also allow adaptation to meet the changing needs of occupants over time. Homes built to this standard are more flexible and readily adaptable as people's needs change, for example if they have children and require easy access for pushchairs, if they have a temporary or permanent disability or health issue, or as they gradually age and their mobility decreases.

The HEDNA 2022 highlights the older populations of South Warwickshire compared to West Midlands and UK. A growing ageing population will drive a need for housing which can meet the needs of older persons, including catering for limited mobility and disability, which is forecast to increase in time.

HEDNA 2022 Table 14.24 shows the estimated need for wheelchair user homes by 2032, being approximately 10% market housing and up to 30% affordable housing. The HEDNA specifically recommends all dwellings (in all tenures) should be required to meet the M4(2) accessibility standards and a minimum of 10% of homes should be required to meet the M4(3) wheelchair user dwellings (and greater proportions for the affordable sector).

Research commissioned by the West Midlands Combined Authority on accessible homes recommends all new homes to be accessible and adaptable M4(2) unless built in line with M4(3), and all plans should set a clear M4(3) policy. The provision of accessible homes (e.g. built to M4(2) standard) ensures any further building adaptions to M4(3) standard are easier, less invasive and less costly; and supports independence, wellbeing and ability to be economically active.

It is envisaged that the standards will be applied through planning conditions or section 106 agreements, which will require an agreed number of units to be constructed to the specified Building Regulations requirements. The policy provides an element of flexibility in recognition of the practicalities of delivering these enhanced building standards, for example given the challenges that may arise around the topography of some sites, where access within the gradients specified in the Building Regulations may not be achievable.

5.3 Providing Custom and Self-Building Housing Plots

Self and custom build homes (SCB) are a unique type of housing which form one element of the government's approach to increasing housing supply and meeting demand. The definition of SCB housing covers a wide spectrum, including projects where individuals are involved in building and/or managing the construction of their home from beginning to end, as well as projects where individuals commission their home whilst making key design and layout decisions.

The NPPF defines self-build as "Housing built by an individual, a group of individuals, or persons working with or for them, to be occupied by that individual. Such housing can be either market or affordable housing".

The 2015 Act (as amended by the Housing and Planning Act 2016) does not distinguish between self-build and custom housebuilding and provides that both are where an individual, an association of individuals, or persons working with or for individuals or associations of individuals, build or complete houses to be occupied as homes by those individuals.

Self-build and custom housebuilding cover a wide spectrum, from projects where individuals are involved in building or managing the construction of their home from beginning to end, to projects where individuals commission their home, making key design and layout decisions, but the home is built ready for occupation ('turnkey').

Government guidance makes it clear that, in considering whether a home is genuinely self-build or custom-build, a local authority must be satisfied that the initial owner has a primary input to its final design and layout. This should include both the external and internal aspects of the dwelling. Conversely, off-plan dwellings purchased prior to construction and without such input from the initial owner are not considered to meet the definition of self-build and custom-build housing.

The Self-Build and Custom Housebuilding (Register) Regulations 2016 oblige all district councils in England to keep a register of individuals (and associations of individuals) who are seeking to acquire serviced plots of land in their area for this purpose.

Warwick District and Stratford-on-Avon District Councils each have their own Self-Build and Custom register, which helps to inform the level of demand to guide decision making. Local Authorities can choose to work together to publicise and promote their registers, with a single application form, provided it is clear to which authority the application is being made.

What was said in the I&O

The Issues and Options suggested three potential approaches to self-build and custom-build homes:

• Option H5a: Identify a range of specific sites within, or on the edge of, existing settlements of approximately 5-20 homes in size, to be developed only for self and custom build homes.
• Option H5b: Require large developments, of say, over 100 homes, to provide a proportion of self and custom-build homes within the overall site.
• Option H5c: Rely on a case-by-case approach, whereby planning applications for self and custom build homes will be assessed against a range of criteria to determine suitability.

The majority of the respondents favoured Option H5a, to identify a range of specific sites for self and custom build. The next most popular option was Option H5c to rely on a case-by-case approach to delivery.

The 'Individual' respondent category marginally favoured Option H5a. Developers and Land Promoters favoured Option H5a and H5c, which they did so equally. Landowners preferred Option H5a.

Justification

To meet the demand for this type of housing within South Warwickshire, we need to increase the land made available to be able to do so. There are several ways plot availability can be increased to meet demand, with the best solution being a combination of these options, to allow greater opportunity is provided for those on the self-build registers to gain land to develop their own property in the way which suits them.

The requirement (A) for 5% of provision for self and custom build on large sites provides a reasonable proportion to meet the overall anticipated self and custom demand.

On unallocated sites (C) a criteria-based approach is utilised, which allows the Councils to assess applications for self and custom build housing on a case-by-case basis. This allows the market to identify where there is the greatest need and demand for this type of housing, as well as emphasise support for the delivery of self-build and community-led housing.

This hybrid approach provides flexibility for allowing the provision of more self-build and custom-build developments across the South Warwickshire districts.

5.4 Meeting the Accommodation Needs of Gypsies, Travellers, Travelling Showpeople and Boat Dwellers

National Planning Policy requires Local Authorities to undertake an assessment of the accommodation needs of Gypsy, Travellers and Travelling Showpeople. In the SWLP area this assessment also examined the needs of Boat Dwellers. The SWLP is required to put an appropriate policy framework in place to ensure that the accommodation needs of these groups are provided for throughout the plan period. This will require the identification of a range of sites across the SWLP area.

What was said in the I&O

The Issues and Options Consultation suggested several ways that might be utilised to increase the availability of accommodation required for Gypsy and Travellers and Travelling Showpeople. It also suggested that a combination of the options set out may also be a consideration. The options are set out below:

Option 6 a: Identify a range of specific sites in sustainable locations of up to 15 pitches/plots in size to be developed only for Gypsy and Traveller and Travelling Showpeople homes.

Option 6 b: Require large developments of over 500 homes to provide a proportion of Gypsy and Traveller and Travelling Showpeople homes on the edge of the overall site.

Option 6 c: Rely on a case-by-case approach whereby planning applications for Gypsy and Traveller and Travelling Showpeople homes will be assessed against a range of criteria to determine their suitability.

The responses to the above options were mixed. Options H6a and H6c were favoured fairly equally. As option H6c is a less suitable option to rely on alone, a combination of these two options may be deemed favourable. Developer and Land Promoter interest considered it unacceptable to require large developments to provide a portion of Gypsy and Traveller and Travelling Showpeople accommodation need on the edge of large sites.

Justification

The NPPF stipulates that Local Authorities should assess and plan accordingly to provide the homes that it needs to meet the future needs of its communities, including travellers. Planning Policy for Traveller Sites (PPTS 2024) sets out the Governments overarching aim to ensure fair and equal treatment for travellers in a way that facilitates the traditional and nomadic way of life of travellers while respecting the interests of the settled community. The Governments aims include increasing the number of traveller sites in appropriate locations to address under provision and maintain an appropriate supply.

Local planning authorities are required to make their own assessment of need for the purposes of planning and to develop fair and effective strategies to meet need through the identification of land for sites.

Comments were received from the Development Industry in the Issues and Options consultation arguing against the approach of utilising larger allocations to accommodate future needs. This policy direction is continuing with this approach because insufficient sites have been forwarded in the call for sites exercises. The Local Plan has an obligation to identify a supply of sites through the Plan period so cannot rely solely on Issues and Options approach H6c which was to rely on planning applications coming forward and being assessed on an ad- hoc case-by-case basis.

Stratford-on-Avon District and Warwick District Gypsy, Traveller, Travelling Showpeople and Boat Dwellers Assessment – August 2024

Stratford on Avon District and Warwick District final GTAA report 18924.pdf An Accommodation Assessment was undertaken by consultants on behalf of the two Council's and was finalised in August 2024. The study's main conclusions are set out below.

There is an overall accommodation need in the South Warwickshire (Stratford-on-Avon District and Warwick District) local authority areas over the Plan period to 2050 (a 25-year period) of 89 pitches. This requirement for 89 pitches has been derived using the 'ethnic identity' methodology. This is the most robust and inclusive way of arriving at the overall need figure. This methodology meets the accommodation needs of all households that ethnically identify as Gypsies and Travellers. There is also an identified need for 18 additional Travelling Showpeople plots and 35 permanent residential moorings for boat dwellers during the same period (subject to engagement with a Marina at Napton in relation to their delivery intentions following a recent Lawful Development Consent for a site for up to 197 moorings). In relation to transit provision, it is recommended that the authorities incorporate a policy to address negotiated stopping places for transient and / or visiting Gypsy and Traveller encampments. It is also recommended that the local authorities consider the development of transit sites, and that as a minimum, they collectively develop two transit sites, each site to accommodate between 8 and 10 caravans. Ideally, with one site located in each of the two authority areas. However, it is recommended that this is in conjunction with the implementation of a negotiated stopping places policy.