Q-H2-1: What is the best way to significantly increase the supply of affordable housing across South Warwickshire?
Enforced, high precentage affordable housing requirements.
selected
selected
selected
No answer given
Stop building 4 or more bedroom estates
selected
selected
selected
No answer given
No large estates of 4 or more bed houses. These take a space of two 2 or 3 bed houses
selected
selected
selected
Start with a plan!
Infil Brownfield Increase the % of houses dedicated to affordable housing in all proposals whether small, eg 5 or larger. As a PC we find that it is impossible to get any affordable housing within a small development.
selected
selected
selected
Specific areas of suitable accommodation with easy access to local services eg;library, community services, health centres
No answer given
selected
selected
selected
No answer given
No answer given
selected
selected
selected
Q-H2-3: How should South Warwickshire best address the specialist needs for older people? Thank you for the opportunity to comment on the South Warwickshire Local Plan Issues and Options consultation. McCarthy Stone is the leading provider of specialist housing for older people. Please find below our comments on the consultation, which specifically addresses the need for specialist housing for older people. The Issues and Options consultation at Table 11, page 105 identifies a need of 234 dwellings per annum for both housing with support and housing with care. This has been derived from the Coventry & Warwickshire Housing and Economic Development Needs Assessment (HEDNA), Final Report, Iceni, November 2022. Page 105 of the consultation document , continues to question that ‘Given the high level of needs of older people, consideration may need to be given to where older people housing schemes are located and what the implications an increasing older population may have on the provision of health and social care services’. The best approach towards addressing the diverse housing needs of older people is for the plan to allocate specific sites to meet the needs of older people that are in the most sustainable locations close to key services as well as including a standalone policy actively supporting the delivery of specialist older people’s housing in the Market Towns and Larger Villages and other locations with good access to services and facilities for older people. Developers of older people’s housing schemes should not be required to demonstrate need given the many benefits that such developments bring and if a quantum is specified this should be regarded as a target and not a ceiling. Given also that such developments “help reduce costs to the social care and health systems” (PPG refers), requirements to assess impact on healthcare services and/or make contributions should be avoided. While we appreciate that no one planning approach will be appropriate for all areas, an example policy is provided that, we hope, will provide a useful reference for the Council: “The Council will encourage the provision of specialist housing for older people across all tenures in sustainable locations. The Council aims to ensure that older people are able to secure and sustain independence in a home appropriate to their circumstances by providing appropriate housing choice, particularly retirement housing and Extra Care Housing/Housing with Care. The Council will, through the identification of sites, allowing for windfall developments, and / or granting of planning consents in sustainable locations, provide for the development of retirement accommodation, residential care homes, close care, Extra Care and assisted care housing and Continuing Care Retirement Communities.” We would remind the Council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509). The evidence underpinning the Council’s planning obligations and building requirements should therefore be robust. We would also like to remind the Council that the viability of specialist older persons’ housing is more finely balanced than ‘general needs’ housing and we are strongly of the view that these housing typologies should be robustly assessed in the forthcoming Local Plan Viability Assessment. This would accord with the typology approach detailed in Paragraph: 004 (Reference ID: 10-004-20190509) of the PPG which states that. “A typology approach is a process plan makers can follow to ensure that they are creating realistic, deliverable policies based on the type of sites that are likely to come forward for development over the plan period. If this is not done, the delivery of much needed specialised housing for older people may be significantly delayed with protracted discussion about other policy areas such as affordable housing policy requirements which are wholly inappropriate when considering such housing need. National Policy Context Government’s policy, as set out in the revised NPPF, is to boost significantly, the supply of housing. Paragraph 60 reads: “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.” The revised NPPF looks at delivering a sufficient supply of homes, Paragraph 62 identifies within this context, the size, and type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies including older people. In June 2019 the PPG was updated to include a section on Housing for Older and Disabled People, recognising the need to provide housing for older people. Paragraph 001 Reference ID: 63-001-20190626 states: “The need to provide housing for older people is critical. People are living longer lives and the proportion of older people in the population is increasing. In mid-2016 there were 1.6 million people aged 85 and over; by mid-2041 this is projected to double to 3.2 million. Offering older people a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social care and health systems. Therefore, an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking” (emphasis added) Paragraph 003 Reference ID: 63-003-20190626 recognises that: “the health and lifestyles of older people will differ greatly, as will their housing needs, which can range from accessible and adaptable general needs housing to specialist housing with high levels of care and support.” Thus, a range of provision needs to be planned for. Paragraph 006 Reference ID: 63-006-20190626 sets out: “plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people. These policies can set out how the plan-making authority will consider proposals for the different types of housing that these groups are likely to require.” Therefore, recognising that housing for older people has its own requirements and cannot be successfully considered against criteria for general family housing is important. Need for Older Persons’ Housing It is well documented that the UK faces an ageing population. Life expectancy is greater than it used to be and as set out above by 2032 the number of people in the UK aged over 80 is set to increase from 3.2 million to 5 million (ONS mid 2018 population estimates). It is generally recognised (for example The Homes for Later Living Report September 2019). That there is a need to deliver 30,000 retirement and extra care houses a year in the UK to keep pace with demand. The age profile of south Warwickshire can be drawn from the 2018 population projections from the Office for National Statistics. This advises that there were 59,046 persons aged 65 and over in 2018, accounting for 21.9% of the total population of the population of the two Council areas. This age range is projected to increase by 27,344 individuals, or 46.3%, to 86,39 between 2018 and 2043. The population aged 65 and over is expected to increase to account for 26.2% of the total population of the area by 2043. In 2018 there were 16,819 persons aged 80 and over, individuals who are more likely to be frail and in need of long-term assistance. The number of people in this age range is forecasted to increase by 15,291 individuals, or 91%, to 32,110 between 2018 and 2043. The population aged 80 and over is anticipated to represent a higher proportion of south Warwickshire’s residents, accounting for 6% of the total population in 2018 and increasing to 10 by 2043. This increase in older people and resultant need is confirmed within the Coventry & Warwickshire Housing and Economic Development Needs Assessment (HEDNA), Final Report, Iceni, November 2022Table 14.3, page 306. . It is therefore clear there will be a significant increase in older people over the Plan Period and the provision of suitable housing and care to meet the needs of this demographic should be a priority of the emerging Local Plan. Benefits of Older Persons’ Housing Older Persons’ Housing produces a large number of significant benefits which can help to reduce the demands exerted on Health and Social Services and other care facilities – not only in terms of the fact that many of the residents remain in better health, both physically and mentally, but also doctors, physiotherapists, community nurses, hairdressers and other essential practitioners can all attend to visit several occupiers at once. This leads to a far more efficient and effective use of public resources. Economic A report ‘Healthier and Happier’ An analysis of the fiscal and wellbeing benefits of building more homes for later living” by WPI Strategy for Homes for Later Living explored the significant savings that Government and individuals could expect to make if more older people in the UK could access this type of housing. The analysis showed that: • ‘Each person living in a home for later living enjoys a reduced risk of health challenges, contributing to fiscal savings to the NHS and social care services of approximately £3,500 per year. • Building 30,000 more retirement housing dwellings every year for the next 10 years would generate fiscal savings across the NHS and social services of £2.1bn per year. • On a selection of national well-being criteria such as happiness and life satisfaction, an average person aged 80 feels as good as someone 10 years younger after moving from mainstream housing to housing specially designed for later living.’ Each person living in a home for later living enjoys a reduced risk of health challenges, contributing fiscal savings to the NHS and social care services of approximately £3,500 per year (Homes for Later Living September 2019). More detail on these financial savings is set out within the report. A further report entitled Silver Saviours for the High Street: How new retirement properties create more local economic value and more local jobs than any other type of residential housing (February 2021) found that retirement properties create more local economic value and more local jobs than any other type of residential development. For an average 45 unit retirement scheme, the residents generate £550,000 of spending a year, £347,000 of which is spent on the high street, directly contributing to keeping local shops open. As recognised by the PPG, retirement housing releases under-occupied family housing and plays a very important role in recycling of housing stock in general. There is a ‘knock-on’ effect in terms of the whole housing chain enabling more effective use of existing housing. In the absence of choice, older people will stay put in properties that are often unsuitable for them until such a time as they need expensive residential care. A further Report “Chain Reaction” The positive impact of specialist retirement housing on the generational divide and first-time buyers (Aug 2020)” reveals that about two in every three retirement properties built, releases a home suitable for a first-time buyer. A typical Homes for Later Living development which consists of 40 apartments therefore results in at least 27 first time buyer properties being released onto the market. Social Retirement housing gives rise to many social benefits: • Specifically designed housing for older people offers significant opportunities to enable residents to be as independent as possible in a safe and warm environment. Older homes are typically in a poorer state of repair, are often colder, damper, have more risk of fire and fall hazards. They lack in adaptions such as handrails, wider internal doors, stair lifts and walk in showers. Without these simple features everyday tasks can become harder and harder • Retirement housing helps to reduce anxieties and worries experienced by many older people living in housing which does not best suit their needs by providing safety, security and reducing management and maintenance concerns. • The Housing for Later Living Report (2019) shows that on a selection of wellbeing criteria such as happiness and life satisfaction, an average person aged 80 feels as good as someone 10 years younger after moving from mainstream housing into housing specifically designed for later living. Environmental The proposal provides a number of key environmental benefits by: • Making more efficient use of land thereby reducing the need to use limited land resources for housing. • Providing housing in close proximity to services and shops which can be easily accessed on foot thereby reducing the need for travel by means which consume energy and create emissions. • Providing shared facilities for a large number of residents in a single building which makes more efficient use of material and energy resources. The Council should also note that ensuring that residents have the ability to stay in their homes for longer through the provision of wheelchair housing, is not, in itself, an appropriate manner of meeting the housing needs of older people. Adaptable houses do not provide the on-site support, care and companionship of specialist older persons’ housing developments nor do they provide the wider community benefits such as releasing under occupied family housing as well as savings to the public purse by reducing the stress of health and social care budgets. The recently published Healthier and Happier Report by WPI Strategy (September 2019) calculated that the average person living in specialist housing for older people saves the NHS and social services £3,490 per year. A supportive local planning policy framework will be crucial in increasing the delivery of specialist older persons’ housing and it should be acknowledged that although adaptable housing can assist it does not remove the need for specific older person’s housing. Housing particularly built to M4(3) standard may serve to institutionalise an older person’s scheme reducing independence contrary to the ethos of older persons and particularly extra care housing.
No answer given
selected
selected
selected
No answer given
The basis on which affordable housing is delivered must be clearly evidence based so the best option is dependent upon the evidence and the spatial distribution of housing. However, in general terms it is likely that the Plan area is too broad for a one policy fits all approach and the HEDNA evidence clearly supports this suggesting a higher level of need in Warwick District than Stratford. We consider a more localised approach would be too complex to assess and administer and therefore option 2b is likely to deliver the right balance.
selected
selected
selected
We would support a policy addressing the specialist needs for older people in principle subject to a robust evidence base demonstrating need.
More council house builds. Agree a sensible definition of affordable.
selected
selected
selected
No answer given
Better financing of providers. And Increase and ensure on-going availability of land.
selected
selected
selected
Better financing of care homes and care staff provisions
Locate this in higher density areas of towns that have facilities and employment to support. This will support 20 minute neighbourhoods
selected
selected
selected
Allow the private sector to take this on - plenty of developments coming up. Older people will need support to find these and make the mindset shift to take these options.
close look at changing nature of town centres where retail is going through huge changes offer sustainable options without having to break into green sites. Councils may need to be more interventionist to shape developments locally to ensure developers meet rquirememts and that affordable is really that for the target groups.
selected
selected
selected
No answer given
No answer given
selected
selected
selected
No answer given
No answer given
selected
selected
selected
1. Allocate specific sites for care homes and care villages 2. Require larger sites to provide a percentage of bungalows and homes that meet with the relevant part of the Building regs
I don't know about how, but it's really important to have a mix of homes in any medium to large development.
selected
selected
selected
Specialist housing adapted to older people's needs. But still with enough floor space to make it a house where people can visit. Concentrate on flor space not number of rooms. Look to have garden and park space near by Look to be near shops, bus stops etc.
No answer given
selected
selected
selected
There should be no special concessions for any particular purpose, all should be subjected to the normal planning.
Building (more) council housing seems a good idea.
selected
selected
selected
Building old people's homes near nurseries and allowing the children and old people to interact is a nice idea that has worked in some places.
Part of the answer lies in reconsidering the whole concept of affordable housing. There are currently families with two decent salaries living in “affordable housing”. That cannot be right! Some revision of the whole concept is needed. The pretext of expecting the market homes, in more expensive areas, to directly fund the affordables, which may not be needed in their immediate area, is fundamentally unfair and unrealistic and clearly unsustainable. If we changed the system, by building “truly affordable market homes” there would be a much smaller demand for affordable/social homes, and people would be much happier. Perhaps those truly affordable market homes would need to be more modest in many ways, but they would find considerable favour and free up affordables for those who really need them. It is time to break some paradigms!
selected
selected
selected
Answer: Older People Needs will be best addressed by listening to the communities, and directing developers to respond appropriately, rather than constantly looking to their bottom line. Specifically: • Build more bungalows – always requested – seldom built – yes, we know they take more land… Perhaps have a fixed percentage for sites of say 10 or more homes? • Build more, if not all, wheelchair accessible homes. • Allocate sites specifically for “care facilities” – e.g. land around Barford House in Barford
The HEDNA analysis in the table below shows that the demand for affordable housing, mainly socially rented, exceeds or is close to the overall housing demand. The choice of location across south Warwickshire should be substantially constrained to those which meet the special needs of those residents. [Pasted table from HEDNA: Projected Annual Change in Housing ] New housing should be located in close proximity to essential services, employment, functional public transport and good walking and cycling provision. The procurement cannot follow the current model of demanding a proportion of such housing as part of a development of market housing but requires the LAs, possible working with HAs, to become the developer.
selected
selected
selected
No answer given
We believe there is too much focus on Affordable Housing need. The primary need after market housing is Social/Rented accommodation. We do not believe that Affordable shared ownership is truly affordable. It is as difficult to obtain a mortgage for that sort of property, and in many cases more difficult, and that the scheme is weighted against the owner.
selected
selected
selected
No answer given
3.24 Taylor Wimpey considers that there is an opportunity to increase the overall housing requirement for the plan period to help deliver a higher amount of affordable housing. 3.25 Table 8.45 of the HEDNA states that WDC and SDC have a combined affordable annual need of 1,386 dwellings per year, this is a significant need and would justify a higher overall housing requirement to ensure that sufficient affordable homes are being provided throughout the plan period. 3.26 It is also relevant to note that constraints on the release of land for residential development, and in turn the provision of houses on that land (for sale or as affordable provision), can lead to increased house prices in an area. The SWLP should therefore be focused on creating a policy environment that does not place undue constraints on sites that are allocated, thereby maintaining a supply that will in turn address issues of affordability.
selected
selected
selected
No answer given
No answer given
selected
selected
selected
4.8 We consider Option H2-2b; providing a separate affordable housing requirement for Stratford-on-Avon and Warwick Districts, would be appropriate in terms of reflecting local requirements and local viability calculations. However, it is considered that the tenure and type of affordable homes sought should be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. L&Q Estates support a collaborative approach to identifying site-specific affordable housing requirements, including tenure and type of affordable homes to be provided on-site.
The Issues and Options consultation recognises that the area has an acute affordability problem. The suggestion is to provide housing above the 'minimum' need, increasing both the supply of housing generally and through this additional affordable housing.
selected
selected
selected
No answer given
The standard methodology includes an affordability adjustment. However, the National Planning Practice Guidance is clear that the affordability adjustment applied to the standard methodology formula is not a solution to problems of affordability as outlined below.“The affordability adjustment is applied in order to ensure that the standard method for assessing local housing need responds to price signals and is consistent with the policy objective of significantly boosting the supply of homes. The specific adjustment in this guidance is set at a level to ensure that minimum annual housing need starts to address the affordability of homes.” (Paragraph: 006 Reference ID: 2a-006-20190220) The Plan confirms that, across the Plan area, the median house price to income ratio is over 10.5. For Stratford-upon-Avon District, the affordable housing need identified in the Table 10 of the Plan is some 547 dwellings per annum. When this is compared to the overall housing need for the district, stated at Table 9 of the Plan, affordable housing need would equate to 96% of the total housing need using the 2014-based projections, or 63% using the trend-based projections. The situation in Warwick District is worse still. Given the above, applying the standard method or trend based approach will barely scratch the surface of addressing affordability in the Plan area and accordingly, it is suggested that an affordability adjustment should be applied to the identified housing need in order to address the considerable housing affordability issue across the Plan area.
selected
selected
selected
Table 11 of the Plan only provides data until 2032 but the Plan itself covers a long period. Therefore, before an approach is determined, the level of need should be fully evidenced over the entire Plan period as this will have a direct effect on the required strategy. Nevertheless, in meeting any identified need for specialist housing for older people, large scale sites are able to cater for a wide variety of needs and therefore where evidenced, such schemes could accommodate these needs in a proportionate manner.
The NPPF is clear that: “the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to, those who require affordable housing…)” (Para 62). 2.70 In this regard, the HEDNA sets out new trend-based projections for the sub-region. The HEDNA finds that Stratford-on-Avon will need to deliver a minimum of 868 dpa over the plan period, whilst Warwick will need to deliver 811 dpa. In relation to affordable housing, the HEDNA identifies a total affordable housing need of 547 dpa for Stratford-on-Avon and 839 dpa for Warwick (Table 8.45, HEDNA). The HEDNA is clear that the affordable housing figures should be used for reference purposes and that decisions about an appropriate mix for an individual area will be informed by viability and local priorities. 2.71 Issues regarding affordability are particularly acute within South Warwickshire, with the HEDNA noting “that the areas where the need for AHO [Affordable Home Ownership] is highest (notably Warwick and Stratford-on-Avon) also show a high need for rented affordable housing” (HEDNA, para 8.98). In light of this identified need, St Philips considers that an uplift to the LHN figure should be considered. 2.72 The PPG8 is clear that an increase in the total housing figures included in the plan could help address the affordability of homes, through the delivery of an increased number of affordable homes. It is likely that there will be a substantial level of demand for affordable housing within the area and that an uplift to the LHN figure to help deliver affordable housing would likely be justified, and necessary to addressing worsening affordability. St Philips therefore considers that this is the best approach to increasing the supply of affordable housing in South Warwickshire. 2.73 In regard to the approaches set out by the IO document, St Philips has no preference between Options H2-2a and H2-2b, however considers that Option HS-2c is not an appropriate response. Paragraph 34 of the NPPF is clear that: “Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure… Such policies should not undermine the deliverability of the plan.” As the IO recognises, localised affordable housing requirements can create uncertainty, making it more difficult for developers to predict their costs and harder for Councils to predict delivery of affordable houses. This could undermine the SWLPs ability to deliver on affordable housing targets. St Philips therefore considers that Option Hs-2c should not be considered as it would not significantly increase the supply of affordable housing within South Warwickshire, and indeed, could negatively affect its provision.
selected
selected
selected
No answer given
6.13 The standard methodology includes an affordability adjustment. However, the national planning practice guidance is clear that the affordability adjustment applied to the standard methodology formula is not a solution to problems of affordability as outlined below. “The affordability adjustment is applied in order to ensure that the standard method for assessing local housing need responds to price signals and is consistent with the policy objective of significantly boosting the supply of homes. The specific adjustment in this guidance is set at a level to ensure that minimum annual housing need starts to address the affordability of homes.” (Paragraph: 006 Reference ID: 2a-006-20190220) 6.14 The Plan confirms that, across the Plan area, the median house price to income ratio is over 10.5. For Warwick District, the affordable housing need identified in the Table 10 of the Plan is some 839 dwellings per annum. When this is compared to the overall housing need for the District, stated at Table 9 of the Plan, affordable housing need would equate to 104% of identified housing need using the trend-based projections. The situation is similar in Stratford-on-Avon District. 6.15 For Coventry, the affordable housing need identified in the Table 8.13 of the HEDNA is some 1,887 dwellings per annum. When this is compared to the overall housing need for the District, 1,964 dwellings per annum, affordable housing need would equate to 96% of the total housing need using the trend-based projections. 6.16 Given the above, applying the standard method or trend-based approach will barely scratch the surface of addressing affordability and accordingly, it is suggested that an affordability adjustment should be applied to the identified housing need in order to address the considerable housing affordability issue across the Plan area. 6.17 Furthermore, to address Coventry’s affordability issues specific sites, i.e. Westwood Heath, should be identified to assist with meeting this need.
selected
selected
selected
6.18 Table 11 of the Plan only provides data until 2032 but the Plan itself covers a long period. Therefore, before an approach is determined, the level of need should be fully evidenced over the entire Plan period as this will have a direct effect on the required strategy. 6.19 Nevertheless, in meeting any identified need for specialist housing for older people, large scale sites are able to cater for a wide variety of needs and therefore where evidenced, such schemes could accommodate these needs in a proportionate manner.
Getting this mix of homes right will maximise the beneficial impact that the delivery of more homes can bring. It is essential that a mix is not prescriptive and is flexible and it should be recognised that not doing so will result in a mix that becomes redundant over time and harm the social outcomes it was designed to achieve. This will especially be the case over a long plan period, where flexibility will enable the mix to be best tailored to the needs of new communities across South Warwickshire The SWLP, and any associated CIL charging, needs to reflect the fact that the contributions and provisions expected from development arising from planning policy requirements should not cumulatively undermine the deliverability of the Local Plan. Robust regard should be given to this through the Local Plan viability assessment work when this is carried out. The unintended consequence of overloading development with additional technical, design and financial requirements could be that the amount of affordable housing being delivered ends up being reduced in order to make a development viable. Furthermore, the supply of affordable housing, and the affordability of housing in general, is also influenced by the overall supply of housing coming forward. The SWLP should accordingly be seeking to plan for the delivery of more than the minimum number of homes identified by the HEDNA to assist with this
selected
selected
selected
No answer given
Lapworth Parish Council does not have the expertise to answer this question but would note that it is important for developments to offer a mix of dwelling sizes including adapted for disabilities and the elderly rather than just 3- and 4-bedroom executive homes on site and monies for affordable housing elsewhere. Partnerships with developers and Housing Associations may be appropriate here.
selected
selected
selected
No answer given
3.27 IM considers that there is an opportunity to increase the overall housing requirement for the plan period to help deliver a higher amount of affordable housing. Table 8.45 of the HEDNA states that WDC and SDC have a combined affordable annual need of 1,386 dwellings per year, this is a significant need and would justify a higher overall housing requirement to ensure that sufficient affordable homes are being provided throughout the plan period. 3.28 It is also relevant to note that constraints on the release of land for residential development, and in turn the provision of houses on that land (for sale or as affordable provision), can lead to increased house prices in an area. The Plan should therefore be focused on creating a policy environment that does not place undue constraints on sites that are allocated, thereby maintaining a supply that will in turn address issues of affordability.
selected
selected
selected
No answer given
The NPPF is clear that: “the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to, those who require affordable housing…)” (Para 62). In this regard, the HEDNA sets out new trend-based projections for the sub-region. The HEDNA finds that Stratford-on-Avon will need to deliver a minimum of 868 dpa over the plan period, whilst Warwick will need to deliver 811 dpa. In relation to affordable housing, the HEDNA identifies a total affordable housing need of 547 dpa for Stratford-on-Avon and 839 dpa for Warwick (HEDNA, Table 8.45). The HEDNA is clear that the affordable housing figures should be used for reference purposes and that decisions about an appropriate mix for an individual area will be informed by viability and local priorities. Issues regarding affordability are particularly acute within South Warwickshire, with the HEDNA noting “that the areas where the need for AHO [Affordable Home Ownership] is highest (notably Warwick and Stratford-on-Avon) also show a high need for rented affordable housing” (HEDNA, para 8.98). In light of this identified need, St Philips considers that an uplift to the LHN figure should be considered. The PPG8 is clear that an increase in the total housing figures included in the plan could help address the affordability of homes, through the delivery of an increased number of affordable homes. It is likely that there will be a substantial level of demand for affordable housing within the area and that an uplift to the LHN figure to help deliver affordable housing would likely be justified, and necessary to addressing worsening affordability. St Philips therefore considers that this is the best approach to increasing the supply of affordable housing in South Warwickshire. In regard to the approaches set out by the IO document, St Philips has no preference between Options H2-2a and H2-2b, however considers that Option HS-2c is not an appropriate response. Paragraph 34 of the NPPF is clear that: “Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure… Such policies should not undermine the deliverability of the plan.” As the IO recognises, localised affordable housing requirements can create uncertainty, making it more difficult for developers to predict their costs and harder for Councils to predict delivery of affordable houses. This could undermine the SWLPs ability to deliver on affordable housing targets. St Philips therefore considers that Option Hs-2c should not be considered as it would not significantly increase the supply of affordable housing within South Warwickshire, and indeed, could negatively affect its provision.
selected
selected
selected
No answer given