Q-H2-1: What is the best way to significantly increase the supply of affordable housing across South Warwickshire?
3.43 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. 3.44 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. 3.45 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.
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47 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). 2.48 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. 2.49 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. 2.50 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. 2.51 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.
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2.48. Fundamentally, the best way to increase the supply of affordable housing across South Warwickshire is to allocate more land for market housing (a proportion of which would be delivered as affordable). 2.49. The principal barrier to a housing development’s ability to deliver affordable housing is viability, which is particularly less assured on brownfield sites and in new settlement allocations hence why affordable housing provision is inevitably reduced on such sites. The Councils therefore need to carefully consider the impact of their preferred strategy, along with the financial implications that other policy requirements may have on the provision of affordable housing, for affordable housing provision to remain viable throughout the plan period and to boost supply. 2.50. While it is appreciated that building more houses does not necessarily bring the value of homes down, ensuring that more than enough land has been allocated to meet housing needs will greatly assist in the timely delivery of market housing which, assuming that other policy requirements are pitched correctly, will translate to the timely delivery of an increased quantum and range of affordable housing product.
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Issue H2. Providing the right type and tenure of housing. Table 10 on page 105 highlights the fact that total affordable need at 547 (Stratford) and 839 (Warwick) is almost as high as the trend-based figure of 868 (Stratford) and 811 (Warwick) from the HEDNA (Table 9). One of these must be wrong or incompatible – otherwise there will be no prospect of resolving housing needs in the two authorities. The two Councils need to take a long hard look at whether they wish to tackle housing shortfalls in Stratford and Warwick through this Local Plan. Against that background, it is naïve to suggest that the price of market housing is not linked to the availability of affordable housing. The more market housing (at lower price levels is delivered) the less will be the pressure on affordable housing. The two are inter-linked. The identification of up to 4 new settlements will involve a very heavy investment in infrastructure in building communities from scratch. Often affordable housing is sacrificed to build expensive roads and heavy infrastructure. The Councils need to consider whether a high investment new settlement approach is therefore ideal. The solution is therefore to allocate higher levels of housing per se, enforce affordable housing quotas as a priority, introduce pathways to home ownership (for example First Homes and shared ownership which require less subsidy) and seek other tenure options which can relieve affordable housing pressures – for example elderly and extra care accommodation. Whether there are single or separate affordable housing requirements for Stratford and Warwick Districts is irrelevant.
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Issue H2: Providing the right tenure and types of homes The HEDNA has found that there is a need for 547 affordable housing units in Stratford District per annum, and 839 units in Warwick District per annum. We welcome the comment that ‘The Plan needs to explore ways of significantly increasing the delivery of affordable homes across South Warwickshire. Q-H2-1: What is the best way to significantly increase the supply of affordable housing across South Warwickshire? We consider that the best way to significantly increase the supply of affordable housing across South Warwickshire is to provide the policy context which enables developments to come forward in a range of settlements, which provide a mix of affordable and market housing local housing needs. This provides an incentive to developers to bring sites forward, ensures the viability of development proposals, and provides a mix of housing to meet an identified requirement. This strategy also increases the flexibility of the Plan to ensure consistent housing delivery in changing circumstances, and avoids the issue of an over reliance on significant infrastructure provision before housing can be delivered. Q H2-2 asks whether affordable housing should be considered across the Plan area, separately in each District, or should offer a more localised approach. We would propose that Option H2 – 2b is most appropriate, setting separate affordable housing requirements for Warwick and for Stratford upon Avon Districts. We note that the requirement for affordable housing in Warwick District is significantly higher than in Stratford-on-Avon District, and therefore it would be more appropriate to set different requirements, and to provide certainty at the District level.
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Issue H2: Providing the right tenure and types of homes The HEDNA has found that there is a need for 547 affordable housing units in Stratford District per annum, and 839 units in Warwick District per annum. We welcome the comment that ‘The Plan needs to explore ways of significantly increasing the delivery of affordable homes across South Warwickshire. Q-H2-1: What is the best way to significantly increase the supply of affordable housing across South Warwickshire? We consider that the best way to significantly increase the supply of affordable housing across South Warwickshire is to provide the policy context which enables developments to come forward in a range of settlements, which provide a mix of affordable and market housing local housing needs. This provides an incentive to developers to bring sites forward, ensures the viability of development proposals, and provides a mix of housing to meet an identified requirement. This strategy also increases the flexibility of the Plan to ensure consistent housing delivery in changing circumstances, and avoids the issue of an over reliance on significant infrastructure provision before housing can be delivered. Q H2-2 asks whether affordable housing should be considered across the Plan area, separately in each District, or should offer a more localised approach. We would propose that Option H2 – 2b is most appropriate, setting separate affordable housing requirements for Warwick and for Stratford upon Avon Districts. We note that the requirement for affordable housing in Warwick District is significantly higher than in Stratford-on-Avon District, and therefore it would be more appropriate to set different requirements, and to provide certainty at the District level.
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There is an acute recognition in the Issues and Options consultation documents of an affordability problem across South Warwickshire Plan area, where those on low incomes and young people struggle to access the housing market. Warwick District Council’s latest ‘Authority Monitoring Report’ (AMR) (for the period 2020-2021) indicates that against an annual requirement of 280 affordable dwellings since the beginning of the currently adopted Plan period in 2011 (within its own area), the Council have delivered 841 affordable dwellings (out of a total requirement for 2,800), 30% of the target. Stratford-on-Avon’s latest AMR for the period 2021-2022 (published December 2022) identifies that in the current Core Strategy plan period of 2011-2031, 3,204 affordable dwellings have been provided out of a total 10,019 dwellings (net) built. This equates to 37% of all dwellings and is just above the Plan’s affordable housing policy requirement of 35% of all dwellings to be affordable. Notwithstanding Stratford-on-Avon’s marginal reported over delivery, the HEDNA considered the affordability issue across the District further. 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. Whilst it is recognised that these are ‘net’ figures and not ‘newly arising need’, PPG paragraph 2a-024 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.” The Issues and Options consultation recognises that the area has an acute affordability problem, and it is suggested that to address this, the Plan could consider providing housing above the ‘minimum’ need, to boost supply, and in turn deliver additional affordable housing.
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Issue H2: Providing the right tenure and types of homes The HEDNA has found that there is a need for 547 affordable housing units in Stratford District per annum, and 839 units in Warwick District per annum. We welcome the comment that ‘The Plan needs to explore ways of significantly increasing the delivery of affordable homes across South Warwickshire. We consider that the best way to significantly increase the supply of affordable housing across South Warwickshire is to provide the policy context which enables developments to come forward in a range of settlements, which provide a mix of affordable and market housing local housing needs. This provides an incentive to developers to bring sites forward, ensures the viability of development proposals, and provides a mix of housing to meet an identified requirement. This strategy also increases the flexibility of the Plan to ensure consistent housing delivery in changing circumstances, and avoids the issue of an over reliance on significant infrastructure provision before housing can be delivered.
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As detailed in Chapter 6 of South Warwickshire Local Plan Part 1 (Stage 2: Issues and Options Consultation, January 2023), the primary source of affordable housing is through delivery as part of market housing schemes. We are not aware of any policy change which is likely to alter this position. Thus, we strongly recommend that the best way to significantly increase the supply of affordable housing across South Warwickshire is to allocate sites for residential development significantly above the minimum objectively assessed need. This aligns with the planning practice guidance which makes clear the identified need is a minimum starting point and uplifts can be applied where it is justified. This approach would in our view meet the test of soundness by being positively prepared to meet local need, justified by being based on an appropriate evidence base and consistent with national policies aim of significantly boosting the supply of homes. To ensure the Plan is effective, we recommend that as the Plan preparation progresses, South Warwickshire agrees Statements of Common Grounds with all landowners and developers that have draft allocations within the plan, this will assist in demonstrating deliverability at independent examination.
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In order to address the specialist needs for older people, we recommend that a specific planning policy is included in the South Warwickshire Local Plan. Similar to that contained within the Warwick District Local Plan (September 2017) and Stratford-on-Avon District Core Strategy (2011-2031), a criteria-based approach would be considered an appropriate mechanism for controlling the delivery of older people accommodation. However, these Plan’s do not allocate sites which are suitable for meeting the identified need and instead rely on applicants demonstrating proposals meet the needs of older people. In order to ensure older people accommodation is delivered in South Warwickshire, we recommend the plan incorporates appropriate allocations. This could either be as part of a wider mix-used schemes or sites solely for the delivery of older people accommodation. This strategy will accord with the test of soundness detailed in paragraph 35 of the NPPF (2021) by meeting the objectively assessed need through allocated sites which have derived from aproportionate evidence base. It will also align with national planning policies which state that plans should reflect the need for different groups in the community, including older people. It is essential that older people accommodation is situated in highly sustainable locations which are accessible to facilities and services to meet the day to day needs of the residents. This will not only support the environmental objective by reducing the need to travel but it will result in significant social benefits by creating a strong, vibrant and healthy community. As part of the proposal for Land North of Stratford Road, Warwickshire Property Development Group are proposing to deliver a care home adjacent to the proposed local centre. It is strongly contended that the older people accommodation will meet the needs of the local community, in a location which accords with local and national sustainability objectives.
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The Consultation Paper asks what is the best way to significantly increase the supply of affordable housing – an issue that is particularly relevant to theTanworth area. We are not familiar with the law and in particular the question of viability which seems to be critical but is not explained. We cannot comment except to note that the Council was relaxed about agreeing “discounted houses” in a small development under construction in Tanworth (which are not affordable because of high market prices ) instead of insisting on the affordable homes required by the original planning permission. It seems to us that the problem is lack of determination rather than lack of policy.
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Affordable housing is a significant issue for the SWLP. It is firstly important to have in mind that delivering housing to meet identified needs will assist in keeping affordability ratios in check, since demand will meet need and will avoid housing prices rising due to elasticity of supply issues. Even in circumstances where housing need is being identified and met, there is an acute need for affordable housing in South Warwickshire. The public sector is unable to deal with this issue, it is therefore for the private sector to deliver necessary affordable housing provision. Exception type housing will deliver a proportion of affordable provision, this however will be very low. The most effective way of delivering affordable housing is via allocations and windfall development over the plan period, by way of an appropriate – viability tested – threshold and percentage delivery requirement. The SWLP should maximise the delivery of market housing delivery, so as to correspondingly maximise the opportunity to deliver affordable housing. This is singularly the only way in which meaningful quantities of affordable housing will come forward in the plan period.
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Affordable housing is a significant issue for the SWLP. It is firstly important to have in mind that delivering housing to meet identified needs will assist in keeping affordability ratios in check, since demand will meet need and will avoid housing prices rising due to elasticity of supply issues. Even in circumstances where housing need is being identified and met, there is an acute need for affordable housing in South Warwickshire. The public sector is unable to deal with this issue, it is therefore for the private sector to deliver necessary affordable housing provision. Exception type housing will deliver a proportion of affordable provision, this however will be very low. The most effective way of delivering affordable housing is via allocations and windfall development over the plan period, by way of an appropriate – viability tested – threshold and percentage delivery requirement. The SWLP should maximise the delivery of market housing delivery, so as to correspondingly maximise the opportunity to deliver affordable housing. This is singularly the only way in which meaningful quantities of affordable housing will come forward in the plan period.
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By a policy that responds to the PPG and encourages the delivery of a wide cross section of house types suitable for older people.
Crest Nicholson welcomes the fact that the Issues and Options consultation document recognises the affordability of housing across South Warwickshire as a key issue, particularly for younger people and others who work in the area on lower incomes. The need for a greater focus on affordability, tenure type, and mix of housing to be delivered in the South Warwickshire is an important aspect of delivering sustainable communities. Housing stock is the most appropriate indicator of housing supply and housing need. Where past housing delivery has not met housing need, this results in suppressed household formation in younger age cohorts and an imbalance between housing supply and housing demand. In turn, this has influenced the increasing gap between average incomes and average house prices. Getting this mix of homes right will maximise the beneficial impact that the delivery of more homes can bring. For example, planning for the right size homes can help address affordability and planning for specialist housing such as older peoples’ housing in the right locations through allocations can have the knock-on effect of freeing up much needed family homes. 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. In addition, planning for more routes into home ownership, such as First Homes and Shared Ownership, will help younger people make that important first step onto the housing ladder. This objective is important to develop and sustain a mixed community to support economic activity and growth. The South Warwickshire Local Plan, and any associated CIL charging also 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, as identified in response to Q-H2-1, the supply of affordable housing, and the affordability of housing in general, is also influenced by the overall supply of housing coming forward. The South Warwickshire Plan 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. It is important the solutions for addressing the affordability gap are addressed at the earliest stages of policy-making and through undertaking site assessments for allocations.
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Planning for a range of types and sizes homes in suitable locations, as well as homes that are capable of adaptation to respond to changing requirements, can help address affordability and provide opportunities for the housing needs of older people to be met
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4.10 Chapter 8 of the HEDNA includes an analysis of affordable housing need in Coventry & Warwickshire, which is claimed to follow the methodology set out in the PPG14. Table 10 of IO document summarises the assessment of need for the SW authorities (drawn from Table 8.45 of the HEDNA) which is presented below. Table 4-2 Net Affordable Housing Need (per annum) – South Warwickshire only Rented---------------------Affordable Need------------- Affordable Home Ownership Need-----------Total Affordable Need Stratford-upon Avon----419------------------------------129-----------------------------------------------------547 Warwick-------------------582-------------------------------258----------------------------------------------------839 SW area------------------1,007-----------------------------378---------------------------------------------------1,385 Source: SWLP IO Jan 2023, Table 10; HEDNA Table 8.45; RPS 4.11 It is recognised in the published evidence base that affordable housing need is ‘high’ relative to the overall housing need across the C&WHMA (paragraph 4.4 of the HEDNA). RPS agrees. Table 8.14 of the HEDNA illustrates this point when comparing affordable need (rented need only) to the trend-based projections for each authority, including Stratford-upon-Avon and Warwick. The table showing the need across all C&WHMA authorities is represented below. Table 4-3 Net Affordable Housing Need (per annum) – C&W HMA -------------------------------Net Rented Need ---- Adjusted Standard ---- Affordable % ----- Affordable Housing ----- Notional Provision to Meet Rented -----------------------------------------------------------------Method ------------ Standard Method --- Policy Requirement ----- Affordable Need in Full Coventry -------------------1,887--------------------------1,964---------------------96%-----------------------25%-----------------------7,548 North Warwickshire-------131-----------------------------119---------------------110%--------------------30-40%----------------------374 Nuneaton &-----------------407-----------------------------409---------------------100%----------------------25%-----------------------1,628 Bedworth Rugby------------------------407-----------------------------409---------------------100%--------------------20-30%---------------------1,628 Stratford-on-----------------419-----------------------------868----------------------48%-----------------------35%-----------------------1,197 Avon Warwick---------------------582-----------------------------811----------------------72%-----------------------40%-----------------------1,455 Warwickshire-------------1,946--------------------------2,942---------------------66%----------------------------------------------------6,282 C & W----------------------3,833--------------------------4,906---------------------78%---------------------------------------------------13,830 Source: C&W HEDNA Table 8.14 4.12 The figures show that the rented affordable need as a proportion of the overall need for housing in the SW authorities is between 48-72% (or 60% across the two combined). Across the C&WHMA as whole, the proportion is 78%. When adding in the affordable home ownership need, the proportions increase from 60 to 82% for the SW area, and from 78 to 91% for the C&WHMA. It is clear that the proposed policy targets will only deliver a fraction of the homes needed even if the policy requirements are met in full (which is unlikely). Affordable housing need therefore represents a significant proportion of overall need which needs to be addressed in the SWLP, and across the HMA as a whole, when considering future housing targets for the area. This is particularly the case in Warwick, but is nonetheless still an important factor in Stratford also. 4.13 In addition, the scale of affordable need as a proportion of total need shown above is, to a large extent, due to the need emanating from Coventry, which is 96%. The HEDNA (at paragraph 8.72) recognises that, in setting overall housing targets, the viability of development and the availability of funding are realistically constraints on the level of provision which can be achieved. If Coventry is to make any significant contribution towards meeting its own housing needs, of all tenures, then additional allocations will be needed. This will require a considerable focus on delivering more housing on previously-developed sites within the city’s boundaries and the push for higher policy targets. However, the focus on brownfield land and higher policy standards will inevitably raise concerns with the viability and deliverability of lower value housing. This is evident because Coventry has failed to deliver its affordable housing policy targets since 2011, achieving 2,562 affordable homes against a policy target of 3,828 (2011-2022)15, or 232 homes per annum. 4.14 On this basis, in devising an overall housing requirement in the SWLP, if the SW authorities are serious about addressing affordable housing delivery then consideration should be given to how the delivery of affordable can be maximised across the C&WHMA in order to deliver sufficient affordable homes to meet local needs, in line with national policy16. The best way to increase the supply of affordable housing across South Warwickshire is therefore simply to allocate more land in sustainable locations within the area. This is best achieved through the development of mixed-tenure private sector-led development in areas where viability is less of a problem, notably in South Warwickshire, relative to metropolitan areas such as Coventry. 14 PPG ID-2a-018 to 2a-024 15 Coventry City Authority Monitoring Report 2021/22 Published 21st November 2022, Figure 9 16 NPPF 2021, paragraph 20
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Questions H2-1 and H2-2 4.38. Within issue H2 on providing the right tenure and mix type of homes, the above analysis emphasises both the role of the private sector in delivering dwellings of all tenures (including affordable) together with the challenges for increasing provision of affordable homes taking account of the ownership of land across the plan area. To achieve increased delivery of housing, especially affordable is only feasible and realistic where there is close partnership working between private and public sectors. 4.39. Table 10 on page 105 of the consultation draft Local Plan explains the level of need for affordable housing. This is 547dpa for Stratford-on-Avon District and 839dpa for Warwick District which (63% and 103% of the respective overall housing needs for each authority as assessed in the HEDNA). Such levels are not viable to deliver even with partnership working of the private and public sectors. 4.40. Whilst there is a need for affordable housing in both authorities, to ensure that its delivery is directed to residents in need within the respective authorities there should be a separate target for each area. 4.41. We do not consider that affordable housing targets should be refined to apply varying requirements within each authority as this would only be appropriate if there is clear evidence in terms of: A) The need for affordable housing including size and tenure including from the housing waiting list; B) How affordable housing need compares to that for market homes (including size) to ensure socially mixed communities; C) That the level of need will not affect viability of development; D) There is sufficient acceptable land to meet the need; and E) That the phasing of delivery is appropriate without either displacement of need into other areas or it resulting in over-provision with households relocating across the plan area. 4.42. These are all matters which would mean that the approach of the plan is not addressing the wider needs of the area as envisaged in NPPF paragraph 61
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The need for a greater focus on affordability, tenure type, and mix of housing to be delivered in the South Warwickshire is an important aspect of delivering sustainable communities. 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 therefore be seeking to plan for the delivery of more than the minimum number of homes identified by the HEDNA to assist with this. Consideration of site viability, particularly in regards to the number of brownfield sites or sites required to deliver a significant amount of infrastructure, will also be important to ensure sites are delivering an appropriate level of affordable housing.
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Specific sites should be allocated to deliver specialist homes for older people. This will ensure that there is a sufficient supply of suitable dwellings in the right places being delivered across the plan period.
In our view the most appropriate way of “significantly increasing” the overall supply of affordable housing across South Warwickshire is to have a housing requirement that is sufficient to support the delivery of much needed affordable housing through planning obligations. This matter is addressed in response to Q-H1-1 above. In terms of the three strategies proposed, we have no particular preference between a plan wide affordable housing requirement, a separate affordable housing requirement for Stratford-upon-Avon and Warwick districts or a localised approach. We would, however, suggest that the simplest approach would be to have a plan wide figure. As the Draft Plan points out, the extent of administrative boundaries is unlikely to be the principal factor that people consider when looking for affordable properties. It is, however, acknowledged that a universal affordable housing policy will not address the significant variance in affordability across the plan area, which can only be addressed by a localised approach.
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4.8 Table 8.45 of the HEDNA (reproduced at Table 10 of the Consultation Document) identifies that there is a total annual affordable housing need of 547 dwellings in Stratford and 839 dwellings in Warwick (totalling 1,386 homes per year). This need is significant and, in the case of Stratford, is in excess of the trend-based alternative figure for overall housing provision that is also suggested by the HEDNA (868 dwellings per annum). 4.9 Catesby Estates submits that the only way to realistically deliver affordable housing at a level that is anywhere close to the level of identified need would be for both Councils to allocate a significantly greater number of sites to deliver market housing over and above the minimum need identified by the HEDNA (either Standard Method or trend-based alternative). Such development would include a portion of affordable housing, in line with the relevant Local Plan policy. 4.10 At present, there is a policy requirement for 35% of proposed residential dwellings to be affordable homes in the Stratford District and 40% in the Warwick District. 4.11 As such, if the total trend-based alternative need figure (1,679 dwellings) was provided annually, and even if assuming affordable housing was provided at 40%, this would result in the provision of 671.6 affordable homes per year; 714.4 dwellings per year less than the identified annual affordable housing need. Clearly, it would be challenging to deliver the and meet the affordable need in full, but the Local Plan should do all it can to tackle the affordability issue by identifying additional sites for housing.
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2.30 The Local Plan needs to address the key strategic issue of housing and affordability. The main approach of dealing with this issue is by facilitating housing growth to ensure a balance of demand and supply which will be the only means of driving housing prices down. The allocation of sites will also facilitate the delivery of affordable housing. Since the adoption of the Core Strategy, national policy has developed following first the Housing White Paper, Fixing the Broken Housing Market (February 2017), and then latterly the Revised NPPF (2021), which build on that original document. 2.31 The key messages of national policy have therefore been ensuring faster delivery, diversification of supply and consequent strong support for small and medium housebuilders and smaller sites in sustainable rural locations. NPPF paragraph 20a emphasises the importance of a comprehensive strategy in respect of housing delivery, which in turn reflects section 19(1B)-(1C) of the PCPA 2004. 2.32 NPPF paragraph 60 continues to emphasise the importance of boosting supply. This is reinforced by NPPF paragraphs 74 to 77, which collectively set in place a requirement to ensure a healthy, rolling 5 year housing land supply. 2.33 NPPF paragraph 69 reflects the need to ensure a range of small and medium sized sites, as these can be built out quickly on the importance of choice and competition and paragraphs NPPF 78-79 in respect of delivering supply at villages). These are all key components of soundness under NPPF paragraph 35. 2.34 A number of these principles are reflected in the most recent Housing White Paper: Planning for the Future (August 2020) and Changes to the Current Planning System (August 2020), which represent a clear direction of travel for national policy in the early part of 2021, and thus during the examination of the new Local Plan.
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In our view the most appropriate way of “significantly increasing” the overall supply of affordable housing across South Warwickshire is to have a housing requirement that is sufficient to support the delivery of much needed affordable housing through planning obligations. This matter is addressed in response to Q-H1-1 above. In terms of the three strategies proposed, we have no particular preference between a plan wide affordable housing requirement, a separate affordable housing requirement for Stratford-upon-Avon and Warwick districts or a localised approach. We would, however, suggest that the simplest approach would be to have a plan wide figure. As the Draft Plan points out, the extent of administrative boundaries is unlikely to be the principal factor that people consider when looking for affordable properties. It is, however, acknowledged that a universal affordable housing policy will not address the significant variance in affordability across the plan area, which can only be addressed by a localised approach.
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2.45. Fundamentally, the best way to increase the supply of affordable housing across South Warwickshire is to allocate more land for market housing (a proportion of which would be delivered as affordable). 2.46. The principal barrier to a housing development’s ability to deliver affordable housing is viability, which is particularly less assured on brownfield sites and in new settlement allocations hence why affordable housing provision is inevitably reduced on such sites. The Councils therefore need to carefully consider the impact of their preferred strategy, along with the financial implications that other policy requirements may have on the provision of affordable housing, for affordable housing provision to remain viable throughout the plan period and to boost supply. 2.47. While it is appreciated that building more houses does not necessarily bring the value of homes down, ensuring that more than enough land has been allocated to meet housing needs will greatly assist in the timely delivery of market housing which, assuming that other policy requirements are pitched correctly, will translate to the timely delivery of an increased quantum and range of affordable housing product.
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This question needs to be dealt with in two different ways. There should be a policy relating specifically to the towns and larger settlements and a further policy dealing with the rural area and the different settlements. You will see our answers to various questions above which bear on tenure and type. For the rural areas whilst there needs to be housing provision by unit across the board, there should not be a predominance of one bedroomed housing units because of the need to accommodate families in three / four bed housing and also the need to provide for bungalows and housing for the disabled in the various locations in the rural area. Much of the rural area lies in Green Belt and for those larger settlements that lie in the Green Belt there must be a much more flexible approach to housing growth to provide for both local needs and long term needs in the Plan period stretching to 2050. Table 12 for market housing seems appropriate but realistically the four bed provision should be 20%.
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This can be dealt with by a proper “needs assessment” for each settlement and then the adoption of an appropriate policy, with some flexibility, for inclusion in the strategy for growth for the rural area.
This question needs to be dealt with in two different ways. There should be a policy relating specifically to the towns and larger settlements and a further policy dealing with the rural area and the different settlements. You will see our answers to various questions above which bear on tenure and type. For the rural areas whilst there needs to be housing provision by unit across the board, there should not be a predominance of one bedroomed housing units because of the need to accommodate families in three / four bed housing and also the need to provide for bungalows and housing for the disabled in the various locations in the rural area. Much of the rural area lies in Green Belt and for those larger settlements that lie in the Green Belt there must be a much more flexible approach to housing growth to provide for both local needs and long term needs in the Plan period stretching to 2050. Table 12 for market housing seems appropriate but realistically the four bed provision should be 20%.
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This can be dealt with by a proper “needs assessment” for each settlement and then the adoption of an appropriate policy, with some flexibility, for inclusion in the strategy for growth for the rural area.