Q-H2-1: What is the best way to significantly increase the supply of affordable housing across South Warwickshire?
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). 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. 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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Page 181 (Policy CS.19 – Housing Mix and Type) states that: “…Affordable Housing requirements and thresholds dependent on location. Requirement for 35% requirements relating to on-site provision, affordability and tenure, on-site integration and delivery…” Lockley Homes response: Lockley Homes maintains its view that there has been a huge, substantial, unprecedented and significant recent material change, and a huge and rapid shift in highly damaging adverse economic circumstances now facing the South Warwickshire Region and the wider United Kingdom, due to the presence of the ongoing global coronavirus pandemic (COVID-19), economic uncertainty caused by Russia’s Spring 2022 invasion of Ukraine, and the subsequent severe and unprecedented economic downturn. Which is anticipated to cause one of the worst economic recessions in the UK in living memory since records began. The severity of the forthcoming recession is now acknowledged by central Government (London), who accept that the COVID-19 pandemic has caused one of the worst economic recessions within the UK not seen for the last 300 years. This is highly significant, and should now result in an urgent re-shaping of affordable housing, Community Infrastructure Levy (CIL), planning obligations, and infrastructure policies within the Council’s emerging Local Plan Review. The Council’s preparing the emerging SWLP and its sister document Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) now need to begin to finally accept that their highly onerous planning policy position on these policy issues now needs to change to help support the highly fragile local economic recovery, and help support the house building development industry at a time when they are bringing forward sites under an incredibly challenging economic climate, which will affect the financial viability of many housing schemes. A highly onerous affordable housing and CIL/ planning obligations/ infrastructure demands approach therefore needs to be avoided within the emerging Local Plan Reviews referred to above. The worst global health pandemic event to affect the UK for the last 100 years, combined with the presence of one of the most severe economic recessions for the last 300 years, should now result in a more supportive Development Management and Planning Policy approach being taken (to support the interests of the private sector development industry and rural landowners) by the LPA within the emerging SAP and SWLP in relation to unreasonable and highly onerous affordable housing planning policy requirements, Community Infrastructure Levy (CIL) planning policy requirements, and other infrastructure demands/ planning policy requirements being placed on the house building development industry, the local business community and rural landowners looking to bring forward sustainably-located new housing development sites. In order to help support the future financial viability of new housing development schemes coming forward across the district at an incredibly challenging time, and to help support the fragile local economic recovery across the district. This approach would be consistent with Government guidance reinforced in paragraph 82 (indent d) of the Revised NPPF (2021) which confirms that: “…Planning policies should (indent d) be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices…, and to enable a rapid response to changes in economic circumstances…” The rapid change in economic circumstances as described above now facing the South Warwickshire Region Local Plan area (which has had a huge and devastating impact on the local economy) should now therefore be carefully shaped into the Plan-making approach being taken by the District Council’s going forwards within both the emerging SAP and SWLP Local Plan Reviews, and their policy formulation. To ensure that the plan-making approach taken within the emerging Local Plan Reviews is based on a platform of sufficiently robust and up-to-date evidence, is deliverable, and responds effectively to the rapid change in severe adverse economic circumstances now facing the local area, consistent with guidance reinforced within paragraphs 31, 35 (indent b) and 82 (indent d) of the Revised NPPF (2021). The severe and unprecedented global coronavirus (COVID-19) pandemic, and the continued 15 months of pro-longed lockdown restrictions across the UK during the years 2020 and 2021, has highlighted and placed into very sharp focus the continued relevance and importance of the need for LPA’s to build-in sufficient planning policy flexibility when they are drafting policies within emerging Local Plan Reviews, for the reasons clearly set out above. These ‘pandemic-related factors’ are of critical importance and should now therefore be carefully shaped into and form part of the planning balance when preparing the Council’s emerging SAP and SWLP Local Plan Reviews as the Plans move forward to their next stage of Local Plan preparation. The evidence is perfectly clear, all of the above ‘pandemic-related’ factors appear to have been given no planning policy consideration and material planning weight whatsoever by the LPA’s when preparing the Council’s emerging Site Allocations Plan (SAP) and emerging South Warwickshire Local Plan (SWLP). We have concerns about this ongoing failure being taken towards Local Plan preparation by the Council’s Planning Policy Teams, who after all, are supposed to be experts in Local Plan preparation. In particular, we consider that any new policies contained within the new emerging SWLP covering policy areas such as affordable housing policy, will need to substantially revised and current planning policy affordable housing threshold levels substantially reduced, to help ensure that the future financial viability of new residential development schemes coming forward across the South Warwickshire Region is not adversely affected and site viability severely harmed. The affordable housing planning policy origins and foundations are sitting on top of a huge mountain of unstainable and insufficiently robust evidence, given that the affordable housing policy is being directly carried over from the existing Stratford-on-Avon District Council’s existing adopted Core Strategy (adopted July 2016), which is forged, set and fixed on highly questionable, insufficiently robust, heavily out-of-date pre-COVID-19 economic data. This Core Strategy (adopted July 2016) no longer has any planning policy credibility to dictate the 35% affordable housing policy trigger threshold, and to carry this over and force-it-through into the emerging SWLP (2023). The Council’s planning policy on these issues is no longer defendable and fails clear tests in paragraph 31 of the Revised NPPF (2021) which reinforces that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…” The evidence would seemingly suggest that the Council’s evidence base on these issues is unsound, and no longer fit for purpose to inform future Plan preparation work going forward within the emerging SAP and SWLP Local Plan Reviews. The Council’s preparing the emerging SAP and SWLP Local Plan Reviews now need to face the reality of the new economic situation, and start to begin to finally accept that times have now significantly changed and moved on since the year 2016 Stratford-on-Avon District Core Strategy was adopted. We would suggest that a 5% affordable housing planning policy threshold going forward within the emerging SWLP Local Plan Review (2023) would be more appropriate given the massive long-term shift in the adverse economic conditions now facing the Local Plan area as described in detail above. Similar to affordable housing, the same issues equally apply to LPA Community Infrastructure Levy (CIL) excessive, onerous and highly damaging planning policy requirements and unreasonable planning policy demands. The existing planning policy evidence base that underpins and provides the current planning policy platform and policy foundations to support the current CIL planning policy regime across the South Warwickshire Local Plan Review area, now lacks any kind of planning policy credibility given that its policy assumptions are now based on a heavily out-of-date and unsound set of economic circumstances. The existing planning policy approach therefore places an unreasonable, highly damaging, excessive and onerous financial burden on the house building development industry, due to wholly unreasonable and heavily out-of-date CIL planning policy requirements. The existing planning policy approach and unreasonable policy regime therefore needs to be urgently revisited and heavily revised within the emerging SWLP Local Plan Review, and more appropriately shaped towards reflecting the heavily adjusted set of long-term adverse economic circumstances now facing the Local Plan area as described above. The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider UK economy should now play a prominent role in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews, in particular, those policies covering affordable housing, CIL, planning obligations, infrastructure planning policy requirements, etc. In order to ensure that the Council’s planning policy Plan-making approach on these matters is sufficiently robust and responds effectively to NPPF guidance referred to within this response. The approach described above, would correspond well to guidance in paragraph 31 of the Revised NPPF (2021) which is perfectly clear that: “…The preparation and review of all policies should be underpinned by relevant and up-to-date evidence…” As well as by guidance in paragraph 82 (indent d) of the Revised NPPF (2021) referred to further above These critically important ‘pandemic-related factors’ described above therefore require critical consideration by Stratford-on-Avon and Warwick District Council’s Planning Policy Teams as part of their ongoing Plan-preparation work going forwards. To ensure that the Council’s planning policy approach is sufficiently robust, based on a platform of credible and fit-for-purpose evidence, and responds effectively to guidance in paragraphs 31, 35 (indents b and c) and 82 (indent d) of the Revised NPPF (2021).
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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 PPG12 . 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 trendbased 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 Method Affordable % Standard Method Affordable Housing Policy Requirement Notional Provision to Meet Rented Affordable Need in Full Coventry 1,887 1,964 96% 25% 7,548 North Warwickshire 131 119 110% 30-40% 374 Nuneaton & Bedworth 407 409 100% 25% 1,628 Rugby 407 735 55% 20-30% 1,628 Stratford-on-Avon 419 868 48% 35% 1,197 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 12 PPG ID-2a-018 to 2a-024 REPORT JBB8799.C8269 | South Warwickshire Local Plan: Issues & Options | Final | rpsgroup.com Page 18 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 a 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)13, 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 policy14. 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.
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Councils should deliver more affordable housing. Given that Kenilworth houses are exorbitantly expensive what would the model be for making any affordable? Do all the building developers stick to their remit for affordable housing. Clearly not, as it is in their financial interests to circumvent this. This needs to be addressed at a government and a council level. Being able to avoid providing enough affordable housing is not in the local populations interests. Urban sprawl is of huge concern for Kenilworth. Further large scale development will alter the nature and attractiveness of this historic town. There are sensitive historical and archaeological sites that should not be swept aside for new development. Green belt land to the west of Kenilworth is inappropriate for new development as it is designated Special Landscape.It is also part of the historic deer park to Kenilworth Castle and provides the setting to the castle.
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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
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Option H2-2c: A more localised approach with separate affordable housing requirements for different localities across South Warwickshire Affordable housing requirements should be determined to suit the needs of the regions and the aspirations of the people wishing to move into those regions, however measures will be required to ensure that there are no deliberate manipulations to ‘fudge the system’. The consideration of it being more difficult for developers to anticipate their costs is the developer’s problem.
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4.9. 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. 4.10. 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. 4.11. 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. 4.12. 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. 4.13. 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.” 4.14. 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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4.9. 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. 4.10. 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. 4.11. 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. 4.12. 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. 4.13. 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.” 4.14. 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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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.” It is identified at paragraph 4.4 of the HEDNA that the overall affordable need is high relative to the overall housing needs. As stated within this paragraph also, …'policies for affordable housing provision within local plans should therefore be influenced by a combination of the needs evidence, viability evidence…' The NPPF also outlines the important role that strategic policies play in the delivery of affordable housing. Furthermore, paragraph 63 states that 'where a need for affordable housing is identified, planning policies should specify the type of affordable housing required and expect it to be met on-site unless: a) off-site provision or an appropriate financial contribution in lieu can be robustly justified; and b) the agreed approach contributes to the objective of creating mixed and balanced communities.' The South Warwickshire Local Plan will have an important role in meeting the unmet housingneed and assist in the wider unmet affordable housing need across Coventry and Warwickshire. The Issues and Options consultation recognises that the area has an acute affordability problem, and it is suggested that to address this, the Plan must consider providing housing above the ‘minimum’ need, to boost supply, and in turn deliver additional affordable housing. The evidence base provided so far demonstrates that there is an undersupply of affordable housing that needs to be addressed which the previous local plans have not delivered. A new settlement allocation within the plan provides the opportunity to deliver and boost the supply of much needed affordable housing within both districts.
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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 strongly recommend 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 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 South Warwickshire agree 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 to 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 a proportionate 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.
4.9. 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. 4.10. 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. 4.11. 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. 4.12. 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. 4.13. 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.” 4.14. 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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4.9. 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. 4.10. 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. 4.11. 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. 4.12. 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. 4.13. 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.” 4.14. 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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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. 4.10. 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. 4.11. 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. 4.12. 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. 4.13. 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.” 4.14. 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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The plan should make best endeavours to meet all housing needs, including those of the elderly. It must also be recognized that many elderly people prefer to remain in their own home for as long as they are able to do so.
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The plan should make best endeavours to meet all housing needs, including those of the elderly. It must also be recognized that many elderly people prefer to remain in their own home for as long as they are able to do so.
4.9. 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. 4.10. 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. 4.11. 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. 4.12. 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. 4.13. 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.” 4.14. 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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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.
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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.
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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.
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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 The Church Commissioners 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 to significant for both Councils to allocate a 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 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. 4.12 It therefore follows that housing should be planned for in excess of twice the annual trendbased alternative need suggested by the HEDNA. Whilst this may be unrealistic, it remains more feasible than alternatives such as relying on affordable housing exception sites, relying on the Councils to deliver ‘Council housing’, or increasing the percentage of affordable housing provided on housing sites to unviable levels. 4.14 As a result, whilst acknowledging that the full scale of the affordable housing need is unlikely to be met, it remains that both Councils are obligated to allocate sites for housing significantly in excess of the trend-based alternative figure suggested by the HEDNA (41,975 dwellings across the Plan Period) and that all options to do so have been fully explored and exhausted, including Green Belt release.
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The Parish Council considers the problem of providing affordable homes in high land and house price areas has proved intractable nationally so that affordable and social housing numbers have declined sharply. Large sites are much more likely to deliver affordable housing either for rent or shared ownership.
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Q-H2-2: The Parish Council considers the HEDNA analysis indicates that half of all housing growth results from a shortage of affordable homes. With regard to the above options, larger sites are much more likely to deliver affordable housing either for rent or shared ownership. The issue with the lack of social housing is due to Local Authorities not building any such housing, over a long period of time. During this period a vast number of tenants have taken advantage of their right to purchase their home after just 5 years’ occupancy. This situation and distortion of the housing market is grossly unfair to those Local Authorities who recognise their responsibility in this area and to individuals who search in vain for a home at an affordable rent. Warwick and Stratford District Councils should work in conjunction with housing associations and the Rural Housing Associations that have delivered housing in the past to re-establish their role of providing rented housing for those who work in their area. QH2.3 The Parish Council consider that the best way of addressing this social concern is at a local level, where local voluntary / church groups can be very effective. Local grants to assist such organisations should be made available, and Parish and Town Councils are often well placed to assist with such initiatives.
It is noted on page 9 of the document that median house prices in both districts are over ten times average salaries. Given it is only possible to borrow five times a salary this demonstrates the scale of the affordable housing problem in the area. The first step in ensuring an adequate supply of affordable housing is to ensure that the definition of affordable is crystal clear. The starting point for this is the definition in the NPPF which states, “Affordable housing: housing for sale or rent, for those whose needs are not met by the market…”. This is reflected in the definition in the glossary at the end of the document. What is missing at present are the calculations setting at what value or rent a house is considered affordable. This is a critical element as it affects the amount developers are prepared to pay for land. It is therefore essential that the calculations which will underpin the price of what constitutes a genuinely affordable house are established as soon as possible. This can be done regardless of which sites are selected for development.
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It is noted on page 9 of the document that median house prices in both districts are over ten times average salaries. Given it is only possible to borrow five times a salary this demonstrates the scale of the affordable housing problem in the area. The first step in ensuring an adequate supply of affordable housing is to ensure that the definition of affordable is crystal clear. The starting point for this is the definition in the NPPF which states, “Affordable housing: housing for sale or rent, for those whose needs are not met by the market…”. This is reflected in the definition in the glossary at the end of the document. What is missing at present are the calculations setting at what value or rent a house is considered affordable. This is a critical element as it affects the amount developers are prepared to pay for land. It is therefore essential that the calculations which will underpin the price of what constitutes a genuinely affordable house are established as soon as possible. This can be done regardless of which sites are selected for development.
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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. 3.34 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. 3.35 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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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 Warwick, is in excess of the trend-based alternative figure for overall housing provision that is also suggested by the HEDNA (811 dwellings per annum). 4.9 Caddick Land 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 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. 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 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. 4.12 It therefore follows that housing should be planned for in excess of twice the annual trendbased alternative need suggested by the HEDNA. 4.13 Whilst this may be unrealistic, it remains more feasible than alternatives such as relying on affordable housing exception sites, relying on the Councils to deliver ‘Council housing’, or increasing the percentage of affordable housing provided on housing sites to unviable levels. 4.14 As a result, whilst acknowledging that the full scale of the affordable housing need is unlikely to be met, it remains that both Councils are obligated to allocate sites for housing significantly in excess of the trend-based alternative figure suggested by the HEDNA (41,975 dwellings across the Plan Period) and that all options to do so have been fully explored and exhausted, including Green Belt release. Greenfield development sites have a proven track record of delivering affordable housing as are not subject to viability considerations that often lower obligations on brownfield sites. They therefore form a critical part of any strategy to increase housing affordability. Q-H2-2: Caddick Land acknowledges the need for affordable housing across South Warwickshire, but reiterates that market conditions and housing need should be taken into account by the Councils. Given that market conditions and housing need (both market and afford able) vary across South Warwickshire, it is considered that it is most appropriate for each authority to have a separate affordable housing requirement (Option H2-2b). Similar to CIL, it is important the two district’s keep their affordable housing require ments separate, as their housing figures remain separate and therefore ensures this overall figure for each district is achievable. In addition, separate affordable housing requirements takes into account items such as geographical location and therefore the difference in land values, it also provides the opportunity for each District to target their own specific affordable housing need. This is supported by Paragraph 0044 (Reference ID: 23b-004-20190901) which sets out that plan makers should consider how needs and viability may differ between site typologies. However, regardless of the affordable housing requirements proposed, the Council need to ensure that Policy is flexible in wording, allowing for viability to be taken in account and demonstrated where required to do so. 4.16 Furthermore, the proposed affordable housing policy is a strategic policy, which should be set out by establishing and understanding the need requirement, therefore the policy should be informed by evidence. This is supported by Paragraph 004 5 (Reference ID: 23b004-20190901) which sets out that planning obligation policies should be informed by evidence of infrastructure and affordable housing need, and a proportionate assessment of viability. Consequently, there is potential that the two local authorities have different needs, and therefore the Policy should be addressed in accordance. However, Caddick Land cannot comment on details relating to specific quantified amounts, as there is no viability evidence presented alongside this consultation at present. 4.17 Option H2-2c should not be considered as it would result in affordable housing requirements being unclear and potentially unknown, therefore introducing risk, impacting upon bringing sites forward and ultimately delivering the required housing figures.
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Issue H2: Providing the right tenure and type of homes Additional points were also raised around Issue H2 and the need to address elderly housing raised in Q-H2-3. To address the issue of increasing aging population a robust approach should be taken, seeking provision of elderly housing and adapted housing as a specific element in strategic proposals/allocation (particularly around Extra Care opportunities and potential) using available HMA, ONS and County based evidence. Also consider specific allocations for Extra Care units and High Dependency units along with their associated health care provision, related to the specialised needs generated by the elderly as part of the housing need to be directly addressed. Furthermore, an additional standards issue that may not be adequately covered in Issue H3: Providing the right size of homes also relates to affordable housing provision and delivery within housing developments. Affordable housing delivery as part of major applications or allocations, whether standard housing or elderly, should not be concentrated in one part of a site but spread evenly or “pepper-potted” throughout the site layout. This requirement needs to be reinforced in any subsequent affordable housing policy developed.
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NWBC Response – Address elderly need within Plan policy either as a specific element/part of housing type and mix for specific strategic sites/allocations (using identified age profile needs for specific settlements or areas, if available) or include as a %percentage requirement within strategic policy for strategic proposals to address, based on ONS/Census data and age profiles/projections for the South Warwickshire Plan area. Alternatively consider specific allocations for Extra Care units and High Dependency units along with their associated health care provision, related to the specialised needs generated by the elderly (either through targeted contributions from development to address those needs or on-site provision as part of the proposal/allocation) as part of the housing need and type to be directly addressed. No further comment
As mentioned in the previous Knight Frank response (ref. 2102), principal contributions to affordable stock arise predominantly through the delivery of greenfield sites. In particular, large-scale mixed-use developments, such as the proposed site at Copham’s Hill, Stratford-upon-Avon (ref. ID 385), are best placed to provide an important amount of affordable housing. Therefore, positively worded supporting policies would likely lead to an increase in affordable housing. Local planning authorities can also improve the delivery of affordable housing through the creative use of their own resources, including land within its ownership and working effectively with other providers of affordable stock. Consideration should be given to alternative approaches such as the conversion of existing stock or vacant housing, further accelerating the delivery of social and intermediate housing. The provision of affordable housing should not exceed the technical housing standards, particularly the set national standards (Nationally Described Space Standards).
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Q-H2-1. What is the best way to significantly increase the supply of affordable housing across South Warwickshire? 3.38 RPS consider Option H2-2a ‘a single South Warwickshire wide affordable housing requirement’ the most appropriate. 3.39 The demand for affordable housing is a significant factor that should be considered in establishing the housing requirement. Para 15.21 of the HEDNA document advises that there is a requirement for 3,833 social or affordable rented homes per annum across the HMA from households who cannot afford to meet their needs within the open market. In addition, the core analysis within the report indicates that there is a need for around 609 affordable home ownership homes per annum. 3.40 The greatest need is shown to be within South Warwickshire, with the evidence pointing to a lack of or very modest need for affordable home ownership products. It is expected that the principal way of delivering this affordable housing would be via Section 106 agreements. 3.41 In addition to ensuring a sufficient supply of affordable housing, RPS contends that housing for key workers should be considered as an option, in the context of Coventry Gateway West there is an ability for the site to provide dedicated worker accommodation for the principal employment growth around the wider Coventry Gateway site 3.42 The demand for affordable housing is a significant factor that should be considered in establishing the housing requirement for South Warwickshire. Q-H2-1. What is the best way to significantly increase the supply of affordable housing across South Warwickshire? 3.43 RPS welcomes the reference in the SWLP Issues and Options document (Table 10) to the need for a ‘net need’ of 1,386 affordable dwellings to be provided for each year up to 2050. RPS recognises that the unaffordability of housing is a function of under-supply and that improvements in affordability can be tackled through increasing the supply of market housing. 3.44 Figure 11, based on affordability data recently published by ONS2, illustrates the affordability problem in South Warwickshire currently. As can be seen, Stratford has the second highest affordability ratio in the West Midlands, only behind Malvern Hills, with Warwick sixth overall. 2 ONS Table 5c, Ratio of median house price to median gross annual (where available) workplace-based earnings by local authority district, England, and Wales, 1997 to 2020 Figure 3-1 Affordability of Housing across the West Midlands 3.45 The new housing requirement for the SWLP is calculated in part to address affordability issues through the 'affordability uplift' when calculating the local housing need figure for the area (under Step 2 of the method). The resultant increase in the demographic starting point (based on household change) would then, ultimately, feed through to the identification of additional land to help address the problem of affordability in the SW area. Nonetheless, RPS considers the affordability problem facing the SW area to be significant relative to neighbouring areas and so, on that basis, the SWLP should assess the adequacy of the affordability uplift in addressing the chronic and long-standing unaffordability of housing seen across the SW area and whether it is appropriate to consider a further adjustment to address the problem of unaffordability. This can be addressed through an appropriate adjustment to the housing figures to assist in increase the delivery of affordable housing, in line with advice in the PPG3. 3 Paragraph: 024 Reference ID: 2a-024-20190220 Revision date: 20 02 2019 3.46 RPS would also recommend that, separate to the above, that the SWAs consider at an early stage applying an adjustment to the total housing figure specifically to assist in addressing the need for affordable housing. Similarly, given that current affordable housing target is already set at 35% in the Stratford Core Strategy (under Policy CS.18), there is very little scope to increase the provision sought within the existing supply under the current policy. The likely result of this would be the need for additional land to be identified to assist in addressing the affordable housing need uplift. Such an approach was adopted by the Gloucester, Cheltenham, and Tewkesbury in 2017, where affordability is currently better compared to the SW area. Through the identification of more land, RPS argue that it would become more viable to deliver more affordable homes given the need is spread more widely, thus reducing the burden on individual sites. 3.47 We contend Option H2-2a ‘A single South Warwickshire wide affordable housing requirement’ is the best option. For the purposes of consistency across both districts which currently are different in their affordable housing requirements in the new developments. The resultant effects of this, means certainty for developers, greater certainty in anticipating their costs and greater certainty in anticipating delivery of affordable homes. 3.48 For the HMA as a whole, when considering past delivery, an affordable housing requirement of 35% would be incapable of delivering a sufficient quantum of affordable housing to meet the identified need. Based on the above, RPS supports any measure to increase the overall supply of housing in order to address housing (un) affordability of housing generally and specifically to address the need for affordable housing in the SW area. Warwick District Council reached an agreement with Coventry City Council to accommodate 94 affordable dwellings per annum towards Coventry’s affordable housing need. In total this means Warwick District needs to accommodate 374 dwellings per annum, which equates to 40% of the average annual housing requirement. Warwick District Council has only achieved this target twice in the past ten years.
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