Q-H6: Please select all options which are appropriate for South Warwickshire
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It would seem that the authorities consider that more housing is required. Not all the new housing should be 3-4 bed homes. Smaller properties are needed for first time buyers. Presumably these are not considered profitable for the developers; nevertheless these smaller properties are essential. Also ALL new housing should have solar panels fitted as part of the roof structure as standard.
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3.22 Taylor Wimpey generally support the proposed trend-based approach using the 2021 census data, which has resulted in an increase of 440 homes per year in comparison with the 2014-based projections. 3.23 It will be important that the CWHMA authorities provide the adequate evidence and justification to support deviating from the current, and potentially future, standard method for calculating local housing need.
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3.27 The provision of minimum space standards for housing should be a standard requirement for new development in South Warwickshire. 3.28 However, in this instance, Option H3a is the most appropriate option for the SWLP as minimum space standards is not a strategic priority which warrants to be included in SWLP Part 1. 3.29 The requirement for minimum space standards for housing is a development management matter which can be included in SWLP Part 2 unless it is centrally prescribed by in national development management policies as proposed by the Levelling Up and Regeneration Bill (LURB).
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Q-H1-1: The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014-based household projections towards a trend based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? 4.1 It is acknowledged that there have been issues with estimating and projecting the population in Coventry, meaning population growth in the City has been systematically over-estimated by ONS (dating back to at least 2001) and that the over-estimation works through into population projections that are demonstrably too high and unrealistic. 4.2 The draft Plan considers that as the overall housing need in Coventry is lower in the HEDNA (compared to the previous 2014-based projections), it follows that the Local Plan will be likely to need to accommodate fewer additional homes from Coventry based on these figures. 4.3 However, it is important to emphasise that the Planning Practice Guidance is clear in its approach that the ‘standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area’ (Paragraph 010; Reference ID: 2a-010-20190220). The draft South Warwickshire Local Plan should therefore reflect that the proposed ‘Housing Need’ figure is only the starting point and additional housing may be required to facilitate economic growth or the delivery of affordable housing. 4.4 For example, an appeal decision for up to 800 dwellings at the Former North Warwickshire Golf Club (Appeal Ref. APP/P4605/W/18/3192918 – a decision which was ‘called-in’ by the Secretary of State) highlighted the chronic shortfall in affordable housing which has come forward within Birmingham City since 2011. Paragraph 14.108 of the Inspector’s Report states that only 2,757 new affordable homes were provided in the City over the first 6 years of the Plan period. This represents less than half of the target provision and a net increase in only 151 affordable homes if Right to Buy sales are taken into account. The Inspector goes on to state that given the heavy reliance in the five year housing land supply on City Centre apartment schemes, it is difficult to see how that trend can be reversed in the short to medium term (paragraph 14.109). 4.5 Whilst it is noted that Birmingham City Council does not form one of South Warwickshire’s Authorities, it highlights recent difficulties with delivering homes on brownfield sites. The high proportion of flatted developments, coupled with the increased likelihood of viability issues, has led to a chronic shortfall in the provision of affordable homes. Should the South Warwickshire Authorities follow a similar approach, it may therefore be necessary to increase the Housing Requirement, in accordance with national guidance, to improve affordability. 4.6 We note that work is ongoing to confirm how much housing can be provided from various sources, both in terms of existing and future capacity to help meet the need. This includes an understanding what has already been built, has planning permission or is identified for development in existing Plans and the capacity of small ‘windfall’ sites. 4.7 Overall, we support a trend-based approach in principle. However, it is considered that any shortfall in housing supply should be regarded as a minimum given that it is currently calculated against an untested housing target that may require an upward adjustment to take account of affordability.
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Q-H3: Please select all options which are appropriate for South Warwickshire 4.9 L&Q Estates have no objection to a requirement to meet optional Building Regulations M4(2)/M4(3) in principle (Option H3c). It is considered that this should be achieved by requiring a certain proportion of homes on sites in medium or higher value zones to meet the optional standards. However, we reserve the right to comment further at a later stage, once the specific requirements for sites have been clearly defined.
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Q-H5: Please select all options which are appropriate for South Warwickshire 4.24 Whilst it is considered that Option H5a would enable the South Warwickshire Authorities to group this type of housing together in small sites in various locations, such an approach would be dependent on landowners putting sites forward for this type of housing. Therefore, this approach may not provide sufficient suitable development permissions to meet the identified demand in accordance with the duties under sections 2 and 2A of the Self Build and Custom Housebuilding Act 2015. 4.25 We consider Option H5b is appropriate for South Warwickshire, provided it can be demonstrated that there is currently a need for self-build and custom build plots identified in the self-build and custom build register for the local authority where the site is located. The proportion of self and custom-build plots to be made available within large sites should be sufficient to match the current number on the register. Such an approach would align with the aims of Paragraph 62 of the NPPF in terms of providing opportunities for people wishing to commission or build their own homes. 4.26 It is considered that any policy under Option H5b should also include a fall-back option of reverting any unsold self-build plots to the developer to build, should any of these plots not be sold after an appropriate marketing period (of, say, 12 months, for example).
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Q-H1-1 Providing the Right Number of New Homes 36. Yes, the HEDNA evidence does provide a reasonable basis for identifying future levels of housing need across South Warwickshire. 37. The provision of a sufficient level of housing growth in the SWLP is critical, in accordance with the NPPF5. 38. SWLP Issues and Options consultation evidence base includes the Coventry and Warwickshire Housing and Economic Development Needs Assessment (‘the HEDNA’, November 2022). The HEDNA seeks to explore the housing and employment needs across Coventry and Warwickshire, and applies a trend-based approach to modelling housing need in order to establish the starting point for the respective Local Authorities in plan-making. 39. The HEDNA applies the principles of the Standard Method calculation set out in national policy but utilises new demographic projections, supported by early data releases from the 2021 Census, to better reflect the needs of the respective and collective Local Authorities. The overall outcome for Coventry and Warwickshire is a decrease in annual housing need from 5,554 dwellings, derived from applying the Standard Method formula as set out in national policy, to 4,906 dwellings. Whilst there are decreases in annual housing need for some of the Local Authorities, and in particular Coventry (a considerable reduction from 3,188 dwellings per annum to 1,964 dwellings per annum), for South Warwickshire there is an overall increase as set out in Table 1 below: Table 1 - South Warwickshire Housing Need Comparison Annual Housing Need - Stratford-on-Avon - Warwick - South Warwickshire Total Standard Method 564 675 1,239 HEDNA Trend-Based 868 811 1,679 40. The NPPF sets out that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the Standard Method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals”6. National policy is therefore supportive of the approach that South Warwickshire Councils are seeking to implement, and as such utilising the HEDNA to inform the local housing need for South Warwickshire is supported. Emerging Requirement and Capacity 41. Commentary on the UCS supporting the SWLP Issues and Options consultation s provided in response to Q-S3.1 above. 42. To summarise, MacMic Group consider that the basis for housing need in South Warwickshire should be the HENDA and that the Plan period should be assumed from 2022 onwards. As a result, MacMic Group consider the local housing need for the SWLP to be 47,012 dwellings over a 28 year plan period. 43. In line with the NPPF7, it is considered that this figure represents the minimum number of homes needed, and that the Councils should consider whether it is appropriate to set a higher housing requirement in line with national guidance8; in order to address a significant affordable housing shortfall, support economic development, or address strategic infrastructure requirements which are likely to increase the number of homes needed. 44. Further consideration will also need to be given to unmet needs within the Housing Market Area in line with the Duty to Cooperate and the positively prepared test of soundness9, which is explored in further detail in response to Q-H4-1 below. 45. With regard to capacity, MacMic Group consider that there are 14,360 dwellings with planning permission at 1st April 2022 which can be included as supply, applying a 5% lapse rate to the number of dwellings set out in the respective Housing Trajectories. There are also a further 5,579 dwellings on outstanding Local Plan allocations without planning permission which can be included in the supply, however it should be ensure that such sites can still be considered to be Developable in line with the NPPF10. 46. With regard to any windfall allowance, this should be calculated on the basis of compelling evidence that it will provide a reliable source of supply, as required by the NPPF11. 5 Paragraph 11 a) and b) of the National Planning Policy Framework (July 2021) 6 Paragraph 61 of the National Planning Policy Framework (July 2021) 7 Paragraph 61 of the National Planning Policy Framework (July 2021) 8 Paragraph 010 Reference ID 2a-010-20201216 of National Guidance 9 Paragraph 35 a) of the National Planning Policy Framework (July 2021) 10 Glossary of the National Planning Policy Framework (July 2021) 11 Paragraph 71 of the National Planning Policy Framework (July 2021)
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I do not have any faith in the methodology used to produce the claim that Coventry and Warwickshire will need 1,600 homes built every year until 2050.
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Issue H5: Providing custom and self-build housing plots. Q-H5: Please select all options which are appropriate for South Warwickshire Support provision and custom and self-build housing plots.
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Q-H6: Pitches and Plots for Gypsies, Travellers and Travelling Showpeople It is considered that the SWLP should adopt a flexible approach to Gypsy and Traveller provision and this approach should utilise a combination of options H6A (identify a range of specific sites in sustainable locations) and H6C (rely on a case-by-case approach where applications are assessed against a range of criteria). This will ensure that locations are chosen that a suitable and attractive for Gypsy and Traveller and Travelling Showpeople which will ensure their needs are met. Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire The site – South East Stratford: CEG and Mixed Farms Ltd control 102 hectares of land on the south-eastern edge of Stratford-upon-Avon, which is considered to be an appropriate location for a major residential-led mixed use development, with potential for an initial short-term phase (included as a Reserve Site in the Revised Preferred Options Consultation of the Stratfordupon-Avon Site Allocations Plan – ref: STR.D (SAP)) that could be delivered early within the Plan period, without prejudicing wider growth of this strategic opportunity. The site is located on the edge of the principal and most sustainable settlement in Stratford-upon-Avon District, one of five main towns across the Plan area, and benefits from easy access to a range of services and facilities. It is not subject to any landscape designations, is located within Flood Zone 1 and does not contain any designated heritage assets. The site is located adjacent to and north of the A422 Banbury Road and would form a natural extension to the existing residential area to the east of Stratford-upon-Avon. It benefits from having direct frontage along the A422 thus enabling a new junction to be accommodated to access the development which links into existing footways. A number of local facilities including Bridgetown Primary School, recreational pitches, convenience food stores, pharmacies are in the immediate vicinity of the site. The town centre of Stratford-upon-Avon offering a range of high street retailers, restaurants and leisure facilities is within 2km of the site. Local buses travel along A422 Banbury Road as well as A4390 Trinity Way. Local bus stops are within a comfortable walking distance from the site along Banbury Road making public transport a genuine option for travel. The site benefits from excellent pedestrian infrastructure with continuous footways on both sides of A422 Banbury Road into Stratford-upon-Avon. Similarly, both A422 Banbury Road and the A4390 Trinity Way provide cycle infrastructure in the form of on-carriageway cycle lanes (A422) and a shared traffic-free cycleway/footway on the norther side of the A4390. The shared route extends from the roundabout junction with A422 Banbury Road to the immediate west of the site to the roundabout of the A4300/Severn Meadows Rd roundabout further west. The site is therefore in a highly sustainable position that benefits from excellent public transport linkages. Development in this location would provide a significant level of market and affordable housing and supporting community infrastructure. It would also help facilitate the delivery and provide financial contributions towards an eastern relief road around Stratford-upon-Avon, as required. This would, in its own right, deliver significant social and economic benefits locally and at the sub-regional level. Given that the SWLP now has a remit of exploring strategic growth opportunities, it should comprehensively consider the substantial benefits that can be delivered through large scale growth south east of Stratford-uponAvon, in particular supporting the delivery of an eastern relief road, strategic piece of infrastructure, noting that paragraph 11a of the NPPF states that plans should positively seek opportunities to meet the development needs of their area. CEG and Mixed Farms are pleased to see that growth in south east Stratford-upon-Avon features in each of the five growth options outlined in the Plan and is rightly scored as the most sustainable option in Stratford-upon-Avon. Having regard to the above, CEG and Mixed Farms proposes to prepare a detailed Vision Document for the site, which will be supported by a range of technical work to demonstrate how the site could successfully deliver a residential-led mixed use development on the edge of the largest and most sustainable settlement in Stratford-onAvon District. At this stage, a ‘Site Constraints and Opportunities Plan and Conceptual Framework’ prepared by Define is provided (see Appendix 2 to these representations) to outline how development of the site could sustainably be provided. This demonstrates that the site can address site specific considerations, comprising the following; a. Circa 1,200 market and affordable dwellings; b. Significant community infrastructure provision including a neighbourhood centre, primary school, sports pitches, public parkland and biodiversity parkland; c. A genuinely landscape-led approach that mitigates the impact on the Alveston Hill vantage point and important views; d. A substantial network of green infrastructure with green corridors that will provide opportunities for sustainable travel and recreation. This will build upon a local neighbourhood concept; e. New movement corridors to help address existing traffic and associated environmental issues within Stratfordupon-Avon itself and create strong, direct links with the economic growth aspirations at Wellesbourne as identified within the SWLP and the recently adopted Wellesbourne Innovation Campus Masterplan SPD; f. Avoiding residential development within the safeguarded zone of the high-pressure gas pipeline; and g. Strong connectivity to Stratford-Upon-Avon through improved linkages along Banbury Road. We would welcome the opportunity to discuss our proposals for the site in more detail, once the Vision Document and associated technical work has been completed. Assessment through the SAP: In the preparation of SDC’s SAP, it was clear that despite Stratford-upon-Avon being the most sustainable settlement in the District, growth was being significantly limited due to a single purported highway capacity issue. In this regard, CEG and Mixed Farms did not consider Stratford-upon-Avon District Council (SDC) struck an appropriate balance between all relevant considerations (noting the significant benefits outlined above) and would seek to ensure that the SWLP does not follow a similar path. Firstly, the matter related to highway capacity, rather than highway safety and paragraph 109 of the NPPF is clear that development should only be prevented on highway grounds if the residual cumulative impacts on the road network would be severe, which we do not consider arises in this instance even based upon the Council’s evidence. Secondly, SDC’s highway evidence supporting the SAP was not considered to be robust, in particular having regard to the substantial growth in future traffic levels that completely ignore trends over the last decade. The SWLP should therefore adopt a more realistic approach, which it appears to be taken having regard to the favourable SA outcomes for the site. It should be noted that Vectos has previously provided transport representations as part of the SAP preparation process which are summarised in a Technical Highways Note, provided at Appendix 1 to these representations, which addresses the mobility vision for the site. The Notes outlines that in relation to the development of the site, the aim is to minimise the need to travel in the first instance, internalise a proportion of trips within the site through local living principles, and where people travel outside of the site, it is practical to make the very best of the site’s locational advantages through sustainable travel modes. This will not only reduce journeys, but journey mode and will hence directly respond to the declared climate change emergency in the region whilst providing for essential growth. Furthermore, it demonstrates that the proposals can suitably mitigate impacts upon the highway network and addresses purported underlying issues with the highway network. 4.29 Thirdly, it outlines that the substantial sustainability benefits of allocating further growth a Stratford-upon-Avon had been ignored through the SAP process and as already outlined, we urge the Councils not to follow this approach again through the SWLP. Summary: Overall, the proposals represent a highly sustainable option growth option that can deliver a range of substantial benefits, a position the Council accept, noting its own evidence identifies it as one of the most sustainable options around Stratford-Upon-Avon and indeed the plan area as a whole. We would welcome the opportunity to discuss the our proposals for the site in due course, once more detailed information has been prepared.
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Q-H3: Please select all options which are appropriate for South Warwickshire. The Issues and Options document states that the Council has acknowledged, through public engagement, the request for minimum internal space standards to be applied through a local plan policy. In addition, St Philips notes that it was agreed in response to a Notice of Motion to Council in Warwick District, that the principle of incorporating Nationally Described Space Standards (NDSS) within the SWLP would be considered (see Cabinet meeting for 29 September 2022, Item 09). It is stated within the Issues and Options document that this would be considered as part of the Local Plan Review process. St Philips recognises the importance of including design-based policies within the Local Plan Review in order to enhance the existing character of the District and provide a good quality of life for current and future residents. It is important to note Footnote 49 of NPPF paragraph 130(f), which states that policies may “make use of the nationally described space standard, where the need for an internal space standard can be justified.” Furthermore, NPPF paragraph 31 states that all policies should be “underpinned by relevant and up-to-date evidence”. In addition, the PPG9 sets out: 2.79 “Where a need for internal space standards is identified, the authority should provide justification for requiring internal space policies. Local planning authorities should take account of need, viability and timing”. 2.80 In consideration of the above, St Philips advises South Warwickshire that, should a policy approach that requires the delivery of dwellings to the NDSS be adopted, the Council should provide a local assessment evidencing the case for the District in accordance with the NPPF and PPG. Therefore, it is recommended that the Council should complete further evidence gathering prior to including a policy. Additionally, it is important to note that any policy requirement would also need to be considered and tested through a viability assessment before adoption. This would ensure that the approach is supported and justified by up to date evidence and that the approach can be found to be legally compliant with both the NPPF and the PPG.
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Q-H4-1: Do you agree with the approach of contributing to meeting the Birmingham and Black Country HMA shortfall to 2031 on the identified sites in Stratford-onAvon District? No The SOADC Site Allocation Plan (SAP) identifies reserve housing sites and the mechanisms for their release, should they be required. Policy SAP. 1 sets out four purposes for identifying reserve sites, with purpose (d) being: “To contribute to meeting any housing needs arising outside the Coventry and Warwickshire HMA that is accepted through co-operation between the relevant councils as needing to be met within the HMA and most appropriately being met within the District.” 2.82 Policy SAP.1 goes on to establish that reserve housing sites will be released in accordance with the mechanisms set out in Policy SAP.3 (Releasing Reserve Housing Sites). St Philips support the Council’s approach to purpose (d), which when read with the proposed Policy SAP.4 (Releasing Reserve Housing Sites for Purpose D), would release sites with immediate effect to help address unmet housing needs in the Birmingham HMA. In this context, Policy SAP.4 identifies the following sites to be released to help meet the unmet need of the GBBCHMA: • STR.A – North of Evesham Road, Stratford-upon-Avon; • STR.B – East of Shipston Road, Stratford-upon-Avon; • STR.C – South of Alcester Road, Stratford-upon-Avon; • MAPP.A – West of Birmingham Road (south), Mappleborough Green; • STR.D – East of Banbury Road, Stratford-upon-Avon. 2.83 In total, these sites have the capacity to deliver approximately 530 homes. Whilst it is welcome that these sites would be released immediately, St Philips considers that the proposed allocations do not sufficiently reflect the scale of the unmet need within the GBBCHMA. In this regard, the SAP Preferred Options asserts that “the housing shortfall in the Greater Birmingham & Black Country Housing Market Area (GBBCHMA) that cannot be met within its boundaries is identified as being 6,302 homes up to 2031” (paragraph 2.4.1). However, there are several shortcomings with this position as set out elsewhere by Lichfields in its blog10 “All the West-laid Plans: The unmet housing needs of the Greater Birmingham and Black Country Housing Market Area”. Lichfields’ critique suggests that whilst Birmingham’s unmet housing need has probably reduced from the original 37,900 in 2017, there remains a likely – and at present, unaccounted – shortfall of between c.11,479-15,479 dwellings up to 2031. This is because several of the ‘banked’ housing contributions from other HMA districts are earmarked to help meet the Black Country’s needs. In this context, St Philips consider that the proposed allocations within the SAP do not sufficiently address the scale of the shortfall arising within the GBBCHMA. 2.85 St Philips is also concerned that the approach taken by SOADC unduly restricts the release of Green Belt sites. In this context, St Philips welcomes that the IO has taken a ‘blind’ approach towards whether potential sites are within the Green Belt. St Philips supports this approach as it ensures that the South Warwickshire Authorities do not limit the release of sites for residential purposes that would otherwise be sustainable and suitable.
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Issue H1: Providing the right number of new homes Q-H1-1: The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014-based household projections towards a trend-based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? 6.1 The NPPF 2012 introduced a radical shift in relation to the approach to meeting housing needs. This remains in the 2021 version where at paragraph 8 it outlines the three overarching objectives to securing sustainable development and paragraph 8b states that to achieve the ‘social objective’ it is necessary to “to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations…” 6.2 Paragraph 60 of the NPPF then states that “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.” 6.3 However, despite the additional requirements and objectives imposed by the NPPF, it is widely accepted that there is a national housing crisis due to the consistent failure to achieve the Government’s target of 300,000 homes per annum, with affordability unsurprisingly worsening across many parts of the country, year on year. Accordingly, it is vital the SWLP sets a positive framework to fully accommodate its housing needs and importantly address existing underlying issues as well. 6.4 The NPPF is clear at paragraph 61 that housing need should be calculated using the Government’s Standard Method unless there are exceptional circumstances to justify an alternative approach. The HEDNA outlines a rationale for applying a trend-based approach for which there is merit but noting the test of national policy for such an approach, it is considered that further justification is still required in this regard. However, regardless of whether the standard method is used, based on the 2014-based projections, or whether the alternative trendbased projection is used, this should still only be the starting point for determining the housing requirement for the Plan. 6.5 The Plan acknowledges that there will likely be a need to accommodate some unmet housing needs from adjoining authorities which of course represents one potential uplift (addressed in response to a separate question), but it is suggested that an affordability adjustment should also be applied. The Plan confirms that, across the Plan area, the median house price to income ratio is over 10.5. For Warwick District, the affordable housing need identified in the Table 10 of the Plan is some 839 dwellings per annum. When this is compared to the overall housing need for the District, stated at Table 9 of the Plan, affordable housing need would equate to 104% of identified housing need using the trend-based projections. The situation is similar in Stratford-on-Avon District. 6.6 Affordability is an on-going and increasing pressure which will require a proactive approach that should be rooted in increasing the housing requirement given that market led housing schemes have, and will continue, to deliver the biggest supply of affordable homes. 6.7 Regarding Coventry’s needs, as part of the trend based approach the HEDNA identifies historic issues with calculating Coventry’s needs which appear to be largely driven by how the student population has influenced demographic projections. Whilst further justification for this deviation from the standard method is still needed, when considering Coventry’s needs and the type of development that has taken place and is needed in the future it is still important that development comes forward that meets the needs of the whole population. 6.8 The 2021/21 AMR for Coventry indicated that housing delivery is ahead of the overall requirements established in the current Local Plan. However, of the total number of completions, 3,818 dwellings, it is important to note that a significant proportion of houses delivered were Purpose Built Student Accommodation (PBSA), 2,621 dwellings compared to 1,233 residential dwellings. 6.9 Focusing on the types of dwellings delivered, of the residential dwellings delivered in 2021/22, the majority (54%) were flats/apartments. 6.10 The type of housing delivery is also having implications for the level of affordable housing delivery, which has been continually declining throughout the plan period. From a peak of 39% in 2012/13 the general trend for affordable completions as a percentage of the overall number has continued to decline with only 5% in 2021/22. 6.11 This decline in affordable housing and the rate of PBSA being delivered within Coventry further confirms the importance of allocations coming forward that can provide a range of house types, including family accommodation. This is reinforced when looking at the needs for different house types within the HEDNA. The type of accommodation needed for Coventry is closely aligned with Warwick and Stratford-On-Avon Districts and show a clear need for family-sized market accommodation i.e. 3 bedroom houses (40%). 6.12 Given the finite supply of land within Coventry and the recent trends for smaller units and PBSA there is a clear need to ensure that developments that provide for a range of house types, in particular family-sized accommodation, to help meet Coventry’s needs. Westwood Heath is strategically well-located to provide for this type of accommodation as part of a sustainable community. Q- H6: Pitches and Plots for gypsies, travellers and travelling showpeople 6.1 Answer – It is considered that the SWLP should adopt a flexible approach to Gypsy and Traveller provision and this approach should utilise a combination of options H6A (identify a range of specific sites in sustainable locations) and H6C (rely on a case by case approach where applications are assessed against a range of criteria). This will ensure that locations are chosen that a suitable and attractive for Gypsy and Traveller and Travelling Showpeople which will ensure their needs are met. The provision of such sites as part of Sustainable Urban Extensions (option H6B) is not considered to be appropriate. Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire The site – Westwood Heath 6.2 CEG control 130 hectares of land on the southern edge of Coventry, adjacent to the University of Warwick’s main campus. 6.3 The site is located on the edge of the City of Coventry, the sub-regional centre. It therefore benefits from easy access to a range of services and facilities. It is not subject to any landscape designations, is located within Flood Zone 1 and does not contain any designated heritage assets. 6.4 Whilst situated in the Green Belt, circa 30 ha of this is identified as safeguarded land (to meet longer-term strategic development needs) through Policy DS21 of the WDLP. 6.5 Policy DS20 ‘Directions for Growth South of Coventry’ of the WDLP acknowledges the transformational change that could occur in the area and commits Warwick District Council (WDC) to an early partial review within five years of the date of adoption of the plan (Summer 2022). The policy is clear that this will allow the Council to address any additional evidence regarding the need and potential for development in this area and in particular to ascertain whether necessary infrastructure has become available to allow safeguarded land to be brought forward to meet local housing need, should additional housing be required. 6.6 The Coventry City Local Plan similarly safeguarded an area of land south of Westwood Heath Road (see Policy GB2) which would be released upon a review of the plan and clarity on development proposals within Warwick District. 6.7 Having regard to the above, WDC subsequently commenced preparation of a wider south of Coventry masterplan framework, which is in progress (further detail outlined below). 6.8 The site is located adjacent to and south of the Westwood Heath Road and would form a natural extension to the existing residential area. It benefits from having direct frontage along the Westwood Heath Road thus enabling a new junction to be accommodated to access the development which links into existing footways. 6.9 A number of local facilities including the Westwood Academy Secondary School, recreational pitches, a Sport and Wellness Hub, convenience food stores are in the immediate vicinity of the site. Tile Hill station (offering connections to Birmingham and London) is 1.4km away and Coventry City Centre is 6.4km and is accessible by Bus and Cycle. Local bus stops are within a comfortable walking distance from the site along within the University of Warwick’s main campus making public transport a genuine option for travel. 6.10 The site benefits from excellent pedestrian infrastructure with continuous footways on both Westwood Heath Road which can be enhanced. Similarly, the proximity to the campus will access existing cycle infrastructure and this will be integrated with the green travel corridor providing links into Coventry and across the area. This corridor also has the potential to integrate with wider connections to the HS2 interchange at Arden Cross. The site is therefore in a highly sustainable position that benefits from excellent public transport linkages. 6.11 Development in this location would provide a significant level of market and affordable housing and supporting community infrastructure. It would also help facilitate the delivery and provide financial contributions towards a green-travel corridor which would facilitate an improved southern access to The University of Warwick. These infrastructure improvements will align with the significant transport improvements already being implemented in the area, including the improvements at the A46 Stoneleigh Junction and the new crossing of the A45, which would, in its own right, deliver significant social and economic benefits locally and at the sub-regional level. Our proposals would also align with the opportunities identified by WDC through the planned preparation of a wider south of Coventry masterplan. 6.12 Given that the SWLP has a remit of exploring strategic growth opportunities, it should comprehensively consider the substantial benefits that can be delivered through large scale growth at Westwood Heath, in particular supporting the delivery of a green travel corridor, a strategic piece of infrastructure, noting that paragraph 11a of the NPPF states that plans should positively seek opportunities to meet the development needs of their area. 6.13 Having regard to the above, CEG proposes to prepare a detailed Vision Document for the site, which will be supported by a range of technical work to demonstrate how the site could successfully deliver a residential-led mixed use development on the edge of Coventry. At this stage, a ‘Conceptual Framework’ prepared by Define is provided (see Appendix 1 to these representations) to outline how development of the site could sustainably be provided. This demonstrates that the site can address site specific considerations, comprising the following; • Circa 2,500 market and affordable dwellings of a type that will make a significant contribution to specific housing needs, divided as follows: - Circa 650 within the safeguarded land; and - Circa 1,850 dwellings within wider land. • Employment/commercial development in a strategic location to offer collaboration opportunities between business and the university • Significant community infrastructure provision including a neighbourhood centre, a 2 FE primary school, sports pitches, public parkland and biodiversity parkland; • A substantial network of green infrastructure with green corridors that will provide opportunities for sustainable travel and recreation. This will build upon a local neighbourhood concept; • New movement corridors to help address existing traffic and associated environmental issues within Coventry and aligning with ongoing infrastructure improvements in the area, improving access to the University with the potential to facilitate access to the HS2 interchange at Arden Cross; • Ensuring development avoids coalescence between settlements through keeping development to the North of HS2; and • Strong connectivity to Coventry and the University of Warwick’s main campus, supporting its role as a Major Investment Site. 6.14 Overall, the proposals represent a highly sustainable option growth option that can deliver a range of substantial benefits. Wider South Coventry Masterplan 6.15 In April 2022 a report was taken to WDC Cabinet seeking approval to enable the formation of a master planning framework for land to the north and east of Kenilworth/South Coventry. A copy of the framework area is included at Appendix 2. 6.16 The Cabinet approved the recommendation of the report resulting in the formation of a working group which includes WDC, Coventry City Council, Warwickshire County Council and the University. The purpose of the working group and the masterplan (as per the Cabinet Report) is to: • To map and understand the various planned and emerging developments in the area; • To explore how to maximise community benefits including through improvements to green and blue infrastructure and connectivity; • To assist partner organisations in preparing their own masterplans for specific sites and to reflect their aspirations in the wider planning of the area ; • To understand how the climate emergencies declared by Warwick District Council, Warwickshire County Council, the West Midlands Combined Authority and the University of Warwick should inform the future planning of this area ; • To provide a focus for considering how best to engage with HS2 in terms of how this project can bring improvements to the area (including by linking with the HS2 Context Integration Study); • To provide a context for considering travel and transport improvements in the area, which should prioritise active and sustainable travel but also consider the purpose, justification and business case for the A46 Strategic Link Road; • To provide a framework and rationale for future business cases and bids to deliver transport infrastructure projects (e.g. road, VLR, South of Coventry/University of Warwick Railway Station); and • To enable, subject to wider work on growth options across South Warwickshire and any agreement within the South Warwickshire Local Plan as to the development strategy, consideration of whether, where and how this area may be suitable for further growth as part of the Local Plan. 6.17 The site is located within the framework area and as well as being capable of coming forward in isolation, could also form part of a wider growth area to the South of Coventry. The site can assist with delivering the aspirations for the masterplan area including: • Supporting the delivery of new homes and employment opportunities, should the SWLP consider this an appropriate area for growth; • Supporting the enhancement and further delivery of green and blue infrastructure; • Ensuring that the series of existing and emerging development sites are well designed and well connected in order to provide a coherent and cohesive masterplan for the area; • Contribute to low carbon and climate resilient development. • Connect new homes and key existing employment hubs such as the University and land around Coventry Airport promoting sustainable neighbourhoods and travel patterns in order to assist Councils drive towards net zero aspirations; and • Assist in the delivery and support of new strategic transport infrastructure such as Very Light rail; green travel corridors (A46 link road); cycle and footpaths; and Coventry/University of Warwick Railway Station 6.18 CEG understand that the working group have begun work on understanding the potential of the masterplan area and would welcome the opportunity to collaborate with the group in the near future.
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Issue H1: Providing the right number of new homes: I do not have any faith in the methodology used to produce the claim that Coventry and Warwickshire will need 1,600 homes built every year until 2050.
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If you have any further comments, please write them here.: Just building new houses is an answer but not the best one. There needs to be much more thinking about the impact, and reuse of areas we have rather than the default let's just build on another field.
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Q-H1-1:The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014-based household projections towards a trend-based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? Yes (for South Warwickshire) The NPPF (paragraph 61) identifies that in order to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method, unless exceptional circumstances justify the use of an alternative approach. Such an alternative approach should reflect current and future demographic trends. It is acknowledged that the ONS has highlighted that the 2014-based household projections gave rise to inconsistencies with the resultant housing need figure for Coventry. The South Warwickshire Councils are in a Housing Market Area (HMA) with Coventry. In this context this current Local Plan review process provides an opportunity to consider what the need for Stratford on Avon and Warwick District Councils might be if more up to date household formation figures are taken into account within the HMA. It is understood that the HEDNA approach seeks to achieve this. Whilst the output from the HEDNA results in a slight lowering of the overall HMA need on a dwelling per annum basis, it is noted that the trend-based figures identified for Warwick and Stratford-on Avon Districts represent an increase over and above the standard method based equivalents. This is influenced by the high levels of net migration projected for these Districts within the HEDNA. It is accordingly considered to be a sensible and robust approach for the SWLP to be planning for, and identifying allocations to meet, this higher figure in order to ensure that there is a sufficient supply of homes coming forward in this area, as a minimum. Due regard should also be given through the Local Plan process to the opportunity to increase provision against this figure to both ensure that there is a sufficient supply and variety of housing sites to enable the Government’s aim of significantly boosting the supply of housing (NPPF paragraph 60) to be met, but to also ensure that the issue of housing affordability within this area is also appropriately addressed. It should also be recognised that the unmet need arising from Coventry will not be crystallised until further evidence base reporting is published by Coventry City Council on the capacity of land within its administrative boundaries. There may therefore be a need for the SWLP to allocate additional land to assist with meeting any unmet need for Coventry, with appropriate regard given to the opportunity provided by land on the edge of existing large sustainable settlements in the SWLP boundary to assist with achieving this.
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Q-H2-2: Option H2-2B: Separate affordable housing requirements for Stratford-on-Avon and Warwick Districts Separate affordable housing requirements for each District are likely to go most of the way towards reflecting local requirements and local viability calculations. Some large scale zoning might be appropriate within each Council’s area.
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Q-H3: Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. It should be noted that across South Warwickshire there is a strong demand for new homes and these sell, despite the adopted Local Plan provisions in force not including policy requirements which bring in these additional Technical Standards. There is therefore not considered to be a need to introduce such standards in order to deliver homes that meet market demand. NPPF footnote 49 states that policies may also make use of the nationally described space standard (NDSS), where the need for an internal space standard can be justified. In relation to the NDSS the PPG4 identifies that LPAs need to take account of need, viability and timing. In relation to the M4(2) and M4(3) standards, the PPG5 states that there is a need for LPAs to give regard to: the likely future need for housing for older and disabled people (including wheelchair user dwellings); size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes); the accessibility and adaptability of existing housing stock; how needs vary across different housing tenures; and the overall impact on viability. 4 Planning practice Guidance Paragraph: 020 Reference ID: 56-020-20150327. 5 Planning practice Guidance Paragraph:007 Reference ID: 56-007-20150327.
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Q-H5: Option H5c is appropriate for meeting any requirement arising during the Local Plan period. The requirement for custom and self-build housing plots need to be determined on a case by case basis. The very nature of self and custom build housing means that it is difficult to plan for precise locations of delivery. Such requirements should be based on local evidence such as the self and custom build register and local eligibility test6. 6 National Planning Policy Framework: Paragraph 125.
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There will be a need to review the position relating to the delivery of homes in South Warwickshire when more evidence is made available to inform the needs and strategy for this area.
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Lapworth Parish Council do not have the expertise to comment on how to best increase the availability of Gypsy. Traveller and Travelling Show People accommodation.
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Q-H1-1 Lapworth Parish Council does not have the expertise to comment on the HEDNA methodology, but it seems sensible to use the most up to date and accurate figures to assess need. We would reiterate that we do not believe it is sensible to use a single strategy based on rail to identify future housing location as this is inflexible and likely to be superseded as a sustainable option by innovative EV/hydrogen technologies in the near future. We would also reiterate that brown field locations regardless of their sustainable access status should be a priority for development over green field sites.
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Q-H1-1 The NPPF is clear that: “Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas” (Para 11b). It also states that: “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance…” (Para 61). In this context, it is noted that the 2021 Scoping Consultation set out the housing need context for the SWLP, highlighting that the SWLP housing requirement is underpinned by the Local Housing Need [LHN] figure generated by the Standard Method. For the SWLP area, on the whole, the Scoping Consultation stated that the SWLP will need to deliver a minimum of 1,230 new homes each year, or c.35,000 dwellings over the 30-year plan period. St Philips considers that the Council’s proposed strategy is acceptable in principle and that the deviation from the Standard Method is enabled by the NPPF and PPG. As acknowledged above, NPPF paragraph 61 states that the local housing need figure determines the minimum number of homes needed. Therefore, an uplift can be applied when supported by evidence. As acknowledged within the Issues and Options document, subsequent to the release of the 2014-based projection, based on more up-to-date assumptions about fertility, mortality and household formation rates, the Housing and Economic Development Needs Assessment [HEDNA] applied alternative projections through the framework provided by the standard method. St Philips considers this deviation to be acceptable in principle. Based off of the trend based projections as presented within the HEDNA, the overall housing need within South Warwickshire has increased when compared to the 2014-based projection from 1,239 dwellings per annum [dpa] to 1,679 dpa. In this instance, South Warwickshire will have to provide a greater supply of deliverable sites in order to meet this greater housing need. St Philips considers that the identification of a variety of suitable sites would accord with paragraph 60 of the NPPF which clearly states that: “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.” As stated above, the use of the HEDNA and the Council’s deviation from the Standard Method is acceptable in principle. As recognised by the Issues and Options Consultation, the standard method framework is the starting point for assessing the housing need. Both the NPPF3 and PPG4 are clear that the LHN figure generated by the standard method is a minimum starting point (i.e. actual housing need may be higher than this figure). Moreover, elsewhere in the guidance, the PPG differentiates between the minimum figure arrived at through the standard method and ‘actual’ housing need which can be higher. Although the HEDNA deviates from the LHN, it is highly likely that an additional uplift will be required as discussed within the response to question H4 below. It is ‘actual’ housing need that represents the objectively assessed need to which the tests in paragraph 11 of the NPPF apply, and there is also a requirement for the Council to test reasonable alternatives5 . Therefore, the Council should actively identify whether there are reasons for testing higher figures as estimates of housing need. Fundamentally, this is because the standard method does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour, nor considers local factors, policy and aspiration which might legitimately mean the Council should seek to plan for more homes than the minimum. The PPG goes on to state that it would be appropriate for a higher figure to be adopted on the basis of employment, infrastructure, affordable housing or unmet housing needs. In this regard, St Philips recommends that the SWLP should seek to deliver a greater number of dwellings over and above the housing need figure set out by the HEDNA. As discussed below, the substantial level of demand for affordable housing within South Warwickshire justifies an uplift to the objectively assessed need figure identified within the HEDNA in order to address the worsening affordability within the area. In the context of affordable housing, whilst the Standard Method includes an adjustment to take account of the median affordability ratio, the PPG7is clear that an increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes. In addition to addressing the affordable housing requirement within South Warwickshire, the scale of the unmet housing needs emerging from within the C&WHMA and GBBCHMA (c.78,000 dwellings) are likely to require an uplift to the housing need figure for South Warwickshire as identified by the HEDNA. The requirement to accommodate these needs is set out below within the response to question H4. Q-H3: The Issues and Options document states that the Council has acknowledged, through public engagement, the request for minimum internal space standards to be applied through a local plan policy. In addition, St Philips notes that it was agreed in response to a Notice of Motion to Council in Warwick District, that the principle of incorporating Nationally Described Space Standards within the SWLP would be considered (see Cabinet meeting for 29 September 2022, Item 09). It is stated within the Issues and Options document that this would be considered as part of the Local Plan Review process. St Philips recognises the importance of including design-based policies within the Local Plan Review in order to enhance the existing character of the District and provide a good quality of life for current and future residents. It is important to note Footnote 49 of NPPF paragraph 130(f), which states that policies may “make use of the nationally described space standard, where the need for an internal space standard can be justified.” Furthermore, NPPF paragraph 31 states that all policies should be “underpinned by relevant and up-to-date evidence”. In addition, the PPG[1] sets out: “Where a need for internal space standards is identified, the authority should provide justification for requiring internal space policies. Local planning authorities should take account of need, viability and timing” In consideration of the above, St Philips advises South Warwickshire that, should a policy approach that requires the delivery of dwellings to the NDSS be adopted, the Council should provide a local assessment evidencing the case for the District in accordance with the NPPF and PPG. Therefore, it is recommended that the Council should complete further evidence gathering prior to including a policy. Additionally, it is important to note that any policy requirement would also need to be considered and tested through a viability assessment before adoption. This would ensure that the approach is supported and justified by up to date evidence and that the approach can be found to be legally compliant with both the NPPF and the PPG. Q-H4-1: The SOADC SAP identifies reserve housing sites and the mechanisms for their release, should they be required. Policy SAP. 1 sets out four purposes for identifying reserve sites, with purpose (d) being: “To contribute to meeting any housing needs arising outside the Coventry and Warwickshire HMA that is accepted through co-operation between the relevant councils as needing to be met within the HMA and most appropriately being met within the District.” Policy SAP.1 goes on to establish that reserve housing sites will be released in accordance with the mechanisms set out in Policy SAP.3 (Releasing Reserve Housing Sites). St Philips support the Council’s approach to purpose (d), which when read with the proposed Policy SAP.4 (Releasing Reserve Housing Sites for Purpose D), would release sites with immediate effect to help address unmet housing needs in the Birmingham HMA. In this context, Policy SAP.4 identifies the following sites to be released to help meet the unmet need of the GBBCHMA: • STR.A – North of Evesham Road, Stratford-upon-Avon; • STR.B – East of Shipston Road, Stratford-upon-Avon; • STR.C – South of Alcester Road, Stratford-upon-Avon; • MAPP.A – West of Birmingham Road (south), Mappleborough Green; • STR.D – East of Banbury Road, Stratford-upon-Avon. In total, these sites have the capacity to deliver approximately 530 homes. Whilst it is welcome that these sites would be released immediately, St Philips considers that the proposed allocations do not sufficiently reflect the scale of the unmet need within the Greater Birmingham and Black Country Housing Market Area [GBBCHMA]. In this regard, the SAP Preferred Options asserts that “the housing shortfall in the Greater Birmingham & Black Country Housing Market Area (GBBCHMA) that cannot be met within its boundaries is identified as being 6,302 homes up to 2031” (paragraph 2.4.1). However, there are several shortcomings with this position as set out elsewhere by Lichfields in its blog9 “All the West-laid Plans: The unmet housing needs of the Greater Birmingham and Black Country Housing Market Area”. Lichfields’ critique suggests that whilst Birmingham’s unmet housing need has probably reduced from the original 37,900 in 2017, there remains a likely – and at present, unaccounted – shortfall of between c.11,479-15,479 dwellings up to 2031. This is because several of the ‘banked’ housing contributions from other HMA districts are earmarked to help meet the Black Country’s needs. In this context, St Philips consider that the proposed allocations within the SAP do not sufficiently address the scale of the shortfall arising within the GBBCHMA. St Philips is also concerned that the approach taken by SOADC unduly restricts the release of Green Belt sites. In this context, St Philips welcomes that the IO has taken a ‘blind’ approach towards whether potential sites are within the Green Belt. St Philips supports this approach as it ensures that the SWAs do not limit the release of sites for residential purposes that would otherwise be sustainable and suitable.
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Question H1.1: 3.25 IM generally support the proposed trend-based approach using the 2021 census data, which has resulted in an increase of 440 homes per year in comparison with the 2014-based projections. 3.26 It will be important that the CWHMA authorities provide the adequate evidence and justification to support deviating from the current, and potentially future, standard method for calculating local housing need.
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Question H3a: Do not seek to include minimum space standards in a policy in the SWLP. 3.29 Space standards are not a strategic matter and should therefore be dealt with in any Part 2 Plan. As set out in Paragraph 002 of the NPPG Chapter ‘Housing: optional technical standards’, any proposed space standards will need to be sufficiently evidenced, to justify a local need for exceeding the minimum standards required by Building Regulations and an optional nationally described space standard.
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Question H5: 3.37 There are significant difficulties associated with setting a standard proportion of self and custom-build homes for all large-scale sites, due to the scale of housing development that is often required, and the diversity of housing needs and demographics between different local areas. IM considers that this approach would be more appropriate to smaller scales sites and could therefore be dealt with through the Part 2 Plans or neighbourhood planning.
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Question H1.1: 3.41 Taylor Wimpey generally supports the proposed trend-based approach using the 2021 census data, which has resulted in an increase of 440 homes per year in comparison with the 2014-based projections. 3.42 It will be important that the CWHMA authorities provide the adequate evidence and justification to support deviating from the current, and potentially future, standard method for calculating local housing need.
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Question H2.2: 3.46 Whilst a single affordable housing policy for the SWLP should be considered as the most straightforward and universal approach, as set out at Option H2-2a, any policy requirement must allow for suitable viability testing on a site-by-site basis.
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Question H3: Option H3a: 3.47 Space standards are not a strategic matter and should therefore be dealt with in any Part 2 Plan. As set out in Paragraph 002 of the NPPG Chapter ‘Housing: optional technical standards’, any proposed space standards will need to be sufficiently evidenced, to justify a local need for exceeding the minimum standards required by Building Regulations and an optional nationally described space standard.
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Question H5: 3.55 Setting a requirement or standards for all large-scale sites to deliver an element of custom built homes can cause significant difficulties. Alternatively, custom build plots would be more appropriate to specific smaller scale sites, which can be included in the SWLP Part 2 or as part of neighbourhood planning.