Q-H6: Please select all options which are appropriate for South Warwickshire
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Q-H1-1: In line with the NPPF the housing need for South Warwickshire will need to reflect current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for. The Council will need to demonstrate that the approach to determining housing needs is consistent with the NPPF. We consider that even with a lower housing need figure it will be impossible for the Plan to meet housing needs without significant greenfield development.
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Consideration must be given to the excessive amount of homes already built in south warwickshire, particularly the existing infrastructure, which were never designed to cope with large volumes of traffic, and lack of public transport links to these developments.
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Q-H3 - Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. 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. 2.54 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. 2.55 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”. 2.56 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” 2.57 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: 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 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.” 2.59 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. 2.60 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 blog “All the West-laid Plans: The unmet housing needs of the Greater Birmingham and Black Country Housing Market Area”. 2.61 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. 2.62 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 thisapproach 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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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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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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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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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? Y/N/DK 2.46. Yes. Overall, the Respondent considers that the HEDNA provides a reasonable basis for identifying future levels of housing need across South Warwickshire. However, it should be noted that the level of future housing need stated in the HEDNA is a floor figure and does not include any unmet housing needs that may arise from other local authorities, which still needs to be established under the duty to cooperate. 2.47. In setting a housing requirement for the plan area it is suggested that the Councils look to allocate significantly more sites than may be required to meet the minimum housing need identified in the HEDNA to increase the supply of affordable housing and attempt to address the issue of affordability in both districts (discussed further under Question Q-H2-1 below). This could be reasonably achieved through the application of a reasonable buffer on top of the minimum housing need identified, which the Urban Capacity Study would also appear to recommend.
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Q-H2-2: Please select the option which is most appropriate for South Warwickshire: Option H2-2a: A single South Warwickshire wide affordable housing requirement 2.51. The Respondent considers that a consistent approach with regards to affordable housing should be applied across both Districts. Accordingly, of the options presented, Option H2-2a is probably the most appropriate in that it would appear to give the greatest certainty to developers and avoid making some areas more attractive than others. However, whatever the option that is settled upon it is imperative that the approach is thoroughly tested in terms of its viability and is appropriately justified.
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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. 2.52. The Respondent agrees that should the Councils wish to impose minimum space standards that they should be adopted as development plan policy. 2.53. The Councils’ aspiration to raise the standard of design of new homes in South Warwickshire is understood. However, given the notable unaffordability issues within the Warwick and Stratford Districts where house prices are around 25% higher than the rest of the HMA, the Respondent has significant reservations regarding the imposition of space standards. Specifically, the respondent is concerned about the implication that such standards could have on the viability of sites, as well as the affordability of new homes given that properties are generally valued and sold on a £ for square ft basis. 2.54. Should the Council wish to introduce the application of Nationally Described Space Standards (NDSS) or optional Building Regulations M4(2)/M4(3) then Footnote 49 of the NPPF makes clear that the need for such standards needs to be justified. Further work will therefore need to be undertaken to demonstrate an appropriate justification. 2.55. For the avoidance of doubt the Respondent would strongly object to the imposition of space standards beyond NDSS.
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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-on-Avon District? Y/N/DK 2.56. Yes broadly. The Respondent agrees that there is a strong argument that the homes needed to contribute to the Birmingham and Black Country HMA shortfall to 2031 should be located close to the source of those needs. However, the Respondent considers that locations that are proximate in terms of sustainable transport connections, and particularly rail services, which benefit from a reasonable commute to sources of need should also not be ruled out.
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Q-H5: Please select all options which are appropriate for South Warwickshire Option H5c: Rely on a case-by-case approach whereby planning applications for self and custom build homes will be assessed against a range of criteria to determine their suitability. 2.61. The Respondent has experience of providing self-build plots on developments in other parts of the Country and would caution that there is often a disparity between the number of people that register an interest in such plots and those that will make a firm commitment and complete a purchase. 2.62. As the Consultation Document points out, there are people who may express an interest for a self-build property but do not want to live within or on the edge of a new housing estate. In a largely rural authority, it is considered likely that the demand for self/custom build is for single plots on the edge of small villages/hamlets or on plots within the open countryside. A case-by-case approach as per that suggested under Option H5c would therefore seem most appropriate in South Warwickshire or for specific sites on the edge of existing settlements to be allocated specifically for this purpose where there is identified demand (Option H5a). 2.63. If Option 5b is to be taken forward, then there must be the flexibility to revert self-build plots back to normal build plots once they have been marketed for an appropriate amount of time. The period of marketing required to demonstrate a lack of demand should not prevent the main developer from completing the self-build plots before the construction programme finishes, since it would not be desirable for developers to be left with vacant plots or for new residents to be subjected to construction activities for a prolonged period.
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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? We confirm that the HEDNA evidence provides a reasonable basis for identifying future level levels of housing need. On this basis there is a need for 811 dwellings per annum across Warwick.
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Issue H3. Sizes of homes. In an ‘ideal’ world, people might choose the size of their home to fit their ‘requirements’, but that is not how the market works. People buy homes which suit their aspirations, both now and in the future. They judge whether to have a family, to accommodate visitors and guests or how many rooms they need to enable them to work from home. Their decisions are governed by choice, location, surroundings, environment and affordability. Any suggestion that market housing should be controlled by size would be fundamentally flawed. For the affordable sector, it is widely assumed that ‘square pegs ought to fit square holes’ and so a closer match is expected. Any guidance on this issue can only be advisory. More active policies to incentivise elderly people to down-size may be more worthwhile – but again, moving in one’s later years is often disruptive and so may not necessarily be feasible. A better policy approach would be to encourage builders to provide elderly persons accommodation and provide offices and spare rooms within new housing to promote home working which would in turn reduce the need for additional affordable housing and propensity to travel. Issue H5. Providing Self-build and custom-build plots: The Government has set a duty within the Self-build and Custom-building Act for authorities to deliver self-build/custom build plots. Stratford on Avon (although not having a self-build policy in their Core Strategy) has taken a pro-active approach by allocating specific small sites within their Site Allocations Plan. Other authorities have taken a less pro-active approach and have adopted a quota-based approach by seeking self-build plots as a proportion of larger sites. This is the opposite of what both self-builders or builders want, in view of their polarised objectives. I would recommend that the Councils allocate smallish sites and supplement this with informal self-build plots in smaller settlements. This conforms to Options H5a and H5c. We would not favour H5b.
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Q-H2-2. Please select the option which is most appropriate for South Warwickshire: Option H2-2c. This is an important consideration for the Cotswolds National Landscape, which is a designated Area of Outstanding Natural Beauty (AONB). Paragraph 176 of the National Planning Policy Framework (NPPF) states that the scale and extent of development in AONBs (and National Parks) should be limited. As such, these protected landscapes are not suitable locations for unrestricted housing. Instead, ‘the expectation is that new housing will be focussed on meeting affordable housing requirements’18 (and supporting local employment opportunities and key services). The term ‘affordable housing’ covers various types of housing, some of which are intended to be affordable in the longer term and some of which are not. A key priority in the protected landscapes is to ‘ensure that affordable housing remains so in the longer term’.19 Paragraph 64 of the NPPF allows for on-site provision of affordable housing on sites of 5 units or fewer in designated rural areas, including in AONBs. The Government-commissioned Landscapes Review recommends that ‘local planning authorities in AONBs should also make use of the provision that allows them to demand on-site affordable housing contributions on all sites [in AONBs], including developments of five homes or fewer’.20 Based on the above points – and based on best practice within protected landscapes21 - we would like to make the following recommendations with regards to (affordable) housing development in the Cotswolds National Landscape: . Housing provision in the Cotswolds National Landscape should be focussed on – and prioritise – meeting affordable housing requirements. . Within the context of Government requirements and locally identified needs, priority (in the Cotswolds National Landscape) should be given to the provision of housing that is affordable in perpetuity, including social rented housing. . The South Warwickshire Local Plan should require: o At least 50% affordable housing in market housing developments within the Cotswolds National Landscape. o 100% affordable housing on Rural Exception Sites (at least within the Cotswolds National Landscape), with a lower percentage only being permitted in exceptional circumstances and the absolute minimum being 75%; o On-site affordable housing provision for housing developments of five units or fewer (ideally, on developments of two or more units). Further guidance on this topic is provided in the Board’s Housing Position Statement.22 18 Defra (2010) English National Parks and the Broads – UK Government Vision and Circular 2010 Paragraph 79. AONBs are afforded the same level of protection as National Parks in national planning policy and are subject to the same requirement for the scale and extent of development to be limited. As such, the same principles that are set out in Circular 2010, in this regard, should also apply to AONBs. 19 Defra (2010) English National Parks and the Broads – UK Government Vision and Circular 2010. Paragraph 79. 20 Defra (2019) Landscapes Review Final Report. Proposal 18: A new National Landscapes Housing Association to build affordable homes. 21 Cotswolds National Landscape Board (2021) Housing Position Statement). Appendix 2 – Case Studies. 22 Cotswolds National Landscape Board (2021) Housing Position Statement
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The accompanying HEDNA proposes a shift away from a future household needs approach based on the 2014 household projections, towards a trend-based approach. It is recognised that following the release of the 2021 census data that the 2014 projection based forecasts are increasingly dated, but they remain Government’s preferred basis for assessing local housing needs. Further, it is evident from initial comparisons of the projections that the Coventry numbers are far lower than those under the 2014 projections. However, given that it is unclear at this stage where the expected uptick in population has gone (i.e. whether it has simply dispersed across the sub region or resulted in a net outflow of population) we therefore have reservations about whether the HEDNA approach is correct. It will be important to continue to deliver a range of homes and the emerging SWLP will need to take account of planning reforms which are set to be announced in Spring 2023.
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NB re: Questions H2a/b, a hybrid approach to affordable housing is required. There should be an absolute level, below which no development should take place. This would prevent developers seeking to negotiate affordable housing down to unacceptable levels. This should sit alongside an approach that recognises differences across sites and geographical areas.
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Q-H1-1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? We confirm that the HEDNA evidence base provides a reasonable basis for identifying future levels of housing need. The draft Plan notes that, based on the Standard Housing Method, 5,554 new dwellings per annum will be needed across Coventry and Warwickshire to 2050, a proportion of which will be provided by the South Warwickshire authorities. We note that it is expected that Stratford-on-Avon and Warwick Districts are likely to see higher levels of growth over the Plan period than other authorities within the Housing Market Area.
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Issue H1: Providing the right number of new homes. Q-H1-1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? We confirm that the HEDNA evidence base provides a reasonable basis for identifying future levels of housing need. The draft Plan notes that, based on the Standard Housing Method, 5,554 new dwellings per annum will be needed across Coventry and Warwickshire to 2050, a proportion of which will be provided by the South Warwickshire authorities. We note that it is expected that Stratford-on-Avon and Warwick Districts are likely to see higher levels of growth over the Plan period than other authorities within the Housing Market Area.
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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? We confirm that the HEDNA evidence provides a reasonable basis for identifying future level levels of housing need. On this basis there is a need for 811 dwellings per annum across Warwick.
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Issue H1: Providing the right number of new homes. Q-H1-1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? We confirm that the HEDNA evidence base provides a reasonable basis for identifying future levels of housing need. The draft Plan notes that, based on the Standard Housing Method, 5,554 new dwellings per annum will be needed across Coventry and Warwickshire to 2050, a proportion of which will be provided by the South Warwickshire authorities. We note that it is expected that Stratford-on-Avon and Warwick Districts are likely to see higher levels of growth over the Plan period than other authorities within the Housing Market Area.
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QH1-1: 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 trendbased approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire Paragraph 11 of the NPPF requires that strategic policies should as a minimum provide for the objectively assessed need for housing as well as any needs that cannot be met in neighbouring areas. Paragraph 60 sets out the Government’s objective of “significantly boosting” the supply of homes and paragraph 61 provides additional guidance identifying that strategic policies should be informed by the minimum local housing need identified by the standard method as well as any unmet needs from neighbouring areas. The Planning Practice Guidance (PPG) (para 2a-002) again confirms that the standard method provides only the minimum number of homes expected to be delivered but it does allow authorities to diverge from the Standard Method where this can be justified by exceptional circumstances: where such an alternative reflects current and future demographic trends including migration and market signals. The HEDNA supporting the Issues and Options Consultation has assessed matters of housing need and requirements in great detail across the Coventry and Warwickshire Hosing Market Area in which ‘South Warwickshire’ is located. In coming to the recommendations on proposed housing need (dwellings per annum) across the Housing Market Area the report appears to have followed the relevant Government guidance in demonstrating exceptional circumstances supporting a trend-based approach to housing need for the Joint Plan area. The modelling of new demographic projects which take account of Census data releases and specific matters relating to the population in Coventry in particular, as part of the housing market area, but also including an assessment of Age Structures across the Housing Market Area (HMA), migration and demographic interactions is supported in principle. The trend based figures, which equate to an overall housing need across the Joint Plan area of 1,679 dwellings per annum is supported in principle. The HEDNA also identifies that Warwick has the highest levels of migration of population from Coventry, and that Stratford-on-Avon forms part of the Greater Birmingham Housing Market Area and the authorities should respectively consider planning for unmet need from Coventry and the Greater Birmingham HMA respectively. Whilst the number of homes which may be required in Coventry is likely to reduce based on the overall need being lower in the HEDNA than the 2014 sub-regional based household projections, the unmet need in the Greater Birmingham and Black Country HMA in particular is well evidenced. The GBBCHMA Housing Need and Housing Land Supply Position Statement (July 2020) identifies the housing shortfall of the GBBCHMA as 67,160 dwellings. The now revoked Draft Black Country Plan 2018-2039 showed a shortfall of circa 28,000 homes in the Black Country alone. Birmingham City Council have recently suggested a potential shortfall of over 78,000 dwellings. Further, the ‘Mind the Gap’ Barton Willmore Paper dated March 2021 and ‘Falling Short – Taking Stock of Unmet Needs across GB&BCHMA’ paper by Turley in August 2021, both commissioned by HBF Members concluded that the significant unmet needs in the GBBCHMA exist now, and will continue to exist in the future. The Black Country shortfall identified is considered to remain relevant to the Plan-making process and the recent letter from the Inspectors examining the Shropshire Local Plan confirms that the scale of need and unmet need remains relevant to Plan-making. Para 14 of that letter (see Appendix C) concluded that "Despite this new plan making context, there is no reason before us to find that the identified unmet needs in the Black Country area will disappear." It is important that these shortfall figures do not take into consideration the 35% uplift applied to Birmingham introduced in December 2020 as the adopted Birmingham Development Plan. The Black Country housing shortfall also does not consider the 35% uplift applied to Wolverhampton City Council in May 2021. Such considerations should also feed into the proposed housing targets that are set in the South Warwickshire Plan going forward and this could increase the requirement even further. NPPF REF
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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified.” Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: “Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.” If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H5: Please select all options which are appropriate for South Warwickshire As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016- 20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. I&O. The HEDNA evidence and Self-Build Register for both authorities should form part of the evidence base that informs any emerging policies that deal the delivery of selfbuild/custom plots on applications for residential development. If the Plan is going to require a % of self-build plots this must only be limited based on the current evidence available. Further, if there is a policy requiring self/custom build on major sites then it is nevertheless submitted that it should include a mechanism to allow for such plots to come forward for market housing if demand is subsequently found to be absent. For example, if serviced plots for self-build and custom housebuilding have been made available and marketed for a set period of time and have not sold, plots can be used for delivery of general market housing.
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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? We confirm that the HEDNA evidence provides a reasonable basis for identifying future level levels of housing need. On this basis the across the Stratford-on –Avon district 868 dwellings per annum will be required.
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Issue H1: Providing the right number of new homes. Q-H1-1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? We confirm that the HEDNA evidence base provides a reasonable basis for identifying future levels of housing need. The draft Plan notes that, based on the Standard Housing Method, 5,554 new dwellings per annum will be needed across Coventry and Warwickshire to 2050, a proportion of which will be provided by the South Warwickshire authorities. We note that it is expected that Stratford-on-Avon and Warwick Districts are likely to see higher levels of growth over the Plan period than other authorities within the Housing Market Area. Q H2-2 asks whether affordable housing should be considered across the Plan area, separately in each District, or should offer a more localised approach. We would propose that Option H2 – 2b is most appropriate, setting separate affordable housing requirements for Warwick and for Stratford upon Avon Districts. We note that the requirement for affordable housing in Warwick District is significantly higher than in Stratford-on-Avon District, and therefore it would be more appropriate to set different requirements, and to provide certainty at the District level.
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Housing Market Area My view is that the allocation of overspill demand from West Midlands is unfairly weighted for South Warwickshire. After the acceleration of changes in working patterns due to the pandemic, the long term future for flexible working is uncertain. People need to be able to commute to their workplaces in reasonable time. Many proposed areas of South Warwickshire are unsustainable on this measure. It is my opinion that the pre existing methodology for contribution to the Birmingham and Black Country housing shortfall is no longer valid.
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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 would go some way towards reflecting local requirements and local viability calculations. It would provide a reasonable level of certainty for developers and Councils. However, the District boundaries are unlikely to be the most accurate way of reflecting of variations in value, or variations in affordable housing demand, in different areas of South Warwickshire.
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Q-H2-2: Option 2 c We don’t see why this option necessarily create doubts in developers minds. But are there material differences in demand for affordable housing – if not a single policy is best. Q-H3: In high price rural areas, such as Tanworth, the lack of small market homes is a particular issue. Existing polices do not deal with this and when we attempted to tackle the issue in the Tanworth NDP we were knocked back by the District Council. You do not ask a question on this issue which suggests you have no ideas. Q-H5: Option H5a: We have experience of planning applicants in the Tanworth area of attempting to get around Green Belt restrictions by claiming a demand for self build. If you really think there is a demand for self build that cannot be met by any of the windfall sites then specifically identify a few sites Option H5c would be open to abuse.
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Q-H2-2a We consider that with a single plan for South Warwickshire, combined as a unified policy area, there should be a single South Warwickshire wide affordable housing requirement – both in terms of threshold and percentage requirement. Q-H3a. We would support option H3a – which does not seek to include minimum space standards in a policy. We would agree that this is not of strategic importance across South Warwickshire and so could be considered in Part 2 of the plan, and assessed against evidence provided that it is a requirement within the District that would not impact of the affordability of properties. Q-H5a and c The Self-build and Custom Housebuilding Act 2015 (as amended) places duty on Councils to keep a register of individuals and associations of individuals and associations of individuals who wish to acquire serviced plots of land to bring forward self-build and custom housebuilding projects. They are also required to have regard to this register and grant enough development permissions to serviced plots of land to meet the identified demand, where the demand is dictated by the number of entries on the Council’s Self-build register within each base period. The Planning Policy Guidance (PPG) states that self-build or custom builds helps to diversify the housing market and increase consumer choice. In such types of projects, the initial homeowners choose the design and layout of their home, allowing for innovative creativity. On this basis, we consider that the Council should give proper consideration to the identification of a range of specific sites on the edge of existing settlements to be developed for self and custom build homes. This is preferable to requiring large developments (over 100 dwellings) to provide a proportion within the overall site. This would not be appealing to most national house builders and difficult to implement in policy terms. Wyre Forest’s recently adopted Local Plan (SP12) includes a specific policy requiring major development schemes of 50 or more dwellings to “take into consideration the demand shown in the Self-Build and Custom- Build register and where possible provide suitable plots.” Where plots are made available and marketed for at least 12 months, and there is no demand – they may be built out by the developer.
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Q-H2-2a We consider that with a single plan for South Warwickshire, combined as a unified policy area, there should be a single South Warwickshire wide affordable housing requirement – both in terms of threshold and percentage requirement. Issue H3: Providing the right size of homes Q-H3a. We would support option H3a – which does not seek to include minimum space standards in a policy. We would agree that this is not of strategic importance across South Warwickshire and so could be considered in Part 2 of the plan, and assessed against evidence provided that it is a requirement within the District that would not impact of the affordability of properties. Issue H5: Providing custom and self-build plots Q-H5a and c The Self-build and Custom Housebuilding Act 2015 (as amended) places duty on Councils to keep a register of individuals and associations of individuals and associations of individuals who wish to acquire serviced plots of land to bring forward self-build and custom housebuilding projects. They are also required to have regard to this register and grant enough development permissions to serviced plots of land to meet the identified demand, where the demand is dictated by the number of entries on the Council’s Self-build register within each base period. The Planning Policy Guidance (PPG) states that self-build or custom builds helps to diversify the housing market and increase consumer choice. In such types of projects, the initial homeowners choose the design and layout of their home, allowing for innovative creativity. On this basis, we consider that the Council should give proper consideration to the identification of a range of specific sites on the edge of existing settlements to be developed for self and custom build homes. This is preferable to requiring large developments (over 100 dwellings) to provide a proportion within the overall site. This would not be appealing to most national house builders and difficult to implement in policy terms. Wyre Forest’s recently adopted Local Plan (SP12) includes a specific policy requiring major development schemes of 50 or more dwellings to “take into consideration the demand shown in the Self-Build and Custom- Build register and where possible provide suitable plots.” Where plots are made available and marketed for at least 12 months, and there is no demand – they may be built out by the developer.