Q-H6: Please select all options which are appropriate for South Warwickshire

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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? 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 approach followed through the HEDNA 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 South Warwickshire Local Plan 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 South Warwickshire Local Plan 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 southern edge of Coventry (south of Westwood Heath Road) to assist with achieving this. Q-H2-2: Please select the option which is most appropriate for South Warwickshire: Crest Nicholson considers that the market dynamics and demand within the South Warwickshire area should be taken into consideration when setting the affordable housing approach. This should give regard to the data included within the HEDNA, as well as the scenario testing and analysis undertaken through the viability assessment work when this is undertaken. This may highlight that particular areas, sizes of site or types of site should be assigned a lower affordable housing figure or may show that a Local Plan wide area based approach works or that a LPA area based approach works. There is not considered to be sufficient information available in the public domain at present to be able to provide a firm answer to this question. Further evidence needs to be made available, notably with respect to viability. Q-H3: Please select all options which are appropriate for South Warwickshire It should be noted that across South Warwickshire there is a strong demand for new homes and these sell, despite the adopted Local Plan 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. It would be for the South Warwickshire Councils to demonstrate through an appropriate evidence base that the imposition of additional Technical Standards. 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 PPG (Paragraph: 020 Reference ID: 56-020-20150327) identifies that LPAs need to take account of need, viability and timing. In relation to the M4(2) and M4(3) standards the PPG (Paragraph: 007 Reference ID: 56-007-20150327) 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. This evidence base has not been made available to provide clear justification to support the inclusion of these additional technical standards alongside the Issues and Options consultation. Therefore as it stands Option H3d would represent the current position. Q-H5: Please select all options which are appropriate for South Warwickshire Crest Nicholson considers that Option H5c is appropriate for meeting any identified 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 test (See PPG Reference: Paragraph: 025 Reference ID: 57-025-20210508). Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire No further comment at this stage. 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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Q-H2.2 In order to ensure that the affordable housing policy meets the requirements of each local authority and settlement, we would suggest option HS-2c which would enable a tailored approach lead by demand within each specific area.

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I am writing in relation to the South Warwickshire Development Plans as a resident of Henley in Arden. Whilst I am reasonable and understand more homes need to be built. I am concerned by the numbers 500 to 2000 new homes. Even 500 homes in this small town does not seem feasible. That would be at least a 1000 more cars. In summary my concerns mainly relate to the infrastructure we do not have the roads, doctors, schools, police to accommodate this. The minute there is a problem with the motorway the traffic through Henley is horrendous this is with the current number of residents let alone doubling the size of the town. In addition my understanding is that Henley has a very old sewage system I am not sure how this would cope with the level of building proposed. I also have concerns around sustainability in terms of the environmental impacts of increasing the population to this extent in Henley in regards to illusion from the traffic alongside wildlife considerations.

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Issue H1: Providing the right number of homes Local Housing Need 4.1 As part of the emerging evidence, the IO document refers to an updated Housing and Economic Development Needs Assessment (HEDNA) that has been produced for the whole of Coventry and Warwickshire Housing Market Area (C&WHMA) using the latest information from the 2021 Census. As rightly stated, the HEDNA uses as the starting point for assessing housing need the standard method set out in Planning Practice Guidance (PPG). 4.2 The Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire. Nonetheless, the HEDNA has modelled an alternative approach based on the Census 2021 early data releases from June 2022, based on apparent issues with estimating and projecting the population in Coventry, particularly relating to potential discrepancies in the estimates of the population that have informed the 2014-based household projections. The alternative need figure is 4,906 dwellings annually across the sub-region. 4.3 Table 9 of the IO document (and Table 15.1 of the HEDNA) shows a breakdown of the overall housing need for each constituent local authority. This is reproduced below for reference. Table 4-1 Local Housing Need – Coventry & Warwickshire LPA -----------------------------2014-based projection ---------------- Trend-based projection Coventry-----------------------3,188----------------------------------------1,964 North Warwickshire---------176------------------------------------------119 Nuneaton & Bedworth------433------------------------------------------409 Rugby---------------------------516------------------------------------------735 Stratford-on-Avon------------564------------------------------------------868 Warwick------------------------675------------------------------------------811 Housing Market Area-------5,554---------------------------------------4,906 Source: C&W HEDNA 2022 4.4 RPS notes that under the alternative ‘trend-based’ (‘revised standard method’) projection the need is higher for both SW authorities compared to the standard method need figures (1,679 dpa under the alternative projection, versus 1,239 dpa using the standard method), an extra 440 homes per annum across the SW area. The trend-based projection is also higher in Rugby, but lower in North Warwickshire and Nuneaton & Bedworth, and substantially lower in Coventry. 4.5 The HEDNA goes to great lengths to explain why an alternative approach to the standard method for estimating local housing need across the sub-region is justified on the basis of ‘exceptional circumstances’, which is required to meet the policy test set out the paragraph 61 of the NPPF. In a nutshell, when looking at population change over the preceding period (2011-2021) the HEDNA claims that a discrepancy exists between the population (mid-year) estimates devised by ONS, and those derived from the Census 2021 population count. 4.6 Table 5.2 and 5.3 of the HEDNA seeks to illustrate this discrepancy. These tables show that population across the sub-region was substantially lower in the Census (942,100) compared to the mid-year estimates (963,173), largely as a result of an over-estimate in the population for Coventry. However, it is also notable that the Census output shows a higher population for both Stratford-upon-Avon and Warwick districts, a total difference of 6,316 extra people residing in South Warwickshire in 2021. This additional number of people will clearly have an impact on future population estimates for the SW area when properly accounted for in future projections. 4.7 On this basis, paragraph 5.105 explains the HEDNA proposes a trend-based projection taking account of the 2021 Census, more recent data around fertility and mortality, analysis of recent migration trends, from which household estimates are then derived (using the 2014-based household formation rates). The remodelled household projections are then fed back into the standard method through the application of the affordability adjustment, to generate the overall housing need figures for each area. 4.8 The local housing need derived from the trend-based projections is provided at Table 5.33 of the HEDNA. Whilst the overall approach is broadly understood, reference is made at paragraphs 5.149-5.150 of the HEDNA to a ‘further adjustment to deal with any suppression of household formation within the projections’ and ‘part return to trend’ analysis based on a refinement of the 2014-based household representative rates (HRRs). The results from the adjusted HRRs is shown in Table 5.34. The figures show a further increase in household growth across the sub-region (by +3,000) compared to alternative trend-based projection, which includes an increase household growth for Stratford-upon-Avon and Warwick districts. However, the HEDNA does not consider the implications this adjustment might have for the estimate of overall housing need across the subregion, or for the South Warwickshire specifically. 4.9 RPS recommends that the adjustment for household suppression presented in the HEDNA is reasonable and consistent with national policy and guidance and so should be taken into account in determining the scale of housing need in south Warwickshire.

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Issue H7: Other Comments Q-H7 Response to Issue H7: Please add any comments you wish to make about delivering homes in South Warwickshire 4.15 This chapter of the IO document provides a commentary on a range of factors relating to policies for the provision of housing, including the scale (or need), type, size, and tenure of new homes to meet the needs of local communities. 4.16 As a general comment, this chapter is the first point at which the overall growth strategy for housing is considered in any detail in the IO document. This is after the IO document has already considered the spatial options for growth in chapter 4 (under Issue S7). This approach runs the risk of predetermining the distribution of growth before establishing the level or scale of growth that should be planned for. As highlighted in response to Issue S10, RPS recommends that the SWLP considers a different approach to devising the strategic policies relating to planning for the growth needs of the area by presenting the case for growth before considering distribution, rather than the other way round. This will ensure the SWLP is presented in a logical and coherent manner where distribution of development is properly considered in light of the scale of growth needed in the 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 levels of housing need. On this basis across the Stratford-on –Avon district 868 dwellings per annum will be required.

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The Plan Period 4.2 We support the approach to planning for the period to 2050. This is on the basis that there are no arbitrary phasing policies which prevent development delivery early in the plan period where it has been unjustifiably tied to unrealistic expectations of delivery of larger scale growth, including in new settlements. As outlined in the representations, delivery of our client’s site west of Southam could occur at an early stage in the plan period of the SWLP. 4.3 Furthermore, any decision on the plan period for the document does not negate the requirement for the plan authorities to undertake reviews at least every five years to ensure that they adequately plan for the development needs in the areas as required by the NPPF 7. 4.4 This review of development needs will also include consideration of changes in unmet housing needs from neighbouring authorities including the cities of Birmingham and Coventry, which could result in a need for additional homes. 7 Also be statue - The Town and Country Planning (Local Planning) (England) (Amendment) Regulations 2017 (legislation.gov.uk) Issue H1: Providing the Right Number of New Homes Issue H4: Accommodating Housing Needs Arising from Outside South Warwickshire 4.5 The draft Local Plan outlines the derivation of the Local Housing Need (LHN) for both Districts, comprising the extent of the South Warwickshire Plan area. It also summarises the evidence within the HEDNA for Coventry and Warwickshire which reviews the realism of the LHN approach having regard to more recent evidence, including the initial results of the 2021 Census. 4.6 Whilst the HEDNA provides comparisons with the mid year estimates for 2020, it has not included comparisons with the projected growth in the various household and population projections in 2014, 2016 and 2018 (the former being those which currently underpin the standard method). The Government has indicated that the 2020 based projections will take account of the results of the 2021 Census. 4.7 The tables below provide comparisons of the population and household projections alongside the results of the Census. 4.8 Our comparison indicates that the population growth for both authorities within the joint plan area within the 2021 Census were significantly above each of the forecasts, and for households, this also applies for Stratford-on-Avon District. The actual household growth in 2021 is marginally below that projected in the 2014 projections whereas it is higher than both the 2016 and 2018 projections. 4.9 The HEDNA references comparison of the 2020 mid-year population estimates and the results of the 2021 Census. These are repeated below alongside the corresponding forecasts within the sub-national projections. Table 1: Population projections comparison with Census Results [see original submission attachment] Table 2: Household projections comparison with Census Results [see original submission attachment] 4.10 Alongside the comparisons of the projections with the Census results, the implications for the expectations on average household size (based upon population / households) is shown in the table. 4.11 This confirms that across the Joint Plan area and Coventry, the average household size has not reduced to the extent envisaged. 4.12 Whilst this might be a result of slowing in societal changes and the expected growth in especially single person households, it could also be a result of constrained housing delivery both nationally and locally which has impacted upon household creation with associated impacts upon over-crowding and wider social needs. 4.13 This represents a reason for delivering additional homes across the plan area to reflect the minimum levels in the HEDNA, even though they exceed the Local Housing Need. 4.14 The impacts upon wider society is illustrated by the very significant growth in household size in Coventry, whereas had the city’s housing stock increased as envisaged, this would not have arisen. 4.15 Whilst it is recognised that the existing plans include allowances for unmet need in Coventry, given the plan preparation programmes and subsequent delivery, they would not have boosted the supply sufficiently to ensure Coventry would have had sufficient homes. 4.16 In any event, these will have been included in the figures for the authorities surrounding the city, including the Joint Plan area. Nevertheless, higher household size figures, especially compared to those envisaged in the 2014 projections indicates that this additional housing was nevertheless insufficient. Table 3: Household size comparison with Census Results [see submission attachment] 4.17 The HEDNA indicates that the need for housing within the joint plan area exceeds the LHN when derived consistent with the guidance. 4.18 Table 7.9 of the HEDNA indicates that the respective housing needs for the districts are as follows: Stratford-on-Avon: 868dpa Warwick: 811dpa 4.19. This compares to their minimum LHN of 564dpa and 675dpa respectively. 4.20. The above analysis indicates that the growth achieved in the plan area between the 2011 and 2021 Census’ was above that forecasted, and this further supports the use of the higher housing figures derived from the HEDNA since these better reflect the local demographic changes of the local housing figures. As noted, household size did not decline to the extent expected. 4.21. The HEDNA figures result in a higher baseline figure before any consideration of unmet needs from neighbouring authorities. 4.22. In the circumstances, the Joint Plan should plan for the minimum figure contained in the HEDNA. Thereafter, there is a need to plan for unmet needs from neighbouring authorities. This is in addition to the HEDNA figure. Unmet Needs from Neighbouring Authorities 4.23. The unmet need would include proportions of that arising in the cities of Birmingham and Coventry. The emerging approach for this is detailed in section 6 associated with issue H4 – needs arising from outside of South Warwickshire. 4.24. The consultation document (page 112) notes that unmet need from the City of Birmingham is currently assessed to be around 78,400 dwellings. The South Warwickshire Plan area currently tests the provision of between 5,000 and 10,000 homes as a contribution towards this unmet need. Such an approach is supported. 4.25. For the city of Coventry, the HEDA provides an alternative assessment of housing need compared to the LHN approach and this potentially shows a reduced overall need. Given the capacity of the city to accommodate growth, should Coventry’s housing needs be reduced to reflect the outputs from the HEDNA, this would lower the extent of any deficit which would need to be addressed in neighbouring area, including South Warwickshire. 4.26. Whilst the HEDNA calculates a lower need for Coventry, as noted above, the development plans of the authorities around the city include uplifts to contribute towards its unresolved needs. Therefore, a proportion of the expected growth of the city has been exported to its neighbours and this therefore further supports the HEDNA calculations associated with especially the Joint Plan area. 4.27. A review of the HEDNA’s conclusion with respect of Coventry’s housing needs is therefore essential to ensure sufficient housing, especially to address social issues such as that arising from the unexpected increase in housing size as shown by the 2021 Census. 4.28. The extent of unmet need within Coventry is therefore likely to be above that associated with the HEDNA as given the comments above, it is not considered that this provides a robust assessment of needs given the results of the Census. Housing Delivery 4.29. The reversal of the reduction in household sizes, especially associated with the city from that projected (as indicated in the tables above) is a further indication of the reasons why further housing is necessary across Warwickshire, including the Joint Plan area. 4.30. As a minimum, we advocate that the plan area’s housing targets are aligned with the baseline assessment in the HEDNA for the reasons outlined, especially as recent performance exceeded the forecasts associated with the 2014 and subsequent projections. This support for delivering the higher growth figures as they are reflective of recent experience as confirmed by the results of the 2021 Census. 4.31. Additionally, whilst figure 22 on page 100 of the draft Local Plan illustrates house building rates achieved in England in the period to 2009, it does not include data for the period 2009 to 2022. That information is shown in Figure 5 below (derived from Governments data) Figure 5. Housing Delivery in England since 2009 [see submission attachment] 4.32. As Figure 5 shows, overall housing delivery is heavily reliant upon provision by private developers with outputs significantly above 150,000 annually, including from 2005-2008, unlike that intermated in the Council’s document. Therefore, it is important to emphasise the clear and important role of private developers like Barwood in delivering homes, especially as they also contribute towards affordable housing which is included in the above figures. 4.33. Furthermore, whilst local authorities and other affordable housing providers have a role in providing additional homes, the vast majority will only come forward on non-public sector land which will be delivered by the private sector. This is therefore a fundamental factor in ensuring achievement of the Government’s wider objectives for 300,000 homes annually within England. 4.34. The delivery of homes by private developers is consequently an important factor in boosting housing supply which will consequently limit changes in house prices, especially where these are affected by limitations in supply. The provision of additional homes to reflect the minimum requirements as identified in the HEDNA is therefore essential for the emerging Plan as envisaged in question Q-H1-1, although this must be recognised as providing a minimum for the joint plan area given the higher growth demonstrated by the 2021 Census compared to the household projections. Questions H1-1 and H1-2 4.36. We agree that the HEDNA provides an appropriate base for determining the housing needs of Stratford-on-Avon District and Warwick District i.e. the South Warwickshire Plan Area. The minimum respective housing needs for each authority is therefore 868dpa and 811dpa. 4.37. As explained above, we disagree with the conclusions of the HEDNA in its determination of the need in Coventry and the extent of its shortfall. This is because an element of this is included in the recent delivery elsewhere in Warwickshire and therefore the additional uplifts required under LHN must also apply to the redistribution.

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Question H3 4.43. Issue H3 references the analysis with respect to the size of dwellings to be sought according to tenure and district in the Joint Plan area. It also references the optional national space standards. The analysis above (Table 3) illustrated that household size across the Joint Plan area has not changed as envisaged. Whilst this provides information on the accuracy of the forecasts of need, the 2021 Census also confirms the very significant role of the current housing stock for meeting existing and evolving needs. 4.44. Unless the authorities are also seeking to ensure necessary adaptation of the existing stock to achieve these standards, there will be significant viability concerns regarding compliance with the requirements. Additionally, there is no evidence that dwellings currently being provided do not adequately meet the needs of residents. This collectively means that we do not consider any space standards are required (Answer H3d). 4.45. For considering housing needs from outside of South Warwickshire (Issue H4), as explained we agree that the Joint Plan area should provide sites for between 5,000 and 10,000 dwellings (in addition to that arising from the Plan area as calculated in the HEDNA) to contribute towards unmet needs from Birmingham (page 112 and questions H4-1 and H4-2). 4.46. For question H4-2 regarding where unmet need should be provided, this should be delivered on sites at sustainable locations, to include Southam – which approach is consistent with and the adopted and emerging strategy. This view is taken as there is no appropriate or justified mechanism, especially for private homes which will represent the majority of future delivery; which restricts where residents associated with the unmet need can live. 4.47. We note a desire for self build homes as outlined in issue H5. We consider that the Councils (in first instance) should seek to ensure this requirement is addressed from specific promoted sites for this purpose. 4.48. For gypsy and travellers (Question H6), we do not consider that pitches should be provided within large scale general housing sites taking account of the specific social and cultural needs of this community, and their rejection of bricks and mortar.

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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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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 - 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 Councils are in a Housing Market Area (HMA) with Coventry. In this context, the SWLP 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 approach followed through the HEDNA 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 (675 dwellings to 811 dwelling per annum) and Stratford-on Avon Districts (564 dwellings to 868 dwellings per annum) represent an increase over and above the minimum standard method based equivalents. National policy sets out an objective to significantly boost the supply of homes (NPPF paragraph 60). It is therefore considered to be a sensible and robust approach for the SWLP to be planning for, and identifying allocations to meet, this higher minimum figure in order to ensure that there is a sufficient supply of homes coming forward in this area. It is important to note that once the minimum housing need is established, national guidance states that assessing housing need is just “the first step in the process of deciding how many homes need to be planned for. It should be undertaken separately from assessing land availability, establishing a housing requirement figure and preparing policies to address this such as site allocations” (Planning Practice Guidance (‘PPG’) Reference ID: 2a-001-20190220). The standard method identifies “a minimum annual housing need figure” and “does not produce a housing requirement figure” (PPG Reference ID: 2a-002-20190220). The housing requirement figure must take into consideration any economic aspirations and the significant housing needs arising from the Greater Birmingham and Black Country HMA as well as the Coventry and Warwickshire HMA. In order to be positively prepared (NPPF paragraph 35), we expect that the SWLP should make a contribution to both of these HMA shortfalls and any proposed contribution should be supported by reasonable evidence and justification for how the figure has been calculated. QH2-2 select an affordable housing option for South Warwickshire No preferred option - Bellway considers that further information on market dynamics and demand within South Warwickshire should be taken into consideration when setting an affordable housing approach. There is not considered to be sufficient information available in the public domain at present to be able to provide a firm answer to this question. Further evidence needs to be made available, notably with respect to viability. Q-H3: Please select all options which are appropriate for South Warwickshire Bellway supports option H3d: None of these – do not set specific space standards. Bellway consider that space standards should be set by national guidance and Building Regulations and agreed on a site by site basis depending on the proposed scheme. Should the SWLP seek to impose specific standards then these will need to be justified. In relation to the NDSS, the PPG (Paragraph: 020 Reference ID: 56-020-20150327) identifies that LPAs need to take account of need, viability and timing. In relation to the M4(2) and M4(3) standards, the PPG (Paragraph:007 Reference ID: 56-007-20150327) 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. Q-H5: Please select all options which are appropriate for South Warwickshire (Self and Custom Build) Bellway support 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. The requirement for custom and self-build housing plots needs 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 test (See PPG Reference: Paragraph: 025 Reference ID: 57-025-20210508).

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Providing the right number of new homes 4.2 Stratford-on-Avon and Warwick are the least affordable areas in the Coventry and Warwickshire sub-area.1 It is imperative therefore that this characteristic is attributed a particular importance in determining the right number of new homes to be provided. The affordability problem will simply be compounded if the Local Plan provides too few houses, either by a deliberate policy choice not to meet the objectively assessed level of housing need in full at the outset, or by an embedded housing land strategy that isn’t sufficiently robust to ensure those needs are met. 4.3 It is instructive that the Housing and Employment Development Needs Assessment has illustrated that a higher housing requirement is generated for Stratford-on-Avon and Warwick in the context of the evidenced demographic characteristics. These factors and the associated analysis is described in section 5 of the HEDNA. 4.4 The effect of this analysis is to identify an overall housing requirement for the Local Plan area greater than that derived from the output of the Government’s Standard Method. This is shown in Table 9 of the consultation document and summarised below: --------------------------------- Standard Method 2014 based household projections --- Standard Method using revised demographic projections Stratford-on-Avon (dpa)---564---------------------------------------------------------------------868 Warwick (dpa)---------------674---------------------------------------------------------------------811 Plan Area (dpa)-------------1238-------------------------------------------------------------------1679 Plan Area (25 years)------30,950-----------------------------------------------------------------41,975 4.5 We agree with the view expressed in the consultation document that “whilst it may be tempting to want to apply the 2014-based figures because they are lower for South Warwickshire, given that Coventry looks unable to accommodate all of its own housing needs, it would most likely fall to South Warwickshire to accommodate a significant quantum of that need. The outcome would then most likely be similar levels of housing as shown in the 10-year trend-based projection”. It would be wrong therefore to develop a Local Plan that was not based on the scale of housing which the adjusted figures above imply. On this basis, the housing requirement should be the higher of the two figures suggested above. 4.6 Based on the evidence of potential existing housing supply in the Urban Capacity study this would suggest a residual need for some 22,000 new homes to be provided over the plan period. 4.7 In this regard, if in due course the housing number is for some reason considered to be less, the Local Plan would simply have identified a strategy and associated supply of housing land that would endure for several more years after the end date of the plan. No disadvantage arises from this because it is inevitable logic that the need for development land wont simply cease at 2050. Consultation on the NPPF 4.8 We are aware that the Government are currently consulting on potential revisions to the NPPF which concern, inter alia, the approach to meeting housing needs. In our view, none of those potential alterations represent a fundamental change to the plan making process in this instance. 4.9 It remains the case that the cornerstone of the planning system is to contribute to the achievement of sustainable development, including the provision of homes and other forms of development, including supporting infrastructure in a sustainable manner (§2). 4.10 The social dimension of sustainable development is still as drafted previously: 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. 5 Summary 5.1 This response to the South Warwickshire Local Plan Issues and Options has been prepared on behalf of Hallam Land Management Limited. 5.2 We have identified that, irrespective of the current consultation relating to the NPPF, it is firmly the case that Local Plans should continue to provide a sufficient supply of housing land to meet identified needs. In this regard, we agree that the housing requirement should be based on the HEDNA exercise which indicates a need over the plan period of some 40,000 new homes. 5.3 Based on the evidence of potential existing housing supply this would suggest a residual need for some 22,000 new homes to be provided over the plan period. This is going to require new land allocations. Having already prioritised previously developed land, the allocation of greenfield land is a legitimate proposition in order to meet the identified needs. If follows that the Spatial Strategy will need to guide those new land allocations to sustainable locations. 5.4 The Spatial Strategy is likely to require a hybrid approach which directs new development to those locations which are the most accessible, which are commensurate with existing centres that have an established range of services and facilities and where future economic growth is likely to be greatest. This approach clearly favours new development being directed to Stratford-upon-Avon, which was the only settlement to appear in each of the Options considered. 5.5 Although there is no consultation question in relation to directions of growth at Stratford-upon-Avon, the evidence base is particularly instructive as to the advantages of development to the south-east of the town. 5.6 The accompanying submission regarding the land controlled by Hallam Land Management Limited at Trinity Way illustrates further the many advantages of new development in this location. 5.7 In preparing the next version of the Local Plan, we would propose that land at Trinity Way is allocated for a housing-led mixed use development. 1 Table 5.1 of the HEDNA

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Q-H3a – Should the National Space Standards be applied? The emerging plan correctly recognises that Nationally Described Space Standards should not automatically be included within emerging plans. Footnote 49 of the NPPF advises that Nationally Described Space Standards can only be applied through policies where the need can be “justified”. The PPG provides guidance on the evidence that is required to “justify” space standards. The Draft Plan advises that at this point in the plan process the Councils have not gathered evidence on the need for and benefit of, including Locally Described Space Standards. There is, therefore, currently no evidence to support the inclusion of such a policy. Should this evidence be produced we reserve the right to comment further. In terms of introduction of M4(2) and M4(3) standards, these are building regulation requirements. It is highly likely that new building regulations will be put in place by the time the SWLP is adopted. There should not be dual regulatory control. Q-H5 – Custom built housing The most appropriate way of delivering custom built housing is Option H5a – Identifying a range of specific sites within or on the edge of settlements to deliver custom and self-build housing. These locations are mostly likely to appeal to self-builders. In Spitfire’s experience, there is very little interest in self-build and custom build plots on large scale market developments. Requiring a set proportion of larger sites to deliver self-build and custom build houses is unlikely to meet the demand for these properties. Requiring larger sites to provide self built plots creates a series of problematic development control matters. As the details of self-build houses will not necessarily be known at the application stage, it means that full planning applications cannot be submitted for schemes that require self build plots. This results in the creation of more complex “hybrid” planning applications.

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Issue H1: Providing the right number of new homes 4.1 Catesby Estates praises the Consultation Document for recognising that ‘England is experiencing a housing crisis’ and that there ‘has been a failure in the supply of affordable homes to achieve the Government’s target of 300,000 homes annually’. Catesby Estates also supports and echoes the issues identified through the previous consultation and summarised within the Consultation Document, including that there is an affordability issue within South Warwickshire. We are clear in our view that the only way of addressing this is by increasing supply of housing overall, which will also help to deliver affordable housing. 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? 4.2 The latest HEDNA suggests exceptional circumstances exist to move away from the Standard Method for determining housing need as there are alleged issues with existing census data in estimating and projecting the population in Coventry. 4.3 The HEDNA has therefore modelled new demographic projections which take account of the initial 2021 Census data releases and seeks to assess how the population can be expected to change over time by applying more up-to-date assumptions about fertility, mortality and household formation rates. The HEDNA then applies these alternative projections through the framework provided by the standard method. 4.4 Barton Willmore, now Stantec has not reviewed the methodology utilised by the HEDNA and therefore cannot comment on its appropriateness. 4.5 The HEDNA nonetheless suggests that, based upon the trend-based projections, whilst the housing need in Coventry City may have reduced, the housing need for Stratford -on-Avon has increased from 564 to 868 dwellings per year (304 dwellings per year / 53.9% increase). Similarly, the need for Warwick District has increased from 675 to 811 dwellings per year (136 dwelling per year / 20.1% increase). The total housing need for both Districts (and therefore South Warwickshire) has accordingly increased from 1,239 to 1,679 dwellings per year (440 dwellings pear year / 35.5% increase). 4.6 The housing need across the Plan Period has therefore increased from 30,975 to 41,975. This figure represents the minimum need that should be planned for and does not include any unmet need from neighbouring authorities (such as Coventry or Birmingham) which may be accommodated, or any addition homes that may be planned for to meet other socio economic objectives (such as increasing affordable housing provision – see answer to Question H2-2). 4.7 Should the authorities choose to pursue the trend-based alternative, they must accept that the housing need increases substantially and that this need must be met, as a minimum. It would not be acceptable to reduce the level of housing provided within Coventry whilst seeking to retain the need for Stratford and Warwick suggested by the Standard Method. 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 Option H2-2b – Separate affordable housing requirements for Stratford On Avon and Warwick Districts Option H2-2c – A more localised approach with separate affordable housing requirements for different localities across South Warwickshire 4.12 Catesby Estates acknowledges the need for affordable housing across South Warwickshire, but reiterates that market conditions and housing need should be taken into account by the Councils. Given that market conditions and housing need (both market and affordable) vary across South Warwickshire, it is considered that it is most appropriate for each authority to have a separate affordable housing requirement. Similar to CIL, it is important the two District’s keep their affordable housing requirements separate, as their housing figures remain separate and therefore ensures this overall figure for each district is achievable. In addition, separate affordable housing requirements takes into account items such as geographical location and therefore the difference in land values, it also provides the opportunity for each District to target their own specific affordable housing need. This is supported by Paragraph 0041 (Reference ID: 23b-004-20190901) which sets out that plan makers should consider how needs and viability may differ between site typologies. 4.13 However, regardless of the affordable housing requirements proposed, the Council need to ensure that Policy is flexible in wording, allowing for viability to be taken in account and demonstrated where required to do so. 4.14 Furthermore, the proposed affordable housing policy is a strategic policy, which should be set out by establishing and understanding the need requirement, therefore the policy should be informed by evidence. 4.15 This is supported by Paragraph 0042 (Reference ID: 23b-004-20190901) which sets out that planning obligations policies should be informed by evidence of infrastructure and affordable housing need, and a proportionate assessment of viability. Consequently, there is potential that the two local authorities have different needs, and therefore the Policy should be addressed in accordance. However, Catesby Estates cannot comment on details relating to specific quantified amounts, as there is no viability evidence presented alongside this consultation at present. 4.16 Option H2-2c should not be considered as it would result in affordable housing requirements being unclear and potentially unknown, therefore introducing risk, impacting upon bringing sites forward and ultimately delivering the required housing figures. 1 Planning Policy Guidance: Where should policy on seeking policy obligations be set out? 2 Planning Policy Guidance: Where should policy on seeking policy obligations be set out? 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 Option H3c – Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. Option H3d – None of these 4.17 As set out under Paragraph 1.4 of the Issues and Options Report, the purpose of Part 1 of the Local Plan is to establish a robust and flexible framework to set out where and how much development should take place across South Warwickshire. Consequently, the introduction of minimum space standards is not appropriate for Part 1 as it is not a strategic consideration, thus none of the above options are the correct or suitable approach. Consequently, Option H3a should be pursued on the basis of not including minimum space standards in a policy within Part 1 of the Local Plan. 4.18 However, if the Council wish to include this, sufficient evidence should be presented as per PPG Paragraph 0023 (Reference ID: 56-002-20160519) which sets out that in order to set minimum space standards within local planning policy, local authorities need to gather evidence to determine where there is need for additional standards in that area, to justify appropriate policies. The importance of this guidance cannot be understated. It is clear that the onus is on local authorities to demonstrate why standards are needed in that area i.e., the absence of such standards is consistently resulting in the provision of under -sized homes within Warwick and Stratford Districts. 4.19 However, it is also worth noting that in order to achieve Minimum Space Standards, larger plots will be required and therefore appropriate densities for allocated sites and what is deemed as suitable densities will need to be considered. Overall, having a Minimum Space Standard requirement may then impact upon achieving the overall housing need, therefore Catesby Estates suggests the local authorities allocate more sites, above the HEDNA requirement in order to take account for Minimum Space Standards, ensuring the Standards can be met without impacting upon density and housing numbers, thus deliverability. Issue H5: Providing custom and self-build housing plots Q-H5: Please select all options which are appropriate for South Warwickshire Option 5a – Identify a range of specific sites within or on the edge of existing settlements of approximately 5-20 homes in size to be developed only for self and custom build homes. Option 5b – Require large developments of, say, over 100 homes to provide a proportion of self and custom-build homes within the overall site. Option 5c – 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. 4.29 Catesby Estates acknowledges the need for self and custom build homes, however the viability of such plots need to be considered when establishing planning policy. Option 5b has potential to be an option, where self and custom build homes will be encouraged/required on larger developments, however the Council will need to test via their viability assessment the amount required against different sized sites. 4.30 However, where Option 5b states ‘over 100 dwellings,’ this threshold needs to be viability tested and justified. In addition, the Policy should be caveated to ensure that it allows developers flexibility, for where it can be demonstrated that the provision of self build and custom plots are not viable as part of the wider scheme, that is acceptable from a policy perspective. This needs to be taken into consideration based upon a site’s location and associated constraints. 4.31 In addition, the Council need to ensure sufficient evidence is present and demonstrated to show need and demand for self and custom built. At present, there is no evidence to show that there is a need for this within South Warwickshire, and if it can be demonstrated, a realistic and achievable consideration should be had when deciding the required amount to underpin the policy. In addition, the Policy should include wording to states that if after 12 months of marketing, there is no demand, the plots/houses can be marketed. 4.32 Option 5c should also be amalgamated into policy, whereby each site should be assessed on its’ own merits and consideration is had if deliverability isn’t possible, or at the required level, specifically on sustainable urban extensions. Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire 4.33 It is crucial that the Councils undertake more evidence, to create a wider, more detailed evidence base to inform the next stage of the South Warwickshire Local Plan. It is detrimental to the potential Growth Options to not have fully evidenced reports, such as a Green Belt Review, review of the Call For Sites submissions, engagement with other authorities within the HMA, the creation/update of the HELAA and viability testing. 4.34 Without this evidence, it is difficult to fully appreciate whether the housing need for South Warwickshire can be accommodated, where it could be accommodated, what sites are physically available for development, and the viability associated with other policies in relation to the delivery of residential sites. Therefore, Catesby Estates strongly advises the Council undertakes further evidence and engages further, prior to the formulation of any future iteration of the Local Plan.

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Heritage and Settlement Sensitivity Assessment The Heritage and Settlement Sensitivity Assessment (HSSA) produced by Place Services at Essex County Council for the SWLP is clearly intended to be relied upon in the next stage of the process when individual development sites are selected. The HSSA study states that it is designed to assess the sensitivity to new development on the existing heritage and landscape character within a number of settlements within South Warwickshire. However, despite including the reference to “landscape”, the text of the HSSA consistently gives considerably more emphasis to “heritage assets” than to landscape. In places there is no mention of the landscape aspect at all. This is emphasised by the RAG rating definitions where the “green” rating states; “Green defines areas where there is little known heritage impact, or it is thought that the heritage assets present can be incorporated into any development proposal with appropriate mitigation resulting in no harm to their significance”. According to the HSSA definition a “green” rated area or zone may therefore contain sites that have high levels of landscape sensitivity but are nevertheless afforded little weight by the HSSA study. The HSSA includes a note highlighting; “This assessment is a high-level desk-based assessment. Once areas for development have been identified there will be a requirement for further in-depth assessment, including site visits, of the impact of each individual development on the heritage assets and their setting”. (Again, no specific reference to landscape impact). We fully accept that a statutory development plan should be policy led and not site-led. However, it is essential that, as highlighted by the above note, the selection of sites should take account of a wide range of relevant evidence and should not be over reliant on high level desk-based studies. The shortcomings of a desk-based study are highlighted in the detail provided for Long Itchington. The HSSA document states in section 10.7 (page 150) that the River Itchen; “flows into the Grand Union Canal 400m to the south of the village”. This is clearly an error resulting from misreading the relevant Ordinance Survey map. The River Itchen clearly flows under the Grand Union Canal and this error highlights that landscape impact can only be properly assessed by landscape experts who include site visits when undertaking their assessments. We therefore seek reassurance that the HSSA will not become a “tablet of stone” and used as a prime justification for the inclusion of proposed development sites. We expect that any sites included in the Preferred Options version of the SWLP are assessed on all evidence currently held by the District Council, including all previous landscape evidence.

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Issue H3: Providing the right size of homes We welcome the emphasis on and recognition of the need for inclusion of more smaller dwellings - 2/3 bedroom, and the acceptance of the need for specific housing types, such as bungalows, homes for the disabled and homes for an ageing population. However, we see no evidence of how you might achieve this when it is clear that developers prefer to build larger, more profitable dwellings on larger estates. In relation to bungalows in particular we urge you to consider a tighter definition so that developers cannot build dormer bungalows to fulfil this criterion. This has been a particular issue for Long Itchington. We ask that immediate thought is given to reduction in large scale developments which pay lip service to genuine housing needs. We urge you to make a more marked distinction between “affordable” homes – rented and shared ownership - and homes which are affordable (market homes of a smaller size). In our experience many young people want to get on the property ladder by buying small market houses, not shared ownership. Issue H5: Providing custom and self-build housing plots In our opinion it is not sustainable to allocate small plots solely for SCB housing because of the very real risk that, should they not be sold, they would revert to market housing. We favour the option of identifying plots within a larger development so that unsold SCB plots can more easily be absorbed. However, since we do not wish to see any more large-scale development plots in Long Itchington, we would only support single plot SCB housing endeavours.

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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 2.25 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. 2.26 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). 2.27 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. 2.28 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. 2.29 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. Option H2-2b: Separate affordable housing requirements for Stratford-on Avon and Warwick Districts 2.35 We consider Option H2-2b; providing a separate affordable housing requirement for Stratford-upon-Avon and Warwick Districts, would be appropriate in terms of reflecting local requirements and local viability calculations. However, it is considered that the tenure and type of affordable homes sought should be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. 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? Yes 2.36 Birmingham City Council has commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes. 2.37 Issue H1 above sets out the approach to needs arising within Coventry and Warwickshire. Even under the redistribution of housing resulting from the trend-based projection, Coventry may not be able to accommodate all of its housing needs (1,964 homes per annum), and as such a relatively modest shortfall may exist to 2050. 2.38 South Warwickshire sits most fully within the Coventry and Warwickshire HMA, with Warwick District most strongly related to Coventry given its shared boundary and interrelationships with the city. South Warwickshire is also within the Birmingham and Black Country HMA owing to Stratford-upon-Avon District’s shared boundaries and inter-relationships with Solihull and Redditch boroughs and Bromsgrove district. Through the Duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs. 2.39 Given the size of South Warwickshire, it is considered that any additional needs can be accommodated outside of any protected areas (e.g., Cotswolds National Landscape/AONB). One exception could be areas designated as Green Belt, particularly if such locations are deliverable, available and suitable for release from the Green Belt to deliver high quality residential developments. Locations for additional growth should be sustainable in close proximity to where people want to live. 2.40 In light of the above considerations, we agree with the approach of contributing to meeting the Birmingham and Black Country HMA shortfall to 2031 on the identified sites in Stratford-upon-Avon District. 2.41 Contributions to meeting the Birmingham and Black Country HMA shortfall to 2031 can be accommodated by either increasing the growth proposed for Option 5: Dispersed. Housing targets should be minimum ones in light of the wider Housing Market Area issue and the need to address the Birmingham and Black Country HMA unmet housing needs.

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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 toward a trends based approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire? Paragraph 61 of the Framework advises that in order to determine the minimum number of homes needed, strategic policies should be informed by local housing needs assessment, conducted using the Standard Method in National Planning Practice Guidance, unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing needs 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. We note that the Standard Method housing figures for Stratford-on-Avon and Warwick Districts are 564dpa and 675dpa respectively. The trend based projection in the HEDNA suggests that 868 dpa are required in Stratford-on-Avon and 811 dpa in Warwick District respectively. As the HEDNA figure is above the Standard Method housing requirement we have no particular concerns with the HEDNA methodology departing from the Standard Method as the level of development proposed would ensure that the minimum Standard Method housing requirement is exceeded. We note that this is not the case in the Coventry and Warwickshire plan area as a whole, where the total housing requirement in the HEDNA is less than the Standard Method requirement. This is principally due to the fact that the HEDNA suggests that the housing needs of Coventry is significantly below the Standard Method figure. We restrict our comments to the Stratford-on-Avon and Warwick sections of the HEDNA only and do not seek to comment on the Coventry figure at this stage given that it relates to a different plan area. In terms of the approach of the HEDNA, it is noted that Table 8.13 – Estimate Need for Social/Affordable Rented Housing by Local Authority, identifies a net need for 419 affordable dwellings per annum in Stratford-on-Avon and 582 affordable dwellings per annum in Warwick District. This equates to 67% and 52% of the identified overall housing requirement respectively for the two authorities. The PPG advises at paragraph 2a-024 that the total affordable housing need can be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probable percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the strategic plan may need to be considered, if it would help to deliver the required number of affordable homes. In all likelihood, the principal way affordable housing will be delivered during the course of the plan period will be through planning obligations associated with residential developments. We are concerned that there will be a significant shortfall of affordable housing provision during the course of the plan period to meet their identified need, as is not realistic to expect housing allocations to deliver 67% or 52% affordable housing. There should, therefore, be consideration to uplift the housing requirement to ensure that an appropriate amount of affordable housing is met. This is particularly important given that the plan advises that the issue of housing under-supply is “specifically and crucially . . . . an issue to do with the lack of affordable housing supply”. There are other documents that support an uplift to the SWDP’s housing requirement to assist with affordable housing delivery. The Stratford-upon-Avon District Housing Strategy (2021 – 2026) sets out three aims including supporting communities and building sustainable and affordable homes. The Warwick District Council Housing Strategy (2014 – 17) sets an objective of meeting the need for housing across the district. The Draft Plan advises at page 98 that there is an issue with affordability, with individuals with lower paid jobs being unable to afford to live within the plan area and having to commute from Coventry. A lack of housing land supply will increase house prices making this issue more profound. The draft Plan also recognises that providing new homes will support the local economy, through the creation of construction jobs and help ensure that existing facilities and services remain open by increasing footfall. All current evidence suggests that the housing requirement should be adjusted upwards from the HEDNA figure to support affordable housing delivery. This would support the Social Role of sustainable development identified by the NPPF, by ensuring that a sufficient number and range of homes are provided to meet the needs of present and future generations. Q-H3a – Should the National Space Standards be applied? The emerging plan correctly recognises that Nationally Described Space Standards should not automatically be included within emerging plans. Footnote 49 of the NPPF advises that Nationally Described Space Standards can only be applied through policies where the need can be “justified”. The PPG provides guidance on the evidence that is required to “justify” space standards. The Draft Plan advises that at this point in the plan process the Councils have not gathered evidence on the need for and benefit of, including Locally Described Space Standards. There is, therefore, currently no evidence to support the inclusion of such a policy. Should this evidence be produced we reserve the right to comment further. In terms of introduction of M4(2) and M4(3) standards, these are building regulation requirements. It is highly likely that new building regulations will be put in place by the time the SWLP is adopted. There should not be dual regulatory control. Q-H5 – Custom built housing The most appropriate way of delivering custom built housing is Option H5a – Identifying a range of specific sites within or on the edge of settlements to deliver custom and self-build housing. These locations are mostly likely to appeal to self-builders. In Vistry’s experience, there is very little interest in self-build and custom build plots on large scale market developments. Requiring a set proportion of larger sites to deliver self-build and custom build houses is unlikely to meet the demand for these properties. Requiring larger sites to provide self build plots creates a series of problematic development control matters. As the details of self-build houses will not necessarily be known at the application stage, it means that full planning applications cannot be submitted for schemes that require self build plots. This results in the creation of more complex “hybrid” planning applications.

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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 2.48. 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. 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. 2.49. The Respondent agrees that should the Councils wish to impose minimum space standards that they should be adopted as development plan policy. 2.50. 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. 2.51. 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. 2.52. For the avoidance of doubt the Respondent would strongly object to the imposition of space standards beyond NDSS 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. 2.58. 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. 2.59. 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). 2.60. 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-H3: This needs more rigorous analysis, probably by external consultants, to report upon the needs for future populations up to 2050. Appropriately worded policies can then flow from that Needs Assessment.

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Q-H3: This needs more rigorous analysis, probably by external consultants, to report upon the needs for future populations up to 2050. Appropriately worded policies can then flow from that Needs Assessment.

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Q-H3: The matters set out above are of importance and should be reflected in the Local Plan Part 1.

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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. 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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Q-H2-1 - What is the best way to significantly increase the supply of affordable housing across South Warwickshire? The delivery of affordable housing is, for the most part, via allocated and windfall sites. If the housing requirement is reduced, so too will affordable delivery. And affordability ratios in Warwickshire are substantial. The best way therefore to significantly increase the supply of affordable housing is to allocate greenfield sites, including the release of Green Belt, for 10+ units across the District. Non-brownfield sites have fewer viability and deliverability issues than brownfield sites and are therefore often capable of delivering a policy compliant level of affordable housing, unless site specific constraints such as the need to ground large overhead powerlines indicates otherwise. Q-H2-2 - Please select the option which is most appropriate for South Warwickshire: 1) Option H2-2a: A single South Warwickshire wide affordable housing requirement. 2) Option H2-2b: Separate affordable housing requirements for Stratford-on-Avon and Warwick Districts 3) Option H2-2c: A more localised approach with separate affordable housing requirements for different localities across South Warwickshire We do not agree with a more localised approach with separate affordable housing requirements for different localities. This will lead to affordable housing across the District becoming fragmented and could also potentially impact on viability more in some locations than others. The approach either needs to be one % requirements across South Warwickshire or one in each District (i.e. different standards for the Stratford-on-Avon area and one for Warwick District. Otherwise, the requirements will be too complicated and piecemeal. Q-H3 - Please select all options which are appropriate for South Warwickshire 1) Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. 2) Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. 3) Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4) Option H3d: None of these Option H3a – do not seek to include minimum space standards in a policy in the SWLP. It is onerous to prescribe in policy that minimum space standards should be met. We would support in principle a policy which requires “up to X%” to be built to M4(2) or M4(3) standards but this should not be a requirement for all dwellings. Q-H5 - Please select all options which are appropriate for South Warwickshire 1) Option H5a: Identify a range of specific sites within or on the edge of existing settlements of approximately 5-20 homes in size to be developed only for self and custom build homes. 2) Option H5b: Require large developments of, say, over 100 homes to provide a proportion of self and custom-build homes within the overall site. 3) 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. Option H5b is not acceptable. It is impracticable to require mainstream housebuilders to provide self / custom build plots throughout a development as it leads to a fragmented development with unbuilt plots left empty on a phase or phases when the rest of a phase is built and occupied. Opportunities for self / custom build should be made through specific site allocations for that purpose only under H5a above alongside encouraging applications under H5c. Q-H6 - Please select all options which are appropriate for South Warwickshire 1) Option H6a: Identify a range of specific sites in sustainable locations of up to 15 pitches/plots in size to be developed only for Gypsy and Traveller and Travelling Showpeople homes. 2) Option H6b: Require large developments of over 500 homes to provide a proportion of Gypsy and Traveller and Travelling Showpeople homes on the edge of the overall site. 3) Option H6c: Rely on a case-by-case approach whereby planning applications for Gypsy and Traveller and Travelling Showpeople homes will be assessed against a range of criteria to determine their suitability. Option H6a should be taken forward. It is not acceptable to require large development to provide a portion of Gypsy and Traveller and Travelling Showpeople homes on the edge of the overall site. This will affect sites’ cohesive design and placemaking, impacting on sales rates and viability.

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Q-H3: The matters set out above are of importance and should be reflected in the Local Plan Part 1.

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Issue – H6: Your consultation correctly highlights the importance of making provision for the travelling community but going forward there will need to be additional consideration for the need for transit sites or emergency stopping places for the travelling community. Issue – H7: Should the need arise, RBC is happy to collaborate with you on how any requirement to accommodate growth from Coventry across Warwickshire is progressed. Duty to cooperate response: Provision for the Gypsy & Travelling community can be controversial and all authorities need to work together to ensure that provision is identified in each plan area. This includes ensuring there is sufficient provision of transit sites/emergency stopping places to enable the travelling community to travel. This may become a cross-boundary issue if one or more authority is unable to meet its identified needs.

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Issue H5: Providing Custom and Self-Build Housing Plots The provision of land to provide custom and self build housing plots is an important part of housing policy which is not addressed in either the Stratford upon Avon District Core Strategy or the Warwick District Local Plan. Policies that meet the legislative duty to provide enough serviced plots to meet identified demand need to be included within the emerging South Warwickshire Local Plan to provide certainty and to support the growth of this housing type to meet aspirational and affordable needs. Evidence from the Councils' self-build/custom house build registers indicates that purchasers do not want to be on large development sites. They are looking for smaller sites on which they can create bespoke homes. Alternatively they want individual plots to meet specific needs. In the light of this Stansgate clients would support Option H5a: Identify a range of specific sites within or on the edge of existing settlements of approximately 5-20 homes in size to be developed only for self and custom build homes. In addition support would be given to a policy whereby unidentified sites, which will be assessed against a range of criteria to determine their need and suitability, can be brought forwards. Given the lack of demand for homes on large development sites, [respondent] would not support Option H5b: Require large developments of, say, over 100 homes to provide a proportion of self and custom-build homes within the overall site.

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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 The provision of land to provide custom and self build housing plots is an important part of housing policy which is not addressed in either the Stratford upon Avon District Core Strategy or the Warwick District Local Plan. Policies that meet the legislative duty to provide enough serviced plots to meet identified demand need to be included within the emerging South Warwickshire Local Plan to provide certainty and to support the growth of this housing type to meet aspirational and affordable needs. Evidence from the Councils’ self-build/custom house build registers indicates that purchasers do not want to be on large development sites. They are looking for smaller sites on which they can create bespoke homes. Alternatively they want individual plots to meet specific needs. In the light of this Rosconn Strategic Land clients would support Option H5a: Identify a range of specific sites within or on the edge of existing settlements of approximately 5-20 homes in size to be developed only for self and custom build homes. In addition support would be given to a policy whereby unidentified sites, which will be assessed against a range of criteria to determine their need and suitability, can be brought forwards. Given the lack of demand for homes on large development sites, Rosconn Strategic Land clients would not support Option H5b: Require large developments of, say, over 100 homes to provide a proportion of self and custom-build homes within the overall site.

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Issue H2: Providing the right tenure and type of homes 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. This would allow the requirement to be applied consistently across both Districts. 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 on 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.

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Q-H2-2: Please select the option which is most appropriate for South Warwickshire: 4.8 We consider Option H2-2b; providing a separate affordable housing requirement for Stratford-on-Avon and Warwick Districts, would be appropriate in terms of reflecting local requirements and local viability calculations. However, it is considered that the tenure and type of affordable homes sought should be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. L&Q Estates support a collaborative approach to identifying site-specific affordable housing requirements, including tenure and type of affordable homes to be provided on-site. Q-H3: Please select all options which are appropriate for South Warwickshire 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. Q-H5: Please select all options which are appropriate for South Warwickshire 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. 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. 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: 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 29. 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. 30. 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). 31. 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. 32. 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. 33. 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. 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 A single affordable housing requirement across the whole South Warwickshire area would provide a consistent approach across both Districts. This results in the most certainty – for developers, greater certainty in anticipating their costs; and for Councils, greater certainty in anticipating delivery of affordable homes. However, this approach would not reflect variations in value, or variations in affordable housing demand, in different areas of the Districts. This could result in a greater level of challenge on viability grounds in areas with lower house prices, and missed potential for affordable housing delivery in areas with higher house prices.   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. 39. We consider Option H2-2b; providing a separate affordable housing requirement for Stratford-on-Avon and Warwick Districts, would be appropriate in terms of reflecting local requirements and local viability calculations. However, it is considered that the tenure and type of affordable homes sought should be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. Option H2-2c: A more localised approach with separate affordable housing requirements for different localities across South Warwickshire A more localised approach could reflect with greater accuracy the variations of value, or variations in affordable housing demand, in different areas of the Districts. This may mean fewer challenges on viability grounds. However, having different requirements in different localities adds a level of uncertainty – it makes it harder for developers to anticipate their costs, and it makes it harder for Councils to anticipate delivery of affordable homes. There could also be unintended consequences if it makes certain areas more attractive to developers than others, with the potential that this makes it more challenging to deliver the chosen spatial growth strategy. As acknowledged on Section 6.1 (fourth paragraph) of the Scoping report increasing the housing target would address housing affordability: “We could consider increasing our housing figure to help address housing affordability.” 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? Yes 40. Birmingham City Council has commenced work on its Local Plan Review to 2042 and has published an Issues and Options consultation. This identifies a shortfall in housing of 78,415 homes. 41. Issue H1 above sets out the approach to needs arising within Coventry and Warwickshire. Even under the redistribution of housing resulting from the trend-based projection, Coventry may not be able to accommodate all of its housing needs (1,964 homes per annum), and as such a relatively modest shortfall may exist to 2050. 42. South Warwickshire sits most fully within the Coventry and Warwickshire HMA, with Warwick District most strongly related to Coventry given its shared boundary and interrelationships with the city. South Warwickshire is also within the Birmingham and Black Country HMA owing to Stratford-on-Avon District’s shared boundaries and inter-relationships with Solihull and Redditch boroughs and Bromsgrove district. Through the Duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs. 43. Given the size of South Warwickshire, it is considered that any additional needs can be accommodated outside of any protected areas (e.g. Cotswolds National Landscape/AONB). One exception could be areas designated as Green Belt, particularly if such locations are deliverable, available and suitable for release from the Green Belt to deliver high quality residential developments. Locations for additional growth should be sustainable in close proximity to where people want to live. 44. In light of the above considerations, we 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. Option H5a: Identify a range of specific sites within or on the edge of existing settlements of approximately 5-20 homes in size to be developed only for self and custom build homes. This would group this type of housing together in small sites in various locations, and whilst it gives certainty as to where this type of housing will be provided, it is dependent on landowners putting sites forward for this type of housing. This approach would not allow for individual plots in other locations that some people might prefer, although it should be borne in mind that the provision of such homes in open countryside would not be appropriate. 46. This would be the preferred option and should be considered for all settlement types, this 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. Option H5b: Require large developments of, say, over 100 homes to provide a proportion of self and custom-build homes within the overall site. This would provide more certainty of delivery as it would be a requirement of the larger development sites across the area and could provide a wider spread of this type of home across South Warwickshire. However, some people looking for self and custom build homes may not wish to live or on the edge of a large housing site. It will be necessary to establish what an appropriate proportion of such homes should be on such sites. 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. This option depends completely on the private sector in terms of the quantity and suitability of any submitted planning applications for self and custom build homes. Whilst this approach may be useful in conjunction with either Options 1 or 2, relying on this option alone would make it impossible to ensure that sufficient numbers of self and custom build home are made available Q-H7: Please add any comments you wish to make about delivering homes in South Warwickshire Spitfire’s experience as a medium sized housebuilder is that self and custom build sites work better when they are stand alone rather than forming part of a large consortium site. Marketing strategies will need to be agreed with the LPA and form part of any s106 agreement to ensure sites come forward and in the event, evidence is produced that no interest has been generated from the marketing strategy that homes can revert back to open market dwellings.