Q-H6: Please select all options which are appropriate for South Warwickshire
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Q-H2-1: What is the best way to significantly increase the supply of affordable housing across South Warwickshire? The WMHAPC supports the option which will allow the greatest provision of affordable homes, in the most sustainable locations. The 2022 HEDNA sets out two separate affordable housing need figures which differ significantly between Stratford-on-Avon (547 dpa) and Warwick (839 dpa). Given the differing housing need within each authority and the existing affordable housing requirements as set out by the development plans of the respective authorities of 35% in Warwick and 40% in Stratford-on-Avon, it is clear that either options 2b and 2c would be the most appropriate to deliver the affordable housing needs of both Stratford-on-Avon and Warwick. In considering the evidence available, paragraphs 8.140 on page 197 of the 2022 HEDNA explains: “Overall, the analysis identifies a notable need for affordable housing, and it is clear that provision of new affordable housing is an important and pressing issue in the area. It does however need to be stressed that this report does not provide an affordable housing target; the amount of affordable housing delivered will be limited to the amount that can viably be provided. The evidence does however suggest that affordable housing delivery should be maximised where opportunities arise.” When taken at face value Option H2-2c would go a long way of increasing the supply of affordable housing at a local level. Option H2-2c acknowledges the importance of recognising the differing house prices and high value areas within both Stratford-on-Avon and Warwick. However, it is difficult to comment on the appropriate option of increasing the supply of affordable until viability testing has taken place. The 2022 HEDNA explains that opportunities for increasing the supply of affordable housing will depend on the viability of the various options put forward. PPG (Paragraph: 001 Reference ID: 67-001- 20190722) supports this position stating: “Strategic policy-making authorities will need to consider the extent to which the identified needs of specific groups can be addressed in the area, taking into account: • the overall level of need identified using the standard method (and whether the evidence suggests that a higher level of need ought to be considered); • the extent to which the overall housing need can be translated into a housing requirement figure for the plan period; and • the anticipated deliverability of different forms of provision, having regard to viability.” Q-H3: Please select all options which are appropriate for South Warwickshire As set out within PPG both Stratford-on-Avon and Warwick District Councils “will need to gather evidence to determine whether there is a need for additional standards in their area, and justify setting appropriate policies in their Local Plans” (Paragraph: 002 Reference ID: 56-002-20160519). As such, there is a possibility that the need for NDSS will differ between the two local authority areas, this will need to be reflected in any NDSS policy put forward by the South Warwickshire Local Plan. The SW councils need to be cautious on the inclusion of internal space standards within policy where there is not an identified need, the application of NDSS across all residential development could undermine the viability of many development schemes. This will potentially result in fewer homes being delivered as optional technical standards have implications for build costs and sales values, which in turn impacts development viability leading to challenges for the delivery of affordable housing. Whilst for prospective residents it is possible that many eligible households in South Warwickshire may not desire, or require housing that meets the NDSS, as it may result in for example, higher rental and heating costs. As set out by PPG the application of NDSS are not a building regulation and remains solely within the planning system as a form of technical planning standard. It is not essential for all dwellings to achieve these standards in order to provide good quality living. For affordable housing in particular, there may be instances where achieving NDSS is impractical and unnecessary. In line with Option H3b it is recommended that meeting NDSS is not made mandatory unless the SW councils are able to demonstrate a clear need for such a standard in dwellings in both Stratford-on- Avon and Warwick. Similarly, it is also acknowledged that the 2022 HEDNA identifies an estimated need figure for wheelchair accessible dwellings in both Stratford-on-Avon and Warwick. The introduction of such a standard will need to be robustly evidenced and viability tested to ensure it isn’t at the detriment of both affordable housing delivery and overall housing delivery more generally. It is suggested that if the SW councils wish to introduce such policies that the rational for their implementation be fully evidenced, and viability assessed in accordance with PPG (Paragraph: 020 Reference ID: 56-020-20150327): “Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.”
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Q-H3: Please select all options which are appropriate for South Warwickshire 4.15. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified”. 4.16. Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 'Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.' 4.17. If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4.18. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H4-2: Please add any comments you wish to make about the scale of the shortfall from the Birmingham and Black Country HMA that South Warwickshire should accommodate within the South Warwickshire Local Plan 4.19. This is discussed in answer to Question H1-1. 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 development 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 4.20. As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016- 20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. 4.21. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. .22. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. 4.23. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. 4.24. The emerging Stratford Site Allocations Plan (SAP) has identified specific sites to deliver selfbuild and custom housing through allocations. It is suggested that the South Warwickshire Local Plan should continue this approach, bring forward the allocations the SAP identified in the most recent Preferred Options document and identify similar suitable sites in Warwick District to ensure a spread across the plan area.
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ISSUE H2: PROVIDING THE RIGHT TENURE TYPES OF HOMES 2.39 Ellis Machinery consider Option H2-2b; providing a separate affordable housing requirement for Stratford-on-Avon and Warwick Districts, would be the most appropriate in terms of reflecting local requirements and local viability issues. 2.40 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. ISSUE H3: PROVIDING THE RIGHT SIZE OF HOMES 2.41 Ellis Machinery has 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, Ellis Machinery reserve the right to comment further at a later stage, once the specific requirements for sites have been clearly defined. ISSUE H5: PROVIDING CUSTOM AND SELF-BUILD HOUSING PLOTS. 2.42 Ellis Machinery consider that both Option H5b and H5c would be appropriate for South Warwickshire. Both approaches 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. For each option, it must 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. 2.43 Option H5b should 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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Issue H1: Providing the right number of new homes: I do not have any faith in the methodology used to produce the claim that Coventry and Warwickshire will need 1,600 homes built every year until 2050.
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Q-H3: Please select all options which are appropriate for South Warwickshire 4.15. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified”. 4.16. Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 'Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger wellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.' 4.17. If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4.18. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H5: Please select all options which are appropriate for South Warwickshire 4.20. As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016-20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. 4.21. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. 4.22. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. 4.23. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. 4.24. The emerging Stratford Site Allocations Plan (SAP) has identified specific sites to deliver self-build and custom housing through allocations. It is suggested that the South Warwickshire Local Plan should continue this approach, bring forward the allocations the SAP identified in the most recent Preferred Options document and identify similar suitable sites in Warwick District to ensure a spread across the plan area.
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We need to build houses which stand the test of a climate emergency, which is accelerating. Developers must evidence how the development will contribute to ‘net zero’ carbon reduction and to the health and wellbeing benefits to residents. Well planned developments must be designed with rich new habitats and wildlife areas. • Ensure that future housing developments are subject to the highest possible environmental standards • We should build zero-carbon/passivhaus housing – as well as commercial/ employment development- which will be able to cope with increased climate change during their lifespan, with car-free communal areas and more natural wild green spaces. • The social and communal spaces such as allotments or community orchards must be integrated in and central component of any new development. • Besides any wetlands/multifunctional SUDs, natural or open green spaces should also consist of areas such as woodlands which can be accessed easily by the new community. • New developments should seek to enhance and expand the District’s tree and woodland resource. • CO2 emissions come not just from ongoing energy use in households, but also from construction (embodied energy of materials), building fabric, space and water heating. All these need to be taken into consideration and policies developed to make sure that there is a reduction of emissions. This will mean changing the way we build and what material we use in the near future, including ensuring in policy that there is re-use and recycling of building materials, minimising waste, • Renewable energy technology, and other low carbon energy technologies must be provided in new developments. • EV charging points must be provided for all dwellings. • Small Community-led renewable energy farms should be encouraged and supported.
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Issue H1: Providing the right number of new homes: I do not have any faith in the methodology used to produce the claim that Coventry and Warwickshire will need 1,600 homes built every year until 2050.
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QH2.2 Please select the option which is most appropriate for South Warwickshire: Claverdon supports option H2.2c Achieving a higher number of affordable homes, suitable for younger people and families in particular is a major challenge. No housing target should be ratified without a fully funded strategy for affordable homes in high price settlements. QH 3 Please select all options which are appropriate for South Warwickshire This policy should be dealt with in Part 2 QH5 Please select all options which are appropriate for South Warwickshire Premature defer to Part 2 Q-H6: Please select all options which are appropriate for South Warwickshire Claverdon supports H6c but it should be deferred to Part 2
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Strategic Housing Land Availability Assessments Our client’s site, Land south of Rogers Lane (middle) (ref. ETT.11) has been assessed through several iterations of Stratford-on-Avon’s Strategic Housing Land Availability Assessment. The most recent iteration of the SHLAA is dated September 2011. This SHLAA gives a red, amber, and green rating for each site against a number of indicators. In terms of the final assessment of our client’s site, the SHLAA states: “Need to restrict development to northern part of site with extensive landscaping to effectively mitigate impact on setting of village. A detailed heritage assessment will be used to decide whether impact on heritage assets is too substantial to be mitigated effectively.” The site is given an amber rating for deliverability, meaning it is ‘likely to be deliverable’. Two other sites in Ettington are rated as amber, with the remaining 14 sites shown as red – i.e., not deliverable. The SHLAA is therefore highlighting that the only constraint which could mitigate against development of our client’s land is impact on heritage assets. This point is discussed in more detail below. Land at Rogers Lane, Ettington: Ettington is classified in the Stratford-on-Avon Core Strategy as a Category 3 “Local Service Village”. Out of the 10 Category 3 Local Service Villages, Ettington is one of the top settlements providing access to a Primary School, pub, general store, and employment opportunities. It has the largest population and the second largest number of existing dwellings (taken from the 2011 Census) when compared against the other Category 3 settlements. In addition, Ettington is a 10-minute bus journey from Stratford-on-Avon which provides access to a wider range of services, facilities and economic potential/ employment opportunities, and provides the opportunity for ’20-minute neighbourhood’ principles to be developed. Category 2 Settlements are still considered to be Local Service Villages, but they are larger. The average population size for a Category 2 settlement is 939 residents and 434 dwellings. Ettington is home to 1,039 residents and 424 dwellings (all figures based on Census 2011 data). Ettington is therefore of a similar scale when compared to the current Category 2 settlements which are identified to accommodate higher growth levels set in the Stratford-on-Avon Core Strategy.
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Q-H3: 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.
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Q-H2.2: A tricky one for the partnership to answer. At this stage optiont H2-2B feels most appropriate. First option is much too broad and third option could lead to clusturing of affordable housing in certain areas rather than creatin g wider inclusive society. Q-H5: the other options [H5a and H5b] are too prescriptive and could potentially result in them versus us developments
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Our overall contention is that housing requirement and future land supply for South Warwickshire have not been accurately judged. This matters because the erroneous estimate by Coventry of 32% population growth has led to blighting of countryside areas in S Warwickshire to meet a need that never materialized. Coventry estimated that 85% of overseas students would remain post-study. The average figure is 15%. The 2021 ONS Census numbers show that 17-18,500 fewer households live in Coventry than the City estimated. (But the houses have still been built…) WE BASE OUR CONCLUSIONS ON SIX KEYPOINTS FROM GERALD KELLS’ REPORT. 1. WINDFALLS • The SWLP allows for land for 220 dwellings per annum (DPA) from windfalls. • Actual annual average windfall numbers since 2011 have been 901. • 69% of Stratford’s housing site needs since 2011 have been met from Windfalls; 44% of Warwick’s. • If instead of 220 DPA’s (as in plan) the SWLP assumed only half the annual average, (450 homes) the housing land shortfall drops from 23,000 to 1510 in 2040; 5,410 in 2045 and 9310 in 2050. • If the actual average since 2011 – 901 - is used, the plan is in surplus: 5,255 excess house spaces in 2040; 3610 excess in 2045. 1965 in 2050. • In addition to a severe underestimate of overall numbers, the Local Planning guidance only includes within the 220, those spaces for fewer than 9 dwellings. So places like the Ford Foundry site, the King’s High School sites, land adjacent to Leamington Spa Station, and others for more than 9 homes would not be included. • We believe that this also seriously distorts likely available land, based on figures since 2011. 2. AFFORDABILITY UPLIFTS • Under a formula devised in 2004, housing numbers are automatically increased in more expensive areas, on the assertion that building more houses will bring down prices. • This has nothing whatsoever to do with actual housing need. • ONS numbers from the base year used (2014) assessed the SWLP area need at 874homes. The Affordability formula increases this to 1,239. These are the numbers used in the SWLP. • This is an increase of 42% over need. 2. IN-MIGRATION • Housing numbers like Coventry’s encourage net in-migration to local areas. They are not a response to endogenous growth. • 76% of Warwick’s estimated population growth for 2018-2028 comes from net inmigration. • 118% of Stratford’s is from the same source. (ie. Just on birth rate, without inmigration, the population would decline). • This therefore risks becoming a self-replicating cycle. (“We’ve filled more houses, therefore we need more houses, therefore…”) 3. DUTY TO CO-OPERATE • Housing was built in the SWLP area as a response to Coventry’s overestimates, destroying swathes of prime farmland in the process. • This is part of the ‘Duty to Cooperate’ imposed on neighbouring areas, when the ‘growing’ area does not have the requisite space. • The government has added 35% to assessed need in 20 key cities. (In theory this means that more urban brownfield sites are used.) Applying this to Birmingham gives them three times their demographic need. • Birmingham (for whom Gerald has also produced an excellent report) does not have space for these numbers. • This potentially means that over the plan period South Warwickshire will have to build houses they don’t want for a Birmingham need that doesn’t exist. • The Black Country (also subject to one of Gerald’s Reports) has currently abandoned its Local Plan for similar reasons. 4. EMPLOYMENT LAND NEEDS • We would ask those responsible for the SWLP to reconsider Employment land needs. • Numbers don’t reflect the estimated 30% reduction in office space post-Covid. • There is also a visible increase in Town Centre vacant retail sites across the region. • In particular, Stratford is estimated to need 132.8Ha (333 acres) of Industrial Land. • This puts it only behind Rugby (Cement and extraction) and Coventry (automotive). • We have asked for an explanation of how this number was derived. 5. TIMEFRAME • The SWLP framework extends from 2025 to 2050, to allow for long-term infrastructure planning. • This is considerably longer than most planning frameworks. • Increasing the plan from the more usual 15 years, increases SWLP housing numbers by 50%. (And therefore countryside blight). • Remaining with 15 years, instead of 35,000 houses by 2050 we would be looking at 23,370 by 2040. For the above six reasons, and so that more agricultural and greenbelt land is not needlessly destroyed, we ask that those responsible reconsider the base assumptions underpinning the South Warwickshire Local Plan, and take serious note of Gerald Kells’ more detailed statistical evidence, from which this summary is derived.
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2.3.1 The housing and employment needs that the SWLP needs to respond to should be clearly set out in future consultations. The I&O document is heavily focused on the results of previous consultations (which could have been reported on separately to help focus the main document on the proposed content of the Local Plan) and the spatial strategy. The I&O document puts forward some potential options for growth but does not set this within the context of how much additional growth needs to be accommodated to supplement existing commitments– including the potential for a significant amount of growth arising from the Greater Birmingham and Black Country Housing Market Area (HMA), over the period 2031 to 2050. Future needs from Coventry will also need addressing. Any consultation about how best to meet needs is potentially premature when the scale and origin of that need, allowing for existing commitments, is not clearly set out.
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2.13 Housing Need (H1.1) 2.13.1 Paragraph 61 of the NPPF notes that: “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.” 2.13.2 The NPPF mandates the use of the 2014 subnational household projections (SNHP) in the Standard Method. The Coventry & Warwickshire Housing & Economic Development Needs Assessment (HEDNA) sets out the rationale for deviating from this approach, because of historic overestimation of the population of Coventry. The HEDNA adopts a trend-based projection and this approach is supported. 2.16 Minimum Space Standards (H3) 2.16.1 H3a and H3b relate to the provision of minimum space standards. The minimum space standards have applied to permitted development since September 2020. The requirement for all development to meet the minimum space standards is supported (H3b). 2.16.2 H3c suggests including a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. This approach is supported but any requirement would need to be evidenced based and subject to viability testing. 2.18 Custom built housing (H5) 2.18.1 Question H5 explores options relating to the provision of sites for self-build and custom homes (H5a - identify specific sites, H5b - require large sites to provide a proportion of custom housing, H5c – case by case basis). The requirement for larger sites to include a proportion of self build and custom housing on site will help ensure that sites for self build and custom build homes are brought forward with the necessary infrastructure in place, H5b is therefore supported. 2.19 Delivering Homes in South Warwickshire (H7) From a review of the I&O document and supporting evidence base the key points in relation to delivering homes in Warwickshire are: The SWLP must avoid being too strategic and focussing on strategic allocations – it must provide a spatial strategy with sufficient granularity for the whole of the plan area. It must provide a balanced portfolio of sites – ensuring a continuous supply of deliverable and developable sites over the plan period (avoiding over reliance on strategic sites that may not start delivering housing until the second quarter of the plan period). It should identify a range of housing sites that will meet future needs, including affordable housing – rather than relying on LP2s and NDPs. The evidence base should be reviewed to ensure a consistent approach to the identification of sustainable locations for growth across the plan area, this includes revisiting the settlement hierarchy.
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Q-H5: 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, Stansgates 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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Q-H2.2: JPC supports option H2.2c The HEDNA analysis indicates that half of all housing growth results from a shortage of affordable homes. Henley is one of the most expensive towns in the region. Achieving a higher number of affordable homes, suitable for younger people and families in particular is a major challenge. The plan is very long on aspirations, but very short on practical steps and the way these homes are going to be made more affordable, as well as increasing in quantum has to be a central part of the next phase of the plan. No housing target should be ratified without a fully funded strategy for affordable homes in high price settlements. If this is not possible the housing target for Henley/Beaudesert should be reduced accordingly. Q-H3: This policy should be dealt with in Part 2 Q-H5: Premature defer to part 2 Q-H6: The JPC supports option H6c but that detailed policies are premature so should be deferred to Part 2 Q-H7: The demand and need in the plan is 50% for affordable homes. The problem of providing affordable homes in high land and house price areas has proved intractable nationally so that affordable and social housing numbers have declined sharply. In Henley and the surrounding villages is by discounted land or public subsidy. When the SWLP announces proposed targets it must indicate the proportion of affordable homes associated level of subsidy Homes England will allocate to areas such as the JPC . A number of residents have also noticed that there is no reference at all to social housing.
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Q-H1-1 and H1-2 35. Richborough Estates’ comments on the HEDNA and the general housing requirement are included in the submission made by Marrons and are not repeated. Q-H3 40. The space and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-H4-1 to H4-3 41. Richborough Estates’ comments on this Local Plan helping to meet the housing needs from outside South Warwickshire are included in the submission made by Marrons and are not repeated. Q-H5 42. Delivering custom homes, or self-build plots, has been awkward on general housing sites because those seeking to build their new home do not want to be on such developments. In most cases, the demand for these types of plots has been low. Such developments can have design constraints imposed through, for example, Design and Access Statements and Design Codes, which stifle the aspirations of the self-builder (e.g. their Grand Design). Instead, the more successful custom and self-build schemes have been smaller sites and it would, therefore, be appropriate for the Local Pan to establish a policy framework for the allocation of such sites in Part 2 Local Plans and Neighbourhood Plans.
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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. 4.15. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified.” 4.16. Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: 4.17. “Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.” 4.18. If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. 4.19. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H5: Please select all options which are appropriate for South Warwickshire 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 development 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 4.20. As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016- 20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. 4.21. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. 4.22. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. 4.23. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. I&O. 4.24. The HEDNA evidence and Self-Build Register for both authorities should form part of the evidence base that informs any emerging policies that deal the delivery of selfbuild/custom plots on applications for residential development. If the Plan is going to require a % of self-build plots this must only be limited based on the current evidence available.Further, if there is a policy requiring self/custom build on major sites then it is nevertheless submitted that it should include a mechanism to allow for such plots to come forward for market housing if demand is subsequently found to be absent. For example, if serviced plots for self-build and custom housebuilding have been made available and marketed for a set period of time and have not sold, plots can be used for delivery of general market housing.
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Q-H1-1 and H1-2 37. Richborough Estates’ comments on the HEDNA and the general housing requirement are included in the submission made by Marrons and are not repeated. Q-H3 42. The space and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-H4-1 to H4-3 43. Richborough Estates’ comments on this Local Plan helping to meet the housing needs from outside South Warwickshire are included in the submission made by Marrons and are not repeated. Q-H5 44. Delivering custom homes, or self-build plots, has been awkward on general housing sites because those seeking to build their new home do not want to be on such developments. In most cases, the demand for these types of plots has been low. Such developments can have design constraints imposed through, for example, Design and Access Statements and Design Codes, which stifle the aspirations of the self-builder (e.g. their Grand Design). Instead, the more successful custom and self-build schemes have been smaller sites and it would, therefore, be appropriate for the Local Pan to establish a policy framework for the allocation of such sites in Part 2 Local Plans and Neighbourhood Plans.
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Q-H1-1 and H1-2 37. Richborough Estates’ comments on the HEDNA and the general housing requirement are included in the submission made by Marrons and are not repeated. Q-H3 42. The space and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-H4-1 to H4-3 43. Richborough Estates’ comments on this Local Plan helping to meet the housing needs from outside South Warwickshire are included in the submission made by Marrons and are not repeated. Q-H5 44. Delivering custom homes, or self-build plots, has been awkward on general housing sites because those seeking to build their new home do not want to be on such developments. In most cases, the demand for these types of plots has been low. Such developments can have design constraints imposed through, for example, Design and Access Statements and Design Codes, which stifle the aspirations of the self-builder (e.g. their Grand Design). Instead, the more successful custom and self-build schemes have been smaller sites and it would, therefore, be appropriate for the Local Pan to establish a policy framework for the allocation of such sites in Part 2 Local Plans and Neighbourhood Plans.
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Q-H1-1 and H1-2 34. Richborough Estates’ comments on the HEDNA and the general housing requirement are included in the submission made by Marrons and are not repeated. Q-H3 39. The space and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-H4-1 to H4-3 40. Richborough Estates’ comments on this Local Plan helping to meet the housing needs from outside South Warwickshire are included in the submission made by Marrons and are not repeated. Q-H5 41. Delivering custom homes, or self-build plots, has been awkward on general housing sites because those seeking to build their new home do not want to be on such developments. In most cases, the demand for these types of plots has been low. Such developments can have design constraints imposed through, for example, Design and Access Statements and Design Codes, which stifle the aspirations of the self-builder (e.g. their Grand Design). Instead, the more successful custom and self-build schemes have been smaller sites and it would, therefore, be appropriate for the Local Pan to establish a policy framework for the allocation of such sites in Part 2 Local Plans and Neighbourhood Plans.
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Q-H1-1 and H1-2 35. Richborough Estates’ comments on the HEDNA and the general housing requirement are included in the submission made by Marrons and are not repeated. Q-H3 40. The space and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-H4-1 to H4-3 41. Richborough Estates’ comments on this Local Plan helping to meet the housing needs from outside South Warwickshire are included in the submission made by Marrons and are not repeated. Q-H5 42. Delivering custom homes, or self-build plots, has been awkward on general housing sites because those seeking to build their new home do not want to be on such developments. In most cases, the demand for these types of plots has been low. Such developments can have design constraints imposed through, for example, Design and Access Statements and Design Codes, which stifle the aspirations of the self-builder (e.g. their Grand Design). Instead, the more successful custom and self-build schemes have been smaller sites and it would, therefore, be appropriate for the Local Pan to establish a policy framework for the allocation of such sites in Part 2 Local Plans and Neighbourhood Plans.
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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? Coventry City Council welcomes and supports this proactive approach to meeting the needs of the sub-region. The council supports the evidence provided by the HEDNA and considers it a reasonable basis for identifying levels of housing need across the Coventry and Warwickshire Housing Market Area.
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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. 55. Rosconn Strategic Land support Option H5a, and the identification of a range of sites. Stratford-on-Avon District Council has already identified suitable and sustainable sites for allocation for self and custom build homes as part of its emerging SAP, and there is no need for the Councils to undo the work already undertaken.
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Education The provision of education facilities should be a major priority when delivering new housing. Ensuring families moving into new housing can access local education places is crucial to ensuring sustainable development, supporting active travel, and building a community early on. The Local Plan should give great consideration to prioritising the early delivery of new school infrastructure where required and should give due consideration to the longterm sustainability of the community
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4.83 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. 4.84 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-H2-2: Please select the option which is most appropriate for South Warwickshire: 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-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? 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. 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. 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 interrelationships with Solihull and Redditch boroughs and Bromsgrove district. Through the Duty to Co-operate, South Warwickshire has a responsibility to help address unmet needs. 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. 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. 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-H2-2a We consider that with a single plan for South Warwickshire, combined as a unified policy area, there should be a single South Warwickshire wide affordable housing requirement – both in terms of threshold and percentage requirement. Issue H3: Providing the right size of homes Q-H3a. We would support option H3a – which does not seek to include minimum space standards in a policy. We would agree that this is not of strategic importance across South Warwickshire and so could be considered in Part 2 of the plan, and assessed against evidence provided that it is a requirement within the District that would not impact of the affordability of properties. Issue H5: Providing custom and self-build plots Q-H5a and c The Self-build and Custom Housebuilding Act 2015 (as amended) places duty on Councils to keep a register of individuals and associations of individuals and associations of individuals who wish to acquire serviced plots of land to bring forward self-build and custom housebuilding projects. They are also required to have regard to this register and grant enough development permissions to serviced plots of land to meet the identified demand, where the demand is dictated by the number of entries on the Council’s Self-build register within each base period. The Planning Policy Guidance (PPG) states that self-build or custom builds helps to diversify the housing market and increase consumer choice. In such types of projects, the initial homeowners choose the design and layout of their home, allowing for innovative creativity. On this basis, we consider that the Council should give proper consideration to the identification of a range of specific sites on the edge of existing settlements to be developed for self and custom build homes. This is preferable to requiring large developments (over 100 dwellings) to provide a proportion within the overall site. This would not be appealing to most national house builders and difficult to implement in policy terms. Wyre Forest’s recently adopted Local Plan (SP12) includes a specific policy requiring major development schemes of 50 or more dwellings to “take into consideration the demand shown in the Self-Build and Custom- Build register and where possible provide suitable plots.” Where plots are made available and marketed for at least 12 months, and there is no demand – they may be built out by the developer.
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Q-H1.1: The Standard Method calculation identifies a need for 5,554 dwellings annually across Coventry and Warwickshire whilst the new trend-based projections point to a need for 4,906 dwellings annually across the sub-region. This is lower than the 5,554 per annum Standard Method figure due to the recognised issues with population data which have informed previous projections for Coventry. Based on the trend based approach, Stratford would plan for 868 dwellings per annum (against a LHN of 564 dwellings per annum) and Warwick would plan for 811 dwellings per annum (against a LHN of 675 dwellings per annum). The overall housing figure would result in 1,679 dwellings per annum being provided across South Warwickshire. Gladman support the choice of the Councils to consider a trend-based projection housing need and accommodate a proportion of unmet need from Greater Birmingham and the Black Country, and Coventry alongside the 2014-based projection. This approach would also support the delivery of much needed affordable housing in South Warwickshire. Stratford-upon-Avon has an affordable housing need of 129 dwellings per annum and Warwick a need of 258 dwellings per annum. The higher trend based requirement for the individual Councils presents a greater chance for this affordable housing need to be met. Q-H3: Please select all options which are appropriate for South Warwickshire with minimum space standards. Gladman support Option H3b as it is based on locally derived evidence. Any policy drafted that requires all new dwellings to be built to the nationally described space standards (NDSS) should note that the PPG is clear that “where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies.” Gladman also consider Option H3c a suitable option. This recognises that Building Regulations M4(2) and M4(3) are optional, and the PPG provides additional guidance on the use of these optional standards. Gladman encourage the Council to ensure that this policy is robust in its justification by accounting for the factors within the PPG. Gladman would welcome the flexibility in any requirement where viability is an issue but note that the baseline requirement should be set so that this is not necessary. Q-H5: Please select all options which are appropriate for South Warwickshire with regard to self-build and custom housing. Gladman consider that Option H5b presents the most suitable approach to custom and self-build housing. However, Gladman recommend that the policy wording includes a mechanism for the plots to be delivered as traditional market housing should there be no interest in the plots following 12 months of marketing.
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Q-H2-2: Please select the option which is most appropriate for South Warwickshire It is considered that Option H2-2b to include separate affordable housing requirements for Stratford-on-Avon and Warwick Districts is the most appropriate. This will ensure that different markets and affordable needs between the two Districts, as well as local viability issues can be taken account of. It is not considered that Option H2-2c would be appropriate as this will generate uncertainty for developers seeking to invest in the South Warwickshire housing market. It will be important that any affordable housing threshold set within policy is subject to viability to ensure that specific site conditions are taken account of and that the need for affordable housing does not threaten the delivery of housing overall within the South Warwickshire area. Q-H3: Please select all options which are appropriate for South Warwickshire It is considered that Option H3a not to include minimum space standards in a policy in the SWLP is the most appropriate option. Footnote 49 to Paragraph 130, part f) of the NPPF states that policies should only make use of nationally described space standards “where the need for internal space standards can be justified .” No justification for considering the use of national space standards has been included within the Issues and Options consultation document, or its evidence base. As such, it is not appropriate to include a policy on space standards within the South Warwickshire Local Plan. Notwithstanding the above, the consideration of space standards is not a strategic matter for consideration within the Part 1 Local Plan. Q-H5: Please select all options which are appropriate for South Warwickshire It is considered that Option H5b is the most appropriate solution for self and custom build homes IF a need can be demonstrated. It is considered that introducing a threshold would provide certainty to developers. However, the suggestion of a threshold of 100 dwellings is not supported. There is no evidence located within either the Issues and Options document or its evidence base to support either the need for self and custom build homes or the viability of the suggested threshold. Evidence must be provided to support both of these matters. Notwithstanding the above, any policy should be caveated that following a 12 month marketing period, any plots which have not been taken on may be delivered by the developer. Q-H7: please add any comments you wish to make about delivering homes in South Warwickshire. The Urban Capacity Study shows a very substantial shortfall in identified sites for housing, which may be considerably worse if the new trend-based housing projections are applied. Either way, brownfield land alone will not solve the local housing supply shortfall, this will need substantial releases of greenfield land, which should be focussed around sustainable settlements, each taking a fair share for good sustainable dispersed growth. In Stratford District, outside of the main conurbation, there are 8 MRC’s of which only 5 including Kineton are outside Green Belt. Kineton should therefore plays it part in meeting the housing numbers, especially as the KNP identified an allowance of 200 reserve plots for this very purpose. Now that a more detailed study of those sites identifies a shortfall of 95 dwellings, then the land on Banbury Road, identified as more suitable and with a capacity of up to 50 by the SDC Landscape Sensitivity Study 2011 and Appeal decision 2016, should be the natural replacement as set out above.