Q-H6: Please select all options which are appropriate for South Warwickshire
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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 identif ied 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 Warwick District, outside of the main conurbation, there are 8 major villages, of which Bishops Tachbrook is one of only 3 that are not within the Green Belt. If the village landscape is consistently re-assessed, the land to the South East would be the next logical choice for a suitable allocation as set out above.
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Q-H5 - 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. 58. 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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Q-H2-2: Option H2-2a: A single South Warwickshire wide affordable housing requirement It would seem sensible for a common approach to be the starting point. Q-H3: Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. This would be dependent on being able to evidence a need for these requirements across South Warwickshire, without having an unacceptable impact on affordability of properties. It may be considered strategically important when considering the capacity of strategic sites. This should be the starting point although we do not understand what, “based on locally derived evidence means”. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. This approach would be supported but needs to be applied flexibly because of potential impacts on design and viability. Q-H5: 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 would seem to be the most appropriate option with support where there is either an identified shortfall across the plan area generally or specifically where a shortfall within a specific locality. Our clients site at Chessetts Wood Road could be well-suited to provide self/custom build housing.
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Chapter 6- Homes Generally – there are several uses of the term ‘sustainable communities’. We suggest that the consultation document should include a definition of this phrase. H5- Self-build options We support options 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.) and H5b (Require large developments of, say, over 100 homes to provide a proportion of self and custom-build homes within the overall site.) Option H5c is not suitable as it would not give the certainty that any plots would be delivered. We also suggest that both councils advertise the existence of self build sites.
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QH2.2Please select the option which is most appropriate for South Warwickshire: 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. QH3Please select all options which are appropriate for South Warwickshire: This policy should be dealt with in Part 2. QH5Please select all options which are appropriate for South Warwickshire. Premature defer to part 2. QH6 Please select all options which are appropriate for South Warwickshire: The JPC supports option H6c but that detailed policies are premature so should be deferred to Part 2. QH7 Please add any comments you wish to make about delivering homes in South Warwickshire: 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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QH.6 and H.7 There are many existing travellers sites which are clearly not being used by the travelling community. Many sites have brick built accommodation which houses residents who do not travel.
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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-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-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-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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Issue H2: Providing the right tenure and type of homes 40. The HEDNA considers the Coventry and Warwickshire Housing Market Area to be a coherent housing market area and a ‘best fit’ functional housing market area. This important when considering the link between new jobs and new housing the best fit for the HEDNA. The HBF views on the use of the trend-based housing need and requirement figures suggested by the HEDNA are detailed in the comments on the Sustainability Appraisal above. National Described Space Standards (NDSS) 41. If the Councils wish to apply the optional NDSS to all dwellings, then this should only be done in accordance with the NPPF (paragraph 130f & Footnote 49) which states that “policies may also make use of the NDSS where the need for an internal space standard can be justified”. As set out in the NPPF, all policies should be underpinned by relevant and up to date evidence, which should be adequate, proportionate and focussed tightly on supporting and justifying the policies concerned. 42. PPG (Ref ID: 56-020-20150327) identifies the type of evidence required to introduce a policy on NDSS. It 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. 43. The Councils will need robust justifiable evidence to introduce the NDSS, based on the criteria set out above. The HBF considers that if the Government had expected all properties to be built to NDSS that they would have made these standards mandatory not optional. 44. The HBF would also remind the Councils that there is a direct relationship between unit size, cost per square metre (sqm), selling price per sqm and affordability. The policy approach should recognise that customers have different budgets and aspirations. An inflexible policy approach to NDSS for all new dwellings will impact on affordability and effect customer choice. Well-designed dwellings below NDSS can provided a good, functional home. Smaller dwellings play a valuable role in meeting specific needs for both open market and affordable home ownership housing. 45. An inflexible policy approach imposing NDSS on all housing removes the most affordable homes and denies lower income households from being able to afford homeownership. The introduction of the NDSS for all dwellings may mean customers purchasing larger homes in floorspace but with bedrooms less suited to their housing needs with the unintended consequences of potentially increasing overcrowding and reducing the quality of their living environment. The Council should focus on good design and usable space to ensure that dwellings are fit for purpose rather than focusing on NDSS. Issue H3: Providing the right size of homes 51. The consultation includes Table 12 which sets out suggested housing size mix as follows: Stratford-on-Avon Market Ownership • 1 bed 10% • 2 bed 35% • 3bed 40% • 4 bed 15% Warwick Market Ownership • 1 bed 10% • 2 bed 40% • 3bed 40% • 4 bed 10% Stratford-on-Avon Affordable Home Ownership • 1 bed 20% • 2 bed 45% • 3bed 25% • 4 bed 10% Warwick Affordable Home Ownership • 1 bed 20% • 2 bed 45% • 3bed 25% • 4 bed 10% Stratford-on-Avon Social/Affordable Rented • 1 bed 40% • 2 bed 35% • 3bed 20% • 4 bed 5% Warwick Social/Affordable Rented • 1 bed 40% • 2 bed 35% • 3bed 20% • 4 bed 5% 52. The HBF agrees with the HEDNA observations that these percentage figures should be used as a monitoring tool rather than being applied rigidly to all individual development sites. The HBF agrees that consideration should also be given to the existing house mix in the locality, site location and characteristics, local needs and market evidence. Any policy on housing type and mix should include flexibility that would allow for negotiations to consider viability and other site-specific considerations on a case by case basis if required to ensure delivery and/or viability of a particular scheme. 53. The requirements to meet Part M4(2) will be superseded by changes to residential Building Regulations. The Government response to ‘Raising accessibility standards for new homes’ states that the Government proposes to mandate the current M4(2) requirement in Building Regulations as a minimum for all new homes, with M4(1) applying in exceptional circumstances. This will be subject to a further consultation on the technical details and will be implemented in due course through the Building Regulations. The requirement to address this issue is planning policy is therefore unnecessary. 54. There is also a need to differentiate between Part a) and part b) of M4(3) technical standards. M43a sets out standards for wheelchair adaptable housing, where M43b relates to wheelchair accessible housing which can only be required on affordable housing where the Council has nomination rights. 55. The HBF notes the observations about the potential of bungalows. However, bungalows can impact on viability so robust testing of any policies will be needed to ensure housing schemes remain viable and deliverable. Any policy should also include the flexibility to allow for consideration of site any specific issues. Issue H5: Providing custom and self-build house plots 62. The HBF considers that a policy which encourages self and custom-build development and sets out where it will be supported in principle would be appropriate. The HBF considers that the Councils can play a key role in facilitating the provision of land as set in the PPG. This could be done, for example, by using the Councils’ own land for such purposes and/or allocating sites specifically for self and custom-build home builders- although this would need to be done through discussion and negotiation with landowners. The HBF does not consider that requiring major developments to provide for self-builders is appropriate.
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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-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-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-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-H3 41. 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-H5 43. 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-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-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-H5: Self-builds must rely on a case-by-case approach as the need for policy requirements and criteria to ensure suitability, sustainable locations, and sensitivity to the local community’s needs.
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I am writing to let you know that I strongly oppose the development of more housing in Henley. The appeal of Henley is that it has beautiful countryside walks either side - whether that be walking up the mount or the beautiful walk under the railway bridge on Brook end drive. These areas are so important for our wildlife when we're being called to re-wild our towns and villages. Henley cannot support such a vast increase in housing. The high street is already so busy that it is a danger at times for children walking especially as so many recklessly park outside the co-op blocking views for pedestrians and drivers. I don't understand why the focus is T on and around Stratford instead of Henley. We don't want our town to be the size of Stratford. You are proposing building on green belt. How is this even being proposed when climate change is such an issue. Biodiversity is crucial to our future. Henley is big enough. Have you tried driving to work in the morning at the traffic lights? If you propose to double the size of Henley this alone would cause havoc. Please, please reconsider this.
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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. This should be the starting point although we do not understand what, “based on locally derived evidence means”. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. This approach would be supported but needs to be applied flexibly because of potential impacts on design and viability. 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. This would seem to be the most appropriate option with support where there is either an identified shortfall across the plan area generally or specifically where a shortfall within a specific locality.
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Q-H3: Minimum Space Standards 50. Whilst the provision homes of an appropriate range and size is supported, William Davis are concerned that the blanket application of Nationally Described Space Standards across South Warwickshire could significantly and negatively impact viability in areas with high levels of unaffordability. There are already substantial existing and emerging policy and building regulations requirements (e.g. biodiversity net gain and future homes standard), combined with fluctuations in the housing market and construction costs that are impacting development viability. The cumulative effects of all proposed plan policies will need to be viability tested, in accordance with national policy. The result may be a choice between policies such as minimum space standards and a lowering of the affordable housing requirement relative to existing expectations.
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To maintain Kenilworth as a vibrant community where people can choose to live, work or learn it is essential that we have the right mix of housing. The apparent current preference for large 4/5 bedroom properties risks destroying this. If further development in Kenilworth is to take place, we would like to see it significantly weighted to create a more diverse property mix overall including more 1 and 2 bed starter properties and bungalows and truly affordable housing.
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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: '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 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-principal 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 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 H3: Providing the right size of homes Hermes’ preference is for option H3a, which does not seek to include minimum space standards in a policy in the SWLP, as this is not a strategic policy, and if necessary minimum space standards could be considered in a Part 2 plan.
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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: '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 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. 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. 4.22. 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. 4.23. 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. This should be reflected in a specific selfbuild and custom housing policy. 4.24. This Site is identified as a self-build and custom housing site in the most recent Stratford SAP Preferred Options document (see policy reference SCB.3). This allocation should be carried forward to the South Warwickshire Local Plan to ensure alignment and consistency between Plan documents and to ensure that this specific type of housing is delivered by the South Warwickshire Plan.
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Housing Numbers A fundamental driver for additional development is housing pressure. This derives from a national picture and government methodologies. These can be seen as transient: future population estimates have emerged to be flawed and the Government’s long term approach presently seems uncertain. For South Warwickshire, the Housing Market Area including demand from West Midlands conurbations and the ‘duty to cooperate’ have promoted a need based on migration to South Warwickshire rather than organic growth from local communities. This is at odds with the overarching principles - most notably zero carbon (despite home working trends) and a 'commuter belt' characteristic has resulted. Turning to the target numbers themselves, the HEDNA notes that the Coventry population growth has been overestimated for some time and that asserts that the Government’s ‘trend based analysis’ can be justified. This would reduce the numbers in Coventry but increase in it surrounding districts. It seems in South Warwickshire, we have been granting permissions and building to meet to need of the combined housing market area including Coventry. In Stratford District the A46 corridor to Stratford and the area around Southam have seen very high percentages of building. Unsurprisingly, these houses are being occupied giving a trend of increasing population. To continue the trend which we now know to be flawed seems unwise. We believe that the figure of 868 homes a year has scant justification and is excessive. As well as the prospect of a review of the duty to cooperate, central government are apparently consulting toward allowing recent over provision to offset future dwelling numbers. Stratford has over provided by 42% since 2016. It may be noted that the new target of 868 represents a very similar target number to that of the last seven years in total, so the new target suggest a continuity of house growth targets. yr end built 'Old' target HEDNA target 16 1048 566 185.16% 868 120.70% 17 1114 894 124.61% 868 128.30% 18 1293 894 144.63% 868 149.00% 19 1386 894 155.03% 868 159.70% 20 1458 894 163.09% 868 168.00% 21 752 894 84.12% 868 86.60% 22 1568 730 214.79% 868 180.60% 8619 5766 149.48% 6076 141.90% Locations Determination of the location of new any settlement is likely to be problematical, not least because of the area of restraint of the Green Belt and AONB. This should not be a reason to confine all proposals to the remaining areas. There are upward of 16 potential settlement sites already indicated in the consultation. We emphasise that this response relates to principles rather that any of the 'sketched-in' locations, many of which can be evidenced to be unsuitable even at this early stage. Self build This is increasingly a developer led loophole in regulations which is being used to create unsuitable housing developments as an unintended consequence of the 2015 Custom and Self Building Act. The plan should address this. Affordable Homes There are concerns about how we can achieve the required level of affordable homes and avoid a developer driven approach. Looking a current practice, we have allowed developers to water down the 35% on viability grounds, and this process is insufficient to meet demand for this category of housing. It is be noted that the Government defined 'affordable housing' is for houses of up to 80% of market rents, can be up to nearly 40% more than social rents and may not be affordable at all to local people. So this problem is significant and should be a major factor in the plan. Although the debate throughout was largely influenced and driven by controversial housing numbers, commercial and business redevelopment does figure, but appears to be led by large developments (eg auto related) and tourism. Do we neglect the wider basis at our peril? Is it wise to ‘suck in’ more big facilities into relatively rural districts which expand housing demand in those rural areas?
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Q-H2.2: Option H2-2a or Option H2-2c. It would not seem useful to have different policies for the two LPA areas when this is a combined Local Plan. Q-H3: Option H3c: We feel that consultation with the population is essential to the development of plans. The County Council is currently carrying out a Joint Strategic Needs Assessment (JSNA) of the care and accommodation needs of older people. For awareness the JSNA is not a consultation document. We suggest that the findings are considered in planning for South Warwickshire. As part of this, we would want the plan to be informed by trends in the uptake of different kinds of support (e.g., Domiciliary Care at home; ECH; Care Homes etc) and in the unmet need and service gaps. Partnership working across district and county council is critical to success. We recommend that we continue to develop and maintain strong working relationships and strategic alignment to explore housing with care needs and the future planning needs. This would ensure housing with care developments are in line with other developments and plans for the local area. Housing with care covers both specialised supported housing and extra care, we note that in the consultation documents there is little reference to specialised supported housing and to people with disabilities. We recommend this is looked at in the remit of housing with care within the local plan and this should also be extended to include, for example but not limited to, those with mental health issues as this is an area of growing demand. Housing with care schemes for people with disabilities would clearly have the majority of spaces built to Building Regulations M4(2)/M4(3) standards. WCC has noted that the HEDNA does not specify details regarding the housing needs for other people with support needs e.g., Safe Accommodation, Learning disabilities, Autism, Mental Health, care leavers etc. WCC would therefore be happy to be involved in the later stages of the consultation to influence representation of these areas. There is strong evidence to suggest that poor space standards in housing can have an adverse impact on health and wellbeing. Therefore, a proportionate baseline would be that all new homes should be built to Nationally Described Space Standards, and a reasonable proportion M4(2 and 3). Again, WCC would welcome engagement on this at a later date as to what would be an appropriate proportion. Broadly aiming for both H3b and H3c would be a sensible ambition. E.g., H3c as a target, and H3b as the fallback position if developer viability demonstrates that only a proportion/ no M4(2 and 3) homes can be delivered. Q-H5: Option H5b seems to be the most deliverable. Q-H6: Options H6a and H6c seem to be the most deliverable.
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Use only brownfield sites; re-examine the projections on which housing needs are based; more social housing, and less building/re-developing of large homes with multiple living rooms in the £500,000+ bracket, meet modern standards of sustainability and energy saving. Promote green corridors and spaces within developments; develop country parks within reach of all significant settlements; protect historic and wildlife sites.
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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: '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 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 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.