Preferred Options 2025

No

Representation ID: 108806

Received: 07/03/2025

Respondent: Barratt David Wilson Homes (Mercia)

Agent: Savills

The SWLP will be examined against 2024 therefore there is no justification to use the HEDNA (2022) as a basis of calculating the housing need for the South Warwickshire area. Instead, in order to comply with national planning policy requirements, the latest standard method calculation figure for South Warwickshire is deemed to be the correct figure to be used in determining the number of homes needed. This results in a minimum requirement of 54,700 dwellings across the Plan period.
To ensure that the SWLP strategy is robust it should be actively accommodating evidenced shortfall from Coventry and Birmingham, in addition to the standard method
requirement for Warwick and Stratford-on-Avon Districts.
Barratt David Wilson Homes Mercia supports the proposed strategic approach of focusing the majority of the additional development needed to meet the housing requirement in large scale extensions to urban areas, in accordance with the approach to identification of Priority Areas set out in Figure 5 of the Preferred Options consultation document and, importantly, supplemented by additional development in new settlements. The proposed Strategic Growth Strategy Options identified in Figure 6 of the Preferred Options consultation document however need to be refined in order to ensure that development opportunities adjacent to the main settlements, notably those in close proximity to railway stations, including at SG07, are being optimised. The approach taken in relation to the location within and adjacent to SG07 is considered further within the site-specific representations made by Barratt David Wilson Mercia in relation to the land it is promoting between the Birmingham Road and Grand Union Canal, immediately to the north west of Warwick Parkway Railway Station.
Barratt David Wilson Homes Mercia also wishes to highlight that the SWLP development strategy should also include smaller sites at sustainable settlements across the SWLP area to enable sufficient variety in the size and number of housing sites allocated. Such smaller sites can be more readily deliverable than large-scale extensions
and new settlements in order to ensure that housing needs are met where and when they arise. If the SWLP continues to be progressed through a 2-part Local Plan process, with smaller allocations made through the Part 2
Plan, then it is considered that the Part 1 SWLP should include a mechanism for supporting the development of sustainable sites adjacent to settlements in advance of the adoption of the Part 2 Plan.

Other

Representation ID: 108807

Received: 07/03/2025

Respondent: Barratt David Wilson Homes (Mercia)

Agent: Savills

Barratt David Wilson Homes Mercia supports the inclusion of new settlements within the development delivery strategy for the SWLP. It is however clear that not all of the new settlement and strategic growth locations identified within the Preferred Options consultation document will be required to meet the SWLP housing requirement identified for the Plan period. It is therefore recognised that a sifting process will need to be undertaken to ensure that the strategic sites which are ultimately allocated are suitable, sustainable, deliverable and fit with the wider vision for the SWLP.
The contribution made by specific sites to this process is considered further within the site-specific representations made by Barratt David Wilson Mercia in relation to the land it is promoting between the Birmingham Road and Grand Union Canal, immediately to the north west of Warwick Parkway Railway Station. Notably these representations challenge: the appropriateness of allocating a new settlement at Hatton; the consistency of the assessment given to the proposed new settlement at Hatton within the evidence base reporting (including within the New Settlements HELAA (Part A) Assessment Results and Bespoke New Settlement Analysis); and the approach taken to the consideration of appropriate alternative sites in this location.

No

Representation ID: 108808

Received: 07/03/2025

Respondent: Barratt David Wilson Homes (Mercia)

Agent: Savills

Policy Direction 7 needs to be amended to take full account of the provisions of NPPF paragraph 148, which identifies the need to give priority to previously developed land, then consider grey belt which is not previously developed, and then other Green Belt locations. Genuine regard should be given to the potential of both Green Belt and non-Green Belt sites through the evidence base assessments, including within the Sustainability Appraisal, to ensure that a robust assessment of potential alternative options has been undertaken. The Sustainability Appraisal will need to be updated in advance of the publication of the SWLP Regulation 19 consultation document in order to take this into account.

No

Representation ID: 108809

Received: 07/03/2025

Respondent: Barratt David Wilson Homes (Mercia)

Agent: Savills

This Draft Policy Direction states that density ranges will be set out in Design Codes. The Policy should be worded to take account of the need for Design Codes to have input from those with an interest in the development of allocations, such as landowners, promoters, and developers. Such stakeholders should be allowed to influence design codes ensure that development is both feasible and deliverable, whilst taking into account the character of the local area, market needs and upholding appropriate design standards.
The Draft Policy Direction also states that the SWLP will identify areas that would be more suited to higher density development through densification. It is important to note that the approach to density should recognise the that appropriateness of densification should be determined on a site-specific basis. Sites within urban areas and / or close to mixed use hubs which have good accessibility to a range of services, employment opportunities and public transport provision are likely to lend themselves to a higher density of development.

No

Representation ID: 108810

Received: 07/03/2025

Respondent: Barratt David Wilson Homes (Mercia)

Agent: Savills

Barratt David Wilson Homes Mercia wishes to reiterate that the SWLP should not be including a Policy which requires NDSS and / or M4(2) and M4(3) compliance without the appropriate justification. This justification is required by the NPPF { National Planning Policy Framework (December 2024) Paragraph 36} and currently does not exist. The Planning Practice Guidance sets out the type of evidence which should be presented in order to justify such a Policy requirement. The viability assessment which is in the process of being undertaken should review the impact of NDSS and M4(2) / M4(3) in conjunction with other policy requirements, for instance in requirements relating to the achievement of Net Zero Carbon goals, enhanced water efficiency standards and ecological net gain.
In setting this Policy requirement consideration should also be given to the contribution made by well-designed smaller homes to affordably meeting the needs for both open market and affordable housing. There is a risk that the imposition of arbitrary space requirements in lieu of focusing on design quality could adversely impact on affordability and deny lower income households from being able to afford homeownership. In particular the proposed requirement for all 1 and 2 bedroom affordable homes to be built with bedrooms capable of satisfactorily accommodating 2 occupiers in each bedroom exceeds the NDSS requirements and would need to be robustly justified within the evidence base.

No

Representation ID: 108811

Received: 07/03/2025

Respondent: Barratt David Wilson Homes (Mercia)

Agent: Savills

Barratt David Wilson Homes Mercia objects to the onerous approach being proposed in Draft Policy B in relation to requiring developments of over 100 dwellings to provide 5% custom and self-build housing. This approach could interfere with the comprehensive design, planning and speed of delivery of these large allocations.
There is therefore no specific requirement for self build or custom build dwellings to be provided as part of larger allocated sites. Crucially no figures are provided in relation to existing and projected need and supply for these dwellings for the SWLP area for the Plan period and therefore it has not been justified how the Draft Policy approach addresses a need or whether the draft approach is likely to be addressing this need within the locations where the need is arising.
The 5% requirement of Draft Policy B would potentially give rise to the need for agreeing multiple separate contracts with interested parties. In addition, there are also practical issues to consider, for example the day-to-day operation of such sites and consideration of potential health and safety issues of having multiple individual construction sites within one development. To avoid the imposition of an onerous requirement through the emerging Policy provisions it is contended that the provision of such plots on strategic sites should be left to the discretion of the developer based on market trends / requirements, which are liable to change over the Plan period.

No

Representation ID: 108812

Received: 07/03/2025

Respondent: Barratt David Wilson Homes (Mercia)

Agent: Savills

Barratt David Wilson Homes Mercia considers that the SWLP should not be including a Policy which requires achievement of a water efficiency standard of 100 litres per person per day without the appropriate justification. This justification is required by the NPPF {National Planning Policy Framework (December 2024) Paragraph 36}.and currently does not exist.
As acknowledged within the supporting text for Draft Policy H, a water efficiency standard of 125 litres per person per day is set in Building Regulations and that there is an option for LPAs to require a tighter standard of 110 litres per person per day where there is a clear local need. Reference is made to the Water Cycle Study {Coventry and Warwickshire Sub-regional Water Cycle Study – Stage 1. Final report. August 2024}. recommending consideration of an even tighter standard of 100 litres per person per day. However, what the evidence base currently does not do is consider the implications of this proposal, which relates to the fittings installed in new dwellings, on the viability of new development. This assessment therefore still needs to take place.

No

Representation ID: 108813

Received: 07/03/2025

Respondent: Barratt David Wilson Homes (Mercia)

Agent: Savills

In principle Barratt David Wilson Homes Mercia supports the production of site-specific design codes. It is noted that Table 8 accompanying the Draft Policy Direction 26 states that production of site-specific design codes will be led by the SWLP team. There is however no reference to input from those with a direct interest in the sites, including landowners, promoters, and developers. Such stakeholders should be allowed to influence design codes to ensure that development is both feasible and deliverable, whilst ensuring that appropriate design standards are upheld. This would then take account of the NPPF {National Planning Policy Framework (December 2024) Paragraph 134} requirement for effective engagement.
The final Policy provision relating to Design Coding should nevertheless also acknowledge, as set out in the NPPF {National Planning Policy Framework (December 2024) Paragraph 134} that site-specific Design Codes could alternatively be produced by landowners and developers in support of planning application proposals. It should also be the case that the production of site-specific design codes should not delay the ability for planning applications to be submitted for the development of the allocated sites.
In addition, it is not considered necessary for densification coding to be undertaken. NPPF Section 11 promotes making effective use of land and encourages the use of minimum density standards for city centres, town centres and other areas as part of the strategy for achieving this. Densification can be achieved without a need to produce densification codes.

Yes

Representation ID: 108814

Received: 07/03/2025

Respondent: Barratt David Wilson Homes (Mercia)

Agent: Savills

Draft Policy Direction 28 notes the use of the waterways as routes for active travel and highlights that development which would improve access and sense of place will be supported. These particular proposed Policy provisions are positive and recognise the value that these routes have in supporting the delivery of a sustainable travel agenda as part of the wider move towards a Net Zero Carbon economy. Accordingly the SWLP approach to site allocations should be supportive of development proposals in suitable locations which can link into, and increase the usage of, these existing active travel routes.

Other

Representation ID: 108815

Received: 07/03/2025

Respondent: Barratt David Wilson Homes (Mercia)

Agent: Savills

Draft Policy Direction 31 states that development proposals should prioritise access to public transport, walking and cycling routes. However neither the Policy text nor supporting explanation make specific reference to the sustainability benefits which arise from the proximity of strategic new development locations to existing railway stations. This is considered to be particularly important in the context of SWLP strategy being heavily influenced by a strategy based on sustainable travel and rail corridors. The text should be updated accordingly to reflect this.
Development near a railway station with existing regular services to key destinations will assist in achieving a reduction in car dependence, and provide access for all including through allowing those with reduced mobility and or low-income to access reliable public transport services and thereby access wider social benefits and employment opportunities.