BASE HEADER

No

ID sylw: 108733

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We object to the draft policy direction as written. Whilst we agree that the Councils should have regard to the latest evidence relating to housing tenure, mix and type when drafting policy wording, we wish to highlight that the 2022 HEDNA, which represents the most recent evidence base on housing, does not base its findings on the revised standard method for the calculation of housing need.
Therefore, whilst the HEDNA provides an assessment of affordable housing needs across the plan area, we consider this evidence base to be largely out of date.
Planning Practice Guidance4 states that once an affordable housing need has been identified “the total affordable housing need can then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, taking into account the probable percentage of affordable housing to be delivered by eligible market housing led developments. An increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes.” (Savills emphasis)
In this context, we welcome the Councils’ recognition at page 59 of the Preferred Options plan that the forthcoming Strategic Housing Market Assessment (SHMA) and the revisions to the NPPF will directly impact emerging policy on affordable and specialist housing. We consider that, should the SHMA identify a significant affordable housing need in South Warwickshire, the Councils should consider increasing the housing requirement of the plan in order to ensure that significant affordable housing can be viably delivered across all identified allocations. We note that the Strategic Growth Options and New Settlements included in the Preferred Options consultation amount to a total capacity of circa 156,000 new dwellings. Given the residual housing requirement is around 28,000 dwellings, we consider that there is ample potential within the SWLP area to provide additional housing in order to facilitate the delivery of additional affordable housing.