BASE HEADER

No

ID sylw: 108734

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We object to Draft Policy A as currently worded, on the basis that some of the requirements within the policy are not supported by adequate evidence and therefore the policy is unsound as it does not meet the requirements of NPPF paragraph 36. Planning Practice Guidance (Paragraph: 002 Reference ID: 56-002-20160519) is clear that the Nationally Described Space Standard (NDSS) is an optional technical standard and that LPAs will need to gather evidence to determine whether there is a need for additional standards, including consideration of viability (Paragraph: 003 Reference ID: 56-003-20150327) . No evidence has been provided as part of the Preferred Options consultation documents to justify the requirement for NDSS, and therefore we consider this element of the policy to be unsound and not in accordance with NPPF paragraph 36.
Additionally, the requirement for all 1 and 2 bed affordable homes to support double/twin occupancy is also unevidenced and goes beyond the requirements of NDSS. The 2022 Coventry and Warwickshire
Housing and Economic Development Needs Assessment (HEDNA) does not provide clear justification for the need for this additional bedroom requirement and therefore we consider that this element of the policy lacks justification and does not accord with NPPF paragraph 36(b).
We note that the 2022 HEDNA recommends at paragraph 14.74 that all dwellings are constructed to M4(2) standard and 10% are constructed to M4(3) standard, with the potential to require a higher percentage for affordable housing. However, there is no justification within the SWLP evidence base for 25% of affordable dwellings to meet the M4(3) standard and so we consider this element of the policy to be unjustified and therefore unsound unless sufficient evidence is provided to demonstrate a clear need for this in line with the requirements of Planning Practice Guidance (Paragraph: 005 Reference ID: 56-005-2015032)
. Planning Practice Guidance (Paragraph: 007 Reference ID: 56-007-20150327)also states that as part of the requirement to demonstrate a clear need for requiring M4(2) or M4(3) standards, LPAs should take into account the overall impact on viability. We wish to highlight that the Councils must provide robust evidence that the requirement for residential development to be built to increased accessibility standards will not impact viability, and therefore housing delivery.
Overall, we consider that prior to the next stage of consultation, the Councils will need to demonstrate that the above requirements do not pose significant challenges to the overall viability of the plan.