BASE HEADER

No

ID sylw: 108824

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land-Land east of Stratford-on-Avon

Asiant : Savills

We object to the requirements set out in Draft Policy A which introduced the requirement for all new residential dwellings to comply with Nationally Described Space Standards. The PPG (Paragraph: 003 Reference ID: 56-003-20150327) states ‘that Local Authorities should consider the impact of using these standards as part of their Local Plan viability assessment.’ We understand from the Preferred Options plan (page 62) that further viability testing will be undertaken, however this has not yet been done and therefore at this stage, the requirement is not evidenced.
Additionally, the requirement for all 1 and 2 bed affordable homes to support double/twin occupancy is not justified as the HEDNA does not provide clear justification for the need for this additional bedroom requirement nor has any evidence been produced to assess the impact of this requirement on viability and the efficient use of land. The PPG also states that where local authorities set additional requirements they 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). This proposed policy requirement is therefore not considered to be in accordance 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. The PPG also states that LPAs should take into account the overall impact on viability of M4(2)/(3). This will need to be a key consideration in the Viability Appraisal that the Councils intend to prepare to support the Regulation 19 SWLP. This requirement should also be considered against national policy to make efficient use of land. Plots which are compliant with M4(2) and M4(3) standards are larger and will result in a lower density of development being achieved.