No

ID sylw: 108549

Derbyniwyd: 29/06/2025

Ymatebydd: Hayfield Homes

Draft Policy A seeks to require at least 10% of market dwellings and at least 25% of affordable dwellings to be built to M4(3) standard. This policy is considered unduly onerous and could adversely impact on the viability of development within South Warwickshire, including allocated sites. Policy A is not considered justified and instead should reflect a requirement for at least 5% of all dwellings to be built to M4(3) standard, as is more commonly applied in other Local Plan areas.

No

ID sylw: 108571

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

The policy states that new residential development must comply with the Nationally Described Space Standards (NDSS). Footnote 51 of the NPPF is clear that planning policies should only refer to NDSS where the need for this can be justified. The attempted justification within the supporting text is weak and unconvincing. No evidence is provided to demonstrate that the size of new homes is diminishing, as alleged, and only two appeal decisions have been considered.

If the use of NDSS is subsequently justified and pursued, the policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below NDSS, will be acceptable. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements.

The draft policy also states that homes should be provided to M4(2) and M4(3) standards. This aspect of the policy must be based on evidence to be justified. The HEDNA does provide some support for this, but is now out-of-date.

Notwithstanding, Corbally Group contend that it is unnecessary to include an M4(2) and/or M4(3) requirement in the SWLP Part 1. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements.

Other

ID sylw: 108619

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Draft Policy A – Providing the Right Size of Homes
5.8.
The policy states that new residential development must comply with the Nationally Described Space Standards (NDSS). Footnote 51 of the NPPF is clear that planning policies should only refer to NDSS where the need for this can be justified. The justification within the supporting text is unconvincing. No evidence is provided to demonstrate that the size of new homes is diminishing, as alleged, and only two appeal decisions have been considered; indeed, the Councils acknowledge that further research and analysis is required, as well as viability testing, which will be essential to ensure that the plan is effective. A
n additional reason to require NDSS compliance offered by the Councils is that Homes England wish for NDSS to be met in grant funded schemes. However, the Homes England Capital Funding Guide does not require this, and 85% of NDSS is generally accepted as the benchmark for grant-led affordable homes. Therefore, at present, the required robust justification for a NDSS policy is lacking, and therefore the draft policy is unsound on this basis.
5.9.
If the use of NDSS is subsequently justified and pursued, the policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below NDSS, 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.
5.10.
The draft policy also states that homes should be provided to M4(2) and M4(3) standards. This aspect of the policy must be based on evidence to be justified. Footnote 51 of the NPPF allows for these optional technical standards for accessible and adaptable housing to be introduced through planning policy ‘where this would address an identified need for such properties’. The HEDNA does provide some support for this, with the study ultimately recommending that all dwellings should meet M4(2) standards and 10% should meet M4(3). However, as discussed elsewhere in these representations, the HEDNA is now out-of-date, and a refreshed study should be produced to determine whether there is a need for M4(2) and M4(3) properties to justify a policy relating to accessible and adaptable dwellings.
5.11.
Notwithstanding, it is unnecessary to include an M4(2) and/or M4(3) requirement in the SWLP Part 1. 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. It is not necessary for this to be repeated in a development plan policy, also because developers are already aware they need to deliver to this standard. Therefore, it is suggested that reference to accessible living standards can be deleted from the draft policy.

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.