Publication (Regulation 19)

5 Building Homes that Meet the Needs of Our Communities Comment

5.1 Housing Mix

5.1.1 As well as ensuring we build the right number of homes it’s important that the homes we build meet the diverse needs of the current and projected population. This means considering the different sizes of homes required, the split between market and affordable tenures to reflect local affordability and ensuring the homes we build are of sufficient size to meet to provide good living conditions.

Policy Justification

5.1.2 The Strategic Housing Market Assessment 2026 (SHMA) assessed the need for different sizes of homes, with recommendations given separately for market housing, rented affordable housing and affordable home ownership housing. These recommendations are reflected in the policy.

5.1.3 Rented affordable housing is allocated to households based on need in accordance with the bedroom entitlement rules. These rules expect certain groups to share bedrooms rather than have their own rooms, including couples and two children of the same gender under the age of 16. As such it is important to ensure the bedrooms in affordable homes are doubles/twins wherever possible and as a minimum, in line with the person capacities stated in the policy.

5.1.4 Affordable home ownership housing is not subject to the same rules however to ensure homes remain desirable to Registered Providers (RP’s) who will buy the units from developers and to allow for flexibility for changes in tenure if required, the person capacities are extended to cover all affordable tenures.

5.1.5 In respect of the size mix for affordable home ownership units, unlike for rented affordable homes, households are able to choose the size of home that suits their requirements and preferences, subject to passing affordability checks. For this reason, Registered Providers can find it difficult to sell 1-bedroom Affordable Home Ownership dwellings as many households choose to buy a larger home than they need. To allow flexibility around 1-bedroom Affordable Home Ownership dwellings the policy requirement allows ‘up to 10%’ as it is accepted that for some sites it may not be practical to include 1 bed units, whilst on others, especially in town centre or high-density locations they may be more appropriate.

Policy Justification

5.1.6 The Nationally Described Space Standards (NDSS) set space requirements for new homes, based on the level of occupancy and number of storeys of a dwelling. The standards include minimum gross floor area as well as minimum requirements for bedroom sizes and storage space.

5.1.7 The NPPF allows local authorities to require compliance with the NDSS in the interests of creating homes with a high standard of amenity for existing and future users, where a need for the standard can be justified.

5.1.8 The NPPF also allows local authorities to introduce optional technical standards for accessible and adaptable housing where this would address an identified need for such properties. The optional technical standards are set out in Approved Document M (Volume 1) of the Building Regulations as follows:

• M4(1) Category 1: Visitable dwellings
• M4(2) Category 2: Accessible and adaptable dwellings
• M4(3) Category 3: Wheelchair user dwellings
  • M4(3)(2a): Wheelchair adaptable dwellings (homes that can be easily adapted to meet the needs of a wheelchair user)
  • M4(3)(2b): Wheelchair accessible (homes readily useable by a wheelchair user at the point of completion)

5.1.9 Compliance with Category 1 is mandatory under the Building Regulations, however Categories 2 & 3 are optional, subject to a need being identified.

5.1.10 The need for accessible housing stems from anticipated increases in both the older person population and the number of people with disabilities. The SHMA (2026) explains that between 2025-50 the population aged 65+ is expected to rise 53% in Stratford-on-Avon district and 43% in Warwick district, compared to the under 65 population which is projected to see growth between 26% and 28% respectively.

5.1.11 The SHMA also highlights that older people are more likely to have a disability with around 30% of those aged 65 and over currently falling into this category. Combined with the ageing population, it is expected that between 2025-50 there will be a 73% increase in those aged 65 and over with a mobility problem in Stratford-on-Avon district and a 58% increase in Warwick District. The changes in those with disabilities are not however limited to the older population. There is expected to be an increase in the population aged 16-64 with impaired mobility of 31% and 34% across the two districts respectively. As a result the SHMA recommends that all new homes are built to M4(2) Category 2 standard.

5.1.12 Compliance with this standard will help the two districts address the needs of those with disabilities now and those who will experience disability in the future. It is important to recognise that disability can affect anyone at any point in their lives, sometimes without warning. Therefore, requiring all homes to meet the M4(2) standard will ensure they can be more easily adapted to meet occupiers needs as required.

5.1.13 The SHMA also investigated the need for wheelchair accessible housing across South Warwickshire and noted that 6.7% of social tenants were wheelchair users compared to 2.6% of owner-occupiers. Using a combination of population projections and prevalence rates for wheelchair users the SHMA calculated that an additional 44 wheelchair user dwellings are required per annum and recommended a need for 2.5% of market homes and 5% of affordable homes to be built as wheelchair user dwellings (Category 3).

5.1.14 In respect of wheelchair accessible homes, the Planning Practice Guidance states that policies for wheelchair accessible homes can only be applied to dwellings where the local authority is responsible for allocating or nominating a person to live. This means that the M4(3)(2b) standard can only be required for social and affordable rented homes as these are the only tenures that either Council nominates residents to live in. Market and affordable home ownership properties can only be required to reach M4(3)(2a) and this is reflected in the policy.

5.1.15 The Councils are mindful that if homes are built to the M4(3)(2b) standard but there is no end user suitable for the home, the cost of installing the necessary upgrades would be abortive. To avoid this situation, the Councils will identify an end user prior to commencement of development of the relevant plot otherwise the plot may be built to the M4(3)(2a) standard.

5.2 Affordable Housing

5.2.1 Affordable Housing is defined in the NPPF as housing for sale or rent for those whose needs are not met by the market. It covers a wide range of housing tenures and types, all available at a cost below market rates.

Policy Justification

5.2.2 The need for Affordable Housing within South Warwickshire was considered in the Strategic Housing Market Assessment 2026 (SHMA). This identified a net need for1237 affordable dwellings per annum (dpa) across South Warwickshire, with the need being slightly higher in Stratford district (668dpa) than Warwick district (569dpa). This represents approximately 56% of the total housing need of South Warwickshire (2197dpa), calculated using the government’s standard method.

5.2.3 Given the significant need for affordable homes, it is important the Councils maximise their delivery across South Warwickshire. For this reason, the Councils have chosen to apply two thresholds from which affordable housing will be required on residential developments, depending on location.

5.2.4 The default threshold applied across South Warwickshire requires affordable housing on schemes of 10 or more dwellings, in accordance with the NPPF Paragraph 65. This threshold has been tested through the whole plan viability appraisal and has been found to be deliverable.

5.2.5 The second threshold applies to residential developments in ‘Designated Rural Areas’ as defined by the Housing Act 1985. The rural nature of these areas means it is less likely housing schemes of 10 units or more will be developed, but nonetheless it is important to provide affordable housing to support rural communities. This lower threshold and the financial contribution that applies (see below) have been tested through the whole plan viability appraisal and found to be deliverable.

5.2.6 The amount of affordable housing required on a site also depends on its location. Though the SHMA found a need for 56% of new homes to be affordable, this proportion was not found to be deliverable through the whole plan viability appraisal. The technical evidence shows a mixed viability picture and as such, the SWLP adopts a flexible approach. Based on the housing market value zones, different affordable housing requirements are set across South Warwickshire. It is acknowledged that these may be challenging in the short-term, and as such, the requirements are subject to viability. It is acknowledged that higher requirements are sought in Grey Belt and Cotswolds National Landscape areas. As such, the figures are expressed as minimums. The approach to affordable housing for the strategic sites is set out in Policy DS.4.

5.2.7 In respect of how affordable homes should be provided, NPPF Paragraph 64 is clear that where a need for affordable housing is identified, this need should be met on-site unless off-site provision or an appropriate financial contribution can be robustly justified and contributes to creating mixed and balanced communities.

5.2.8 The Local Planning Authorities are however concerned that requiring on site delivery of affordable homes where the lower threshold applies in Designated Rural Areas could act as a barrier for development due to the small numbers of units that would come forward and challenges around securing a Register Provider to buy the units. To overcome this issue a financial contribution is required for affordable housing on sites of fewer than 10 units instead of on-site delivery. The funds received can then be used to provide affordable housing, for example through rural exception sites.

Policy Justification

5.2.9 Affordable Housing is an umbrella term that covers several different tenures of housing, both for rent and home ownership, which are designed to address the different housing needs of individual households who are unable to access suitable housing on the open market.

5.2.10 The Strategic Housing Market Assessment (SHMA 2026) evaluated the need for different tenures of Affordable Housing and found a requirement for 60% Social Rent, 20% Affordable Rent and 20% Affordable Home Ownership. The Local Planning Authorities are however concerned that Affordable Rent homes are less affordable than Social Rent homes and some households can find themselves trapped on housing benefit or Universal Credit to cover the rent. To address this issue the delivery of Social Rent homes has been prioritised and all rented affordable housing are required to be delivered in this tenure. To balance the impact this has on development viability the proportion of Shared Ownership dwellings was initially increased from 20% to 30%. However due to wider viability challenges and a desire to deliver as many affordable homes as possible, this was increased again to 40%.

5.2.11 In respect of affordable home ownership units, this term includes several different tenures including Shared Ownership, Rent to Buy and Discounted Market Sale housing. The SHMA found that there was no evidence to support the need for Discounted Market Sale within South Warwickshire (including First Homes). Further, Rent to Buy was found to offer insufficient savings for households to be able to afford a 10% deposit on a property. It is therefore considered that Shared Ownership is the most appropriate form of affordable home ownership tenure in South Warwickshire, particularly as buyers can now purchase as little as 10% equity. There may however be exceptional circumstances where the preferred tenure split is not appropriate or deliverable. Subject to clear evidence being provided, alternative tenure splits will be considered. In the event an alternative tenure split includes Affordable Rent, this should be capped at Local Housing Allowance rates.

5.2.12 As well as the tenure and size of a home, the type of home is also important. Most new homes within South Warwickshire are provided as houses, but some are built as apartments, maisonettes or bungalows. Developments will be expected to provide an appropriate range of house types, taking into account the location of the development, but given the ageing population across South Warwickshire, a requirement for a small proportion of ground floor single level homes has been included to respond to this demographic change. Depending on the location of the development and the density requirements, these may take the form of bungalows or ground floor apartments.

5.2.13 In respect of the affordability of Affordable Housing the SHMA has highlighted the high housing costs within South Warwickshire relative to incomes. In particular Discounted Market Sale housing was only found to be affordable with a discount of at least 40% from open market value whereas the minimum level of discount required by the NPPF is 20%. This highlights the need for proposals to have regard to local housing costs and incomes. Where applicable, any assessment of housing costs should include reference to all relevant costs including service charges.

5.2.14 The NPPF references the need to create mixed and balanced communities and it is considered that to achieve this it is important that new Affordable Housing is both fully integrated into developments and indistinguishable from market housing. This includes the design and materials of individual units along with the layout and landscaping used, including the parking design.

Policy Justification

5.2.15 High property prices limited affordable housing supply and housing stock imbalances present challenges across the plan area but particularly in rural areas where housing supply is more restricted. However, the focus of housing development in the South Warwickshire Local Plan is within and around existing larger settlements. Fewer homes are intended for rural areas and policies within this plan limit the places where new homes can be built in the countryside, particularly in the green belt. In this context it is important that rural communities can provide sufficient affordable housing to meet their needs and allow those with strong family links or who work in those communities to live there.

5.2.16 Rural exception sites are an established mechanism to meet rural affordable housing needs. They are an exception to normal planning policy in recognition of the importance of providing affordable housing in rural areas. Rural exception sites are included in national planning policy and are a form of development that is acceptable in the green belt.

5.2.17 The purpose of this policy is to set out the circumstances where development of a rural exception site would be acceptable. As these sites are an exception to normal planning policy, additional controls are imposed to ensure developments meet the needs of rural communities and to maintain the integrity and reputation of rural exception sites, thereby safeguarding the policy from abuse.

5.3 Specialised Housing

5.3.1 Meeting the housing needs of South Warwickshire is not only about ensuring we provide enough housing for our communities, but also that the homes we build meet their needs. Whilst most new housing will cater for the general needs of the population; some residents will have more diverse requirements that are best met through Specialised Housing options.

Policy Justification

5.3.2 Specialised Housing is accommodation that, through its location, design and management, meets or has the flexibility to meet, the needs of vulnerable people and households, whilst promoting and supporting their ability to continue to live independently as far as possible. This includes accommodation:

• For people of all ages, but especially older people, which supports their ability to continue to live independently but also incorporates flexible provision to meet their care needs.
• For people of all ages who require accommodation within schemes designed and managed to cater for their specific support needs.

5.3.3 The most common form of Specialised Housing is accommodation for older people. There are different types of housing for older people to cater for different needs, as follows^[10]:

• Age-restricted general market housing: Generally, for people aged 55 and over and the active elderly. It may include some shared amenities such as communal gardens but does not include support or care services.
• Retirement living or sheltered housing (housing with support): This usually consists of purpose-built flats or bungalows with limited communal facilities such as a lounge, laundry room and guest room. It does not generally provide care services but provides some support to enable residents to live independently. This can include 24-hour on-site assistance (alarm) and a warden or house manager.
• Extra care housing or housing-with-care (housing with care): This usually consists of purpose-built or adapted flats or bungalows with a medium to high level of care available if required, through an onsite care agency registered through the Care Quality Commission (CQC). Residents are able to live independently with 24-hour access to support services and staff, and meals are also available. There are often extensive communal areas, such as space to socialise or a wellbeing centre. In some cases, these developments are known as retirement communities or villages - the intention is for residents to benefit from varying levels of care as time progresses.
• Residential care homes and nursing homes (care bedspaces): These have individual rooms within a residential building and provide a high level of care meeting all activities of daily living. They do not usually include support services for independent living. This type of housing can also include dementia care homes.

5.3.4 The Strategic Housing Market Assessment (SHMA 2026) identified that the proportion of residents aged 65 and over is 19% in Warwick District and 25.4% in Stratford District. This compares to 18.7% for England as a whole. Between 2025-50 the population aged 65 and over is projected to increase by around 53% in Stratford-on-Avon and 43% in Warwick. In contrast the population aged under 65 is projected to see growth of between 26% and 28% over the same period. Given the ageing population and the current supply of older persons accommodation, the SHMA identified a need for more units of all types of older persons accommodation in both Stratford and Warwick district by 2050 as shown in Figure 20.

Figure 18: Older Persons Housing

Specialist Housing Need for Older Persons, 2025-50 (SHMA 2026)

5.3.5 In addition to housing for older people, Specialised Housing includes accommodation for those with physical or mental impairment including people with ambulatory difficulties, blindness, learning difficulties and mental health needs. Specialised Housing also extends to housing for children in care, those experiencing or at risk of domestic abuse, those with drug or alcohol dependencies and homeless households. Accommodation may be intended as short term housing to help people overcome challenges or more permanent arrangements where longer-term support is required.

5.3.6 Given the very broad range of accommodation that falls within the term Specialised Housing, this policy is designed to act as a framework to assess the range of proposals that may come forward. Further, the Plan covers the period to 2050, and it is reasonable to assume that during this period:

• new or updated evidence will emerge on the scale and nature of need for Supported Housing;
• there will be changes to market conditions, national and local priorities and policies, and preferred delivery models of different categories of specialised housing.

5.3.7 Changes can sometimes happen at short notice and relate to matters which may not directly fall within the scope of the planning system, but which may have significant impacts for the way in which Specialised Housing is delivered. It is also important to consider implications arising from implementation of the Supported Housing (Regulatory Oversight) Act 2023.

5.3.8 The SHMA calculated different levels of need for affordable older persons housing depending on the type of support proposed. The need is shown in the table above and reflected in the different proportions required in the policy. Given that viability is a mixed picture, viability will be assessed on a case-by-case basis.

Policy Justification

5.3.9 The NPPF defines Build to Rent as ‘Purpose built housing that is typically 100% rented out. It can form part of a wider multi-tenure development comprising either flats or houses, but should be on the same site and/or contiguous with the main development. Schemes will usually offer longer tenancy agreements of three years or more, and will typically be professionally managed stock in single ownership and management control’.

5.3.10 NPPF Paragraph 63 explains that the housing needs for different groups in the community, including those who rent their homes, should be assessed and reflected in planning policies.

5.3.11 The Strategic Housing Market Assessment (SHMA 2026) considered the need for Build to Rent units and found that whilst it was not possible to quantify the exact need for Build to Rent units in South Warwickshire, it would be appropriate for the Plan to offer broad support to Build to Rent developments and provide a framework for supporting schemes. This policy aims to fulfil this recommendation and recognise the specific way Build to Rent functions.

5.4 Gypsy & Travellers and Boat Dwellers

5.4.1 Gypsies, travellers and Travelling Showpeople have specific accommodation needs. South Warwickshire is required to assess and meet these accommodation needs. Meeting this need is as important as every other housing need within the plan area. The Councils are also required to consider the needs of people residing in or resorting to places on inland waterways where houseboats can be moored.

Policy Justification

5.4.2 The safeguarding of existing and future gypsy and traveller, travelling showpeople and boat dweller accommodation with permanent planning permission will be important to ensure that that there are no losses of provision to other uses. This will assist in maintaining an appropriate supply of accommodation and also ensure that households are confident that their right to remain on sites is protected. Proposals for the loss of existing sites approved for gypsies, travellers and travelling showpeople, or sites last used for that purpose will be required to demonstrate that there is no longer a need for this type of accommodation in the plan area or that the site is no longer suitable for that use.

Policy Justification

5.4.3 National planning policy for Gypsy, Travellers and Travelling Showpeople is set out in the NPPF and Planning Policy for Traveller Sites (PPTS) and all new sites will be expected to meet the requirements of national policy.

5.4.4 This policy sets out a criteria-based approach to assessing proposals which come forward on an ad-hoc basis for the provision of accommodation to meet the needs of gypsies, travellers and travelling showpeople. The policy provides flexibility to meet such needs on a case-by-case basis and seeks to ensure that sites are provided in appropriate and sustainable locations, and which respect both the interests and cultures of both settled and traveller communities to promote a sustainable, balanced and integrated community.

5.4.5 The criteria in the above policy will also be used together with other relevant policies of this plan to assess suitability and deliverability when planning applications are decided. It is recognised however that there are unlikely to be sites that meet every one of these criteria. A ‘best-fit’ approach will therefore be adopted.

5.4.6 A negotiated stopping policy protocol will be developed to help mitigate the impacts of unauthorised encampments.

5.4.7 It is important that an appropriate strategy is developed to deal with unauthorised encampments that occur across the South Warwickshire. Our GTAA, recommends that the councils explore the use of a ‘negotiated stopping’ approach, that in appropriate circumstances, would enable transient gypsies and travellers to stop at suitable locations for an agreed and limited period of time. The GTAA study also stipulates that this approach may be achieved in conjunction with the development and use of formal transit sites.

5.4.8 A negotiated stopping approach will be explored for South Warwickshire, and it is likely that this may be best achieved in conjunction with other local authorities across Warwickshire. To complement this approach, as part of the allocation at Harbury Lane, a formal transit site with a capacity of 8 bays is to be provided to serve the South Warwickshire Local Plan area. To ensure its effectiveness, this site will require careful management, and it is intended that will be provided in conjunction with the implementation of a Traveller support hub that is also to be located on the site.

5.4.9 The cultural practice of Travelling Showpeople is to live on a plot in a yard in static caravans or mobile homes, along with smaller caravans used for travelling or inhabited by other family members. Their equipment (including rides, kiosks and stalls) is usually kept on the same plot. Clearly, such large storage and maintenance areas have implications in terms the design of plots. Residential amenity and landscape impact will require very careful consideration when devising site layouts.

Policy Justification

5.4.10 In order to ensure that new accommodation is delivered appropriately, a site design policy is considered to be essential. This is especially important given the high number of pitches which are required to be provided in the plan period.

5.4.11 Everyone should have the opportunity of a safe and comfortable home it is therefore important that new traveller accommodation is designed to a high standard to ensure that they have can be successfully assimilated into the local environment and deliver safe and secure homes that will have a positive impact on the health and wellbeing of future occupants.

5.4.12 Whilst there is no single, appropriate design for sites the considerations set out in the policy above are important factors that will help to shape the delivery of safe and accessible Gypsy, Traveller and Travelling Showpeople sites. With regards to the design of Travelling Showpeople sites reference to the Showmen’s Guild Guidance for travelling Showpeople sites (2007) will be necessary.

Policy Justification

5.4.13 Boat dwellers are not classed as an ethnic minority under the Equality Act (2010), but the Housing and Planning Act (2016) sets out a requirement to consider the needs of people residing in or resorting to places on inland waterways where houseboats can be moored. In line with draft government guidance published in 2016, our Accommodation Assessment examined boat dweller accommodation needs for the period 2024-2050.

5.4.14 Since the formulation of the study in 2024 a material change in the supply of residential moorings has been established. A local marina secured an established use certificate confirming that there were no restrictions on the numbers of permanent moorings it was allowed. This change of circumstances provides supply sufficient to meet the previously identified need of 35 permanent residential moorings across both Stratford-on-Avon and Warwick Districts over the plan period to 2050.

5.4.15 The GTAA acknowledges that there is currently no unmet need for permanent residential moorings, however it is considered important to ensure that there is an appropriate policy framework in place to assess any future proposals especially as the nature of boat dwelling continues to evolve. Proposals for new moorings will be required to demonstrate suitable access to facilities and services and must demonstrate that the new moorings would not result in adverse impacts on the area.

5.5 Self-Build and Custom-Build Housing

5.5.1 Self-build and custom build housing provides opportunities for individuals or groups to take a more active role in designing and building their own home to do so. Local Planning Authorities are required to keep a register of individuals and groups who wish to build their own homes and to ensure that a sufficient number of self-build and custom-build plots are provided to meet this need.

Policy Justification

5.5.2 The Self-Build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016), places a duty on Local Authorities to keep a register of individuals, and associations of individuals, who wish to acquire serviced plots of land to bring forward Self-Build and Custom Housebuilding projects.

5.5.3 The Act also places a duty on Local Authorities to have regard to the register when carrying out planning and other functions, including giving permission for sufficient serviced plots of land to meet the demand in their area.

5.5.4 The Councils will apply the definition of Self-Build and Custom Housebuilding from the Self-Build and Custom Housebuilding Act 2015.

Larger Housing Sites

5.5.5 The policy provides several routes for self and custom build schemes to come forward. The primary route is through larger housing allocations by requiring a proportion of homes to be delivered as self-build plots. This will ensure new self-build homes are located in the most sustainable locations with convenient access to services and sustainable transport options.

5.5.6 The requirement for 2% of plots to come forward for self and custom build plot is based on demand trends from both Councils registers. It is however acknowledged that demand may change over the plan period and therefore flexibility is included in the policy to adapt to falling demand. If demand increases and a developer wishes to provide more than 2% self and custom build plots, the Councils will give this consideration, taking into account other policy aims of this plan.

5.5.7 To balance the efficient use of land with the practicalities of self-building, self-build and custom build developments are expected to achieve a density of at least 25 dwellings per hectare.

Unallocated Sites

5.5.8 Individual and small-scale self and custom build proposals will supported within existing settlement boundaries, as defined in this plan. Small scale is considered to be less than 10 plots.

5.5.9 In addition, there may be circumstances where demand for self and custom plots, as shown by the Councils respective registers, is not being met by larger housing sites, particularly if there are delays developing large sites or if demand increases relative to current trends. Where there is unmet demand, suitable individual or small-scale sites adjacent to larger settlements to meet this demand will be supported.

5.5.10 There may also be circumstances where local communities wish to bring forward self and custom build sites to meet the needs of their community. This need should be evidenced by a suitable and robust Housing Needs Survey (as per Policy HO.4) for further guidance on Housing Need Surveys. Given such schemes are for the benefit of local communities, they are permissible in all areas of South Warwickshire including in the Green Belt and within the Cotswold National Landscape. Suitable controls, including legal agreements, will be used as required to avoid abuse of the policy.

5.6 Homes in Multiple Occupancy and Student Accommodation

5.6.1 Homes in multiple occupancy and student accommodation provide additional choice in the housing market however they can present challenges to local standards of amenity. Management of these forms of accommodation is therefore necessary mitigate the potential issues that may arise.

Policy Justification

5.6.2 The increase in the number of Houses in Multiple Occupation (HMO’s) in Royal Leamington Spa has led to a fall in the standards of amenity experienced by residents in parts of the town where HMO’s have concentrated. This is largely a result of:

• a relatively large proportion of young, single people with student lifestyles that conflict with the lifestyles of more settled residents; and
• a relatively large proportion of privately rented accommodation, with short-term tenancies, which often leads to a lower standard of upkeep of property and the loss of a sense of belonging within the community.

5.6.3 The purpose of this policy is to prevent unacceptable adverse impacts on amenity (as set out above) and to control the location of new HMOs and student accommodation in order to prevent these uses from either exacerbating existing or creating new concentrations. Additional HMOs and student accommodation can impact on local amenity where they lead to concentrations at either the neighbourhood level or in very localised situations. The policy aims to prevent concentrations at both levels by ensuring that within a 100m radius of the proposal not more than 10% of dwellings are HMOs and student accommodation, and also at a more localised level, by preventing the “sandwiching” of a non-HMO dwelling between two HMOs or a continuous frontage of three or more HMOs. For clarity, when undertaking calculations for the 10% policy, only lawful HMOs (either with planning permission or a lawful development certificate) will be considered. In respect of sandwiching, consideration will include properties above, below, behind and in front of a dwelling, as well as those either side.

5.6.4 It is not the intention of the policy to restrict further growth in HMOs. The Councils recognise the importance of HMOs and the private rented sector generally in the housing stock but seeks to ensure that the amenity of more settled residents is not compromised. The policy also aims to ensure that there is satisfactory provision for the storage of waste, since a house occupied as an HMO generates more waste than a family or couple. In addition, the policy also aims to ensure that new HMOs and student accommodation are within reasonable walking distance of a bus stop because access to public transport is essential for most University of Warwick students due to the restrictive parking arrangements on campus.

5.6.4 The policy provides for the application of the 100m radius test to allow HMOs or student accommodation in locations that would not impact on existing residential areas. Since one of the main problems is anti-social behaviour and noise on routes home from the town centre, these criteria are intended to allow HMOs in locations where residential areas would not be affected. The following principles will be used to determine whether a route is a main thoroughfare:

5.6.5 In respect of mixed use areas these are defined as those with a predominance of non-residential uses. For non-residential uses to be predominant they would need to be greater in number than the residential uses within a recognisable area. A judgement on this matter therefore requires consideration of the extent of the ‘area’ and whether that area should be considered mixed use. The following factors will be taken into account when assessing these matters:

Note: Existing student accommodation will be taken into account when assessing amenity impact caused by the introduction of further student accommodation. It is appropriate to ensure that all existing residents amenity should be considered, whomever they are.

In applying exception (ii), even where a proposal is on a main thoroughfare account should be taken of the potential for disturbance along nearby residential streets where, for example, significant pedestrian movements may arise between the application site and the town centre.

5.6.7 Whilst issues with HMOs and student accommodation are focused in Royal Leamington Spa, due to the proximity to the University of Warwick, applying the policy across South Warwickshire allows consistent management of these forms of accommodation thereby avoiding displacing issues elsewhere.

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^[10] Extract from SHMA 2026