Object

Representation ID: 71626

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

The draft should be expanded to refer to the relevant sections of the NPPF and PPG in terms of the purposes and scope of an SPD.

The draft SPD states that affordable housing policies are not defined as strategic policies within the Warwick District Local Plan. Therefore, neighbourhood plans could seek to require a different amount of affordable housing provision within their neighbourhood area, provided there is local justification. Where a ‘made’ neighbourhood plan does include different affordable housing policies to those in the local plan, these
will take precedence where they differ from the Local Plan.
Policy H2 Affordable Housing of the WDC Local Plan does not reference the ability for Neighbourhood Plans to vary the overall 40% District requirement. Reference is made to the sizes, types and tenures of homes being determined “by other local needs surveys and information” but not the overall scale of provision. However, should this element of the SPD be taken forward the text should be updated to reflect that the Local Plan policy requirement is based upon the Strategic Housing Market Assessment evidence and has been the subject of a viability assessment (in line with national policy and guidance). The draft SPD should stipulate that neighbourhood plan policies are not expected to seek in excess of the Local Plan policy requirement accordingly; any that do must be the subject of a neighbourhood plan viability assessment.