Other

Representation ID: 103222

Received: 07/03/2025

Respondent: Richborough - Kineton Road, Wellesbourne

Agent: Turley

Richborough has no objection to the emerging policy direction and agrees that density should be considered in accordance with different types of locations of development.

With regard to the reference to Design Codes, it is recommended that the future policy text for Draft Policy Direction 8 should cross refer to Draft Policy Direction 26 ‘Design Codes’ and the supporting text. Richborough have provided more detailed comments in relation to Design Codes within their response to Draft Policy Direction 26.

Other

Representation ID: 103224

Received: 07/03/2025

Respondent: Richborough - Wellesbourne Road, Wellesbourne

Agent: Turley

Richborough has no objection to the emerging policy direction and agrees that density should be considered in accordance with different types of locations of development.

With regard to the reference to Design Codes, it is recommended that the future policy text for Draft Policy Direction 8 should cross refer to Draft Policy Direction 26 ‘Design Codes’ and the supporting text. Richborough have provided more detailed comments in relation to Design Codes within their response to Draft Policy Direction 26.

Other

Representation ID: 103226

Received: 07/03/2025

Respondent: Richborough - Plough Lane, Bishop's Itchington

Agent: Turley

Richborough has no objection to the emerging policy direction and agrees that density should be considered in accordance with different types of locations of development.

With regard to the reference to Design Codes, it is recommended that the future policy text for Draft Policy Direction 8 should cross refer to Draft Policy Direction 26 ‘Design Codes’ and the supporting text. Richborough have provided more detailed comments in relation to Design Codes within their response to Draft Policy Direction 26.

Yes

Representation ID: 103358

Received: 07/03/2025

Respondent: Mr Stephen Norrie

I support this policy with a bit of hesitation, and I think density levels in specific design codes could be underpinned by a more general minimum density level.

Yes

Representation ID: 103439

Received: 07/03/2025

Respondent: Mrs Christine Easton

I would have thought it obvious that density would be a factor. We would all like less but handled sympathetically would be key.

No

Representation ID: 103482

Received: 07/03/2025

Respondent: Mr Neal Appleton

Density measurements as used currently lead to creeping over-urbanisation. Pockets of settlement historically have high density, with spaces between. Filling in those spaces at the same density ruin the character of a place. Development patterns with varying density should be encouraged.

No

Representation ID: 104203

Received: 07/03/2025

Respondent: Mr Kenneth Chitty

The required minimum density of dwellings should be clearly defined and clearly allow for multiple occupation buildings - e.g. Correctly designed High Rise buildings. Not specifying a minimum density will merely lead to rows of four bedroom detached houses being built.

Yes

Representation ID: 104207

Received: 07/03/2025

Respondent: Ms Rachel Pope

There are now lots of examples of good practice in densification, including from other countries such as the Netherlands. As such this provides an exciting opportunity for innovative and sustainable design.

Other

Representation ID: 104368

Received: 07/03/2025

Respondent: South Warwickshire Foundation trust

We would seek assurance that development density will have due regard for both avoiding any exacerbation or creation of inequalities in the new and incoming populations, whilst also creating communities with good access to infrastructure, as well as minimising the footprint of new buildings.

Yes

Representation ID: 104440

Received: 07/03/2025

Respondent: Mr ROLAND CHERRY

In general greater density in existing urban areas is much preferable to building on our pastoral landscape. Great emphasis must be placed on repurposing brown field sites within urban areas which has the advantage of improving the urban landscape and provides aspirational housing for people close to their place of work - a win win. Many cities have done this very well - noteworthy are the regenerated docks in both London and Liverpool. More areas of West Midlands conurbations should be developed in such a way rather than "exporting" houses as overspill, thus forcing people to commute great distances.

No

Representation ID: 104529

Received: 07/03/2025

Respondent: Mrs Mary Harman

Too vague, open to increase or decrease density at will and forego impact on rural areas, focussing more on the numbers game for sake of meeting targets.

No

Representation ID: 104683

Received: 07/03/2025

Respondent: Mrs Sarah Whalley-Hoggins

Density will inevitably cause developments to be less desirable than others . Residents still need to be able to park cars and this should be off road. There is not enough detail about the implications of density and what is meant by this in terms of design and living conditions.

No

Representation ID: 104686

Received: 07/03/2025

Respondent: Mr Ian Dunning

Finally you're talking about density., but it is weak.

"areas that would be more suited to higher density development"
"respects and enhances the existing neighbourhood character"

This is weak. Build density everywhere. Parents of kids killed by cars will not be comforted by your "respect for neighbourhood character"

Other

Representation ID: 104766

Received: 07/03/2025

Respondent: Stratford-on-Avon Town Council

Densification for its own sake should be avoided. There is a lot to be said in favour of green spaces within towns and urban environments and they should be preserved wherever possible. An alternative to be encouraged is increasing the occupancy of existing buildings, for example by converting unused floors above shops and commercial buildings into residential use.

Yes

Representation ID: 104840

Received: 07/03/2025

Respondent: Fern Arnold

I'm in favour of densification BUT with wildlife corridors. It is important to consider if infilling will affect biodiversity. Places for bats, birds, foxes, hedgehogs, insects etc. Do look at B lines and consult with Plantlife, Buglife and Warwickshire Wildlife Trust etc.

No

Representation ID: 106195

Received: 07/03/2025

Respondent: Acres Land & Planning

This policy doesn’t actually say anything and therefore serves no real purpose. The case for densification has not been made within the text, it simply states that a Design Code will be produced. This is not a policy.

Other

Representation ID: 106218

Received: 07/03/2025

Respondent: Cala Homes (Cotswolds)

Agent: Lichfields (London)

Cala broadly agrees with the approach laid out in Draft Policy Direction 8 to maximise use of land in line with the NPPF but recognises that density ranges may need to vary at different locations to ensure appropriate levels of development, compatible with site characteristics, are delivered across different sites. As stated in relation to DPD 2, it is important that capacity of different land ownerships across the settlement is clearly defined to ensure delivery of the existing, allocated LMAGV is not compromised.

Para 129 of the NPPF notes that planning policies should support development that makes efficient use of land and Para 130 states that is especially important for policies and decisions to avoid low-density building where there is a shortage of land for meeting identified housing needs.

Cala supports the approach of identifying appropriate density ranges in design codes only on the basis that it recognised one size does not fit all. The currently adopted Long Marston Garden Village Framework Masterplan SPD specifies a range of densities according to specific location ranging from 25-55 dph and recommends any design codes which come forward for proposed new settlement E1 carefully consider the densities of the adopted SPD to ensure that the codes do not hinder or conflict with development on the already allocated site. Forthcoming densities should also explore the opportunity to further maximise use of brownfield land where possible.

Yes

Representation ID: 106368

Received: 07/03/2025

Respondent: West Midlands Housing Association Planning Consortium

Agent: Tetlow King Planning

The WMHAPC supports the approach outlined in draft Policy Direction 8, as it aims to optimise land use effectively. Accordingly, the WMHAPC welcomes further guidance through a design code to ensure
that densification maximises affordable housing delivery while maintaining high quality homes that respect the local vernacular.
Future policies on density should allow for flexibility and nuance, considering the relationship between density, dwelling size (including implications of optional space and accessible/adaptable home standards), housing mix, and developable land. Future policies should be viability tested to take these factors into account.
Additionally, future policies should consider that when determining applications, the impact on delivering
a diverse range of housing typologies to meet the needs of different groups should be carefully evaluated, with scope for site specific considerations and case by case assessments where appropriate.

Other

Representation ID: 106509

Received: 06/03/2025

Respondent: Wychbury Developments

Agent: Cerda Planning Ltd

We consider that policy should avoid expressing specific densities, but instead should make reference to
the NPPF and the need to utilise land efficiently and effectively.
This is in the context of a highly material consideration; that being that density is not an indicator of urban
quality, some of the Councils highest valued urban areas deliver densities at what might be considered to
be very high. By way of worked example, a maisonette doubles the density of a building over a traditional
house but has no material effect on the urban environment.
In any event, it is not considered appropriate to defer densities to Design Codes. These will, according to
the SWLP, follow after the SWLP is progressed. This means that the Councils are unable to establish whateach spatial growth site might deliver in terms of housing yield, which in turn makes it impossible to
robustly set out what sites are required to meet the Standard Method and duty to co-operate. It also means
that site viability, and thus deliverability, cannot be established with promoters since the infrastructure
requirements will be fixed by the SWLP based upon sites with an unquantified yield.

Yes

Representation ID: 106645

Received: 07/03/2025

Respondent: Warwickshire Property and Development Group

Agent: Framptons

Draft Policy Direction 8 is broadly consistent with the NPPF (Chapter 11 - Making effective use of land) and we recognise that increasing housing densities can have play a positive role in helping meet local housing needs, address affordability concerns, and ultimately promoting sustainable forms of development by making effective use of land.
For a future policy on densities and associated design codes to be effective, a careful balance needs to be struck between seeking to optimise the density of development and ensuring that other development considerations are appropriately considered.
when the Councils are setting density standards we consider that it is also important density levels are realistic and that they take into consideration: • the Councils own housing mix requirements; • the need for developers to also meet other policy requirements that influence the how much development can be delivered on a site, e.g. green infrastructure and open space standards, the mandatory 10% net gain in on-site biodiversity; and, • the nationally described space standard for housing should the Councils decide that this should also become a policy requirement on the SWLP.
Furthermore, developing and implementing design codes requires significant time and expertise. We therefore have concerns about their use and effectiveness, when planning departments are resource and financially constrained.

Other

Representation ID: 106768

Received: 02/03/2025

Respondent: ms louisa graham

Density of building will be inappropriate and its impact on the character of any area will be detrimental.

There will be overshadowing and loss of privacy. Development will not fit with established building, destroying the look of an area. Density of building will be maximised. Profit over all.

Other

Representation ID: 106963

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land off Mallory Road, Bishop's Tachbrook

Agent: Savills

We support the provision of broad density requirements being proposed and areas suitable for higher density development being indicatively identified. However, the NPPF (paragraph 129) is clear that there are a number of factors which should be considered when assessing whether a scheme makes the most efficient use of land. When it comes to the implementation of minimum density standards, a range should be used to reflect accessibility and potential of different areas (NPPF paragraph 130). Fundamentally, densities should be determined on a site by site basis.
In regards to the production of Design Codes, it is important that these are produced in conjunction with the Sites’ landowners/ promoters / developers to ensure they are deliverable.

Other

Representation ID: 107021

Received: 06/03/2025

Respondent: Ministry of Defence

DTC RESPONSE:

Section 4.10, Policy Direction 8 – Density
The MOD recognises the need for quality design within the planning system. However, there may be
occasions where specific operational or technical requirements of buildings and structures required for
defence purposes can restrict MOD’s ability to change the density of developments to meet local design
2
criteria. It is important therefore that local design codes are not too restrictive and that they recognise the need
for flexibility in such cases.

No

Representation ID: 107513

Received: 07/03/2025

Respondent: Davidsons Homes

Agent: Cerda Planning Ltd

We consider that policy should avoid expressing specific densities, but instead should make reference to the NPPF and the need to utilise land efficiently and effectively.
This is in the context of a highly material consideration; that being that density is not an indicator of urban quality, some of the Council’s highest valued urban areas deliver densities at what might be considered to be very high. By way of worked example, a maisonette doubles the density of a building over a traditional house but has no material effect on the urban environment.
In any event, it is not considered appropriate to defer densities to Design Codes. These will, according to the SWLP, follow after the SWLP is progressed. This means that the Councils are unable to establish what each spatial growth site might deliver in terms of housing yield, which in turn makes it impossible to robustly set out what sites are required to meet the Standard Method and duty to co-operate. It also means that site viability, and thus deliverability, cannot be established with promoters since the infrastructure requirements will be fixed by the SWLP based upon sites with an unquantified yield.

Other

Representation ID: 107602

Received: 07/03/2025

Respondent: National Highways

National Highways believes that this is an LHA matter and have no further comments
to provide.

Yes

Representation ID: 107659

Received: 07/03/2025

Respondent: Cala Homes (Cotswolds)

Agent: Lichfields (London)

Cala broadly agrees with the approach laid out in Draft Policy Direction 8 to maximise use of land in line with the NPPF but recognises that density ranges may need to vary at different locations to ensure appropriate levels of development, compatible with their site characteristics, are delivered across different sites. As stated, in relation to DPD 2, it is important that capacity of the different land ownerships across the settlement is clearly defined to ensure that delivery of the existing, allocated LMAGV is not compromised.
Cala supports the approach for “Appropriate density ranges for different types and locations of development to be indicated in design codes” in the Draft Policy Direction on the basis that this recognises that ‘not one size fits all.’

Other

Representation ID: 107695

Received: 04/03/2025

Respondent: Pete Frteeman

Densification should only be considered in the case of "quality" low rise buildings, "cheek by jowel sprawl” should by avoided at all costs. The recreation of "Los Angeles" in South Warwickshire should not be a desirable objective!

Other

Representation ID: 107738

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land to the west of Southam Road, Long Itchington

Agent: Savills

We support the provision of broad density requirements being proposed and areas suitable for higher density development being indicatively identified. However, the NPPF (paragraph 129) is clear that there are a number of factors which should be considered when assessing whether a scheme makes the most efficient use of land. When it comes to the implementation of minimum density standards, a range should be used to reflect accessibility and potential of different areas (NPPF paragraph 130). Fundamentally, densities should be determined on a site by site basis.
In regards to the production of Design Codes, it is important that these are produced in conjunction with the Sites’ landowners/ promoters / developers to ensure they are deliverable.

Yes

Representation ID: 107816

Received: 05/03/2025

Respondent: Catesby Estates Ltd

Agent: Pegasus Group

This policy is broadly supported as it recognizes a flexible approach to density should be taken. This is consistent with national policy as the NPPF states that densities should be appropriate to the character of the area. Paragraph 130 states that density should reflect the accessibility and potential of different areas. The approach is justified The Guide to Existing Housing Densities Topic Paper provides evidence of the varying existing densities in South Warwickshire.

Yes

Representation ID: 107857

Received: 07/03/2025

Respondent: Taylor Wimpey Strategic Land

Agent: Turley

Taylor Wimpey has no objection to the emerging policy direction and agrees that density should be considered in accordance with different types of locations of development.
In respect of any overarching Design Code to be adopted by the Council, this should give a degree of flexibility to allow consideration on a site-by-site basis and to ensure it remains adaptable to a changing market.