Issue and Options 2023
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New searchQuestions H2-1 and H2-2 4.38. Within issue H2 on providing the right tenure and mix type of homes, the above analysis emphasises both the role of the private sector in delivering dwellings of all tenures (including affordable) together with the challenges for increasing provision of affordable homes taking account of the ownership of land across the plan area. To achieve increased delivery of housing, especially affordable is only feasible and realistic where there is close partnership working between private and public sectors. 4.39. Table 10 on page 105 of the consultation draft Local Plan explains the level of need for affordable housing. This is 547dpa for Stratford-on-Avon District and 839dpa for Warwick District which (63% and 103% of the respective overall housing needs for each authority as assessed in the HEDNA). Such levels are not viable to deliver even with partnership working of the private and public sectors. 4.40. Whilst there is a need for affordable housing in both authorities, to ensure that its delivery is directed to residents in need within the respective authorities there should be a separate target for each area. 4.41. We do not consider that affordable housing targets should be refined to apply varying requirements within each authority as this would only be appropriate if there is clear evidence in terms of: A) The need for affordable housing including size and tenure including from the housing waiting list; B) How affordable housing need compares to that for market homes (including size) to ensure socially mixed communities; C) That the level of need will not affect viability of development; D) There is sufficient acceptable land to meet the need; and E) That the phasing of delivery is appropriate without either displacement of need into other areas or it resulting in over-provision with households relocating across the plan area. 4.42. These are all matters which would mean that the approach of the plan is not addressing the wider needs of the area as envisaged in NPPF paragraph 61
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Question H3 4.43. Issue H3 references the analysis with respect to the size of dwellings to be sought according to tenure and district in the Joint Plan area. It also references the optional national space standards. The analysis above (Table 3) illustrated that household size across the Joint Plan area has not changed as envisaged. Whilst this provides information on the accuracy of the forecasts of need, the 2021 Census also confirms the very significant role of the current housing stock for meeting existing and evolving needs. 4.44. Unless the authorities are also seeking to ensure necessary adaptation of the existing stock to achieve these standards, there will be significant viability concerns regarding compliance with the requirements. Additionally, there is no evidence that dwellings currently being provided do not adequately meet the needs of residents. This collectively means that we do not consider any space standards are required (Answer H3d). 4.45. For considering housing needs from outside of South Warwickshire (Issue H4), as explained we agree that the Joint Plan area should provide sites for between 5,000 and 10,000 dwellings (in addition to that arising from the Plan area as calculated in the HEDNA) to contribute towards unmet needs from Birmingham (page 112 and questions H4-1 and H4-2). 4.46. For question H4-2 regarding where unmet need should be provided, this should be delivered on sites at sustainable locations, to include Southam – which approach is consistent with and the adopted and emerging strategy. This view is taken as there is no appropriate or justified mechanism, especially for private homes which will represent the majority of future delivery; which restricts where residents associated with the unmet need can live. 4.47. We note a desire for self build homes as outlined in issue H5. We consider that the Councils (in first instance) should seek to ensure this requirement is addressed from specific promoted sites for this purpose. 4.48. For gypsy and travellers (Question H6), we do not consider that pitches should be provided within large scale general housing sites taking account of the specific social and cultural needs of this community, and their rejection of bricks and mortar.
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Issue C4: New Buildings 5.1 We do not consider that there is any justification for seeking achievement of standards on carbon uses which exceed building regulations. 5.2 The Government have set out a clear roadmap to low carbon homes that will alongside the decarbonisation of the national grid ensure that the Government can meet its commitments to net zero by 2050. 5.3 Government recognises that the improvements in energy efficiency of new homes should be a transition which ensures that new homes continue to come forward to meet housing needs whilst still be sufficiently challenging to significantly reduce the carbon emissions of new homes from 2025. 5.4 There is no requirement or justification for additional standards to be placed on development through local plans.
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Issue C9: Mitigating Biodiversity loss 5.5 We do not consider that there is any justification for setting specific measures beyond the levels set by Government in the Environment Act. This is because the imposition of additional measures does not reflect the specific characteristics and opportunities alongside constraints which will vary from site to site.
Issue D3: Designing adaptable, diverse and flexible spaces 6.1 We do not consider that there is any justification for seeking to define minimum densities which must be achieved across the plan area, this this will not fully reflect the specific characteristics and opportunities alongside constraints which will vary from site to site.
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Issue T1: 20-Minute Neighbourhoods 7.1 For the reasons set out in response to Chapters 4 and 6 above, we support the principle of the 20-minite neighbourhood.
