The PPG sets out that there may be circumstances where it is appropriate to consider whether the actual housing need is higher than the standard method indicates. These include growth strategies for the area, strategic infrastructure improvements, meeting an unmet need from neighbouring authorities and where previous levels of delivery or previous assessments of need are significantly greater than the outcome of the standard method. For example, the Cheshire and Warrington LEP?S Building a Better Future Together: Supporting Recovery in Cheshire and Warrington 2021/22 document highlights investment in strategic infrastructure and priority housing, including exploiting opportunities offered by HS2 and Northern Powerhouse Rail. The HBF considers it is important that the proposed housing requirement is viewed as a minimum and barriers are not put in place which may hinder greater levels of sustainable growth. It is considered that the plan could facilitate higher levels of growth by providing greater flexibility. The HBF considers that Warrington is ideally located to achieve high levels of growth, providing it is based upon an appropriate development strategy.

The HBF generally supports the Council in setting a density policy and making efficient use of land in accordance with NPPF . However, the HBF considers that it is important to ensure that the prioritisation of higher density development and the use of PDL does not compromise the delivery of homes in sustainable locations to meet local needs. The Council will need to ensure that consideration is given to the full range of policy requirements as well as the density of development, this will include the provision of M4(2) and M4(3) standards, the NDSS, the provision of cycle and bin storage, the mix of homes provided, the availability of EV Charging and parking, any implications of design coding and the provision of tree-lined streets, highways requirements, and the potential requirements in relation to Biodiversity Net Gain, changes to the Building Regulations requirements in relation to heating and energy and the Future Homes Standard. The HBF also considers it will be important to consider the future deliverability of intensely developed residential schemes, which will be dependent on the viability of PDL and demand for high density urban living post Covid-19.

It appears this stepped housing requirement is intended to reduce the backlog in housing supply at the start of the plan and is being used by the Council as a way of achieving a five-year land supply position on adoption. It is important to remember that this is not just a theoretical mathematical numbers exercise but represents actual households in housing need today, so it is unreasonable and unequitable to expect them to wait until later in the plan period before their current housing needs are addressed.

The HBF does not dispute the need for affordable housing within Warrington and indeed supports the need to address the affordable housing requirements of the borough. The Local Housing Need 2021 report identifies a need for 433 affordable homes per annum in Warrington, this is an increase from the previous 377 affordable homes per annum identified in the previous assessment. The Local Plan Viability Assessment (August 2021) highlights issues with affordability for some of the typologies and site allocations. Therefore, the HBF have concerns that this policy will lead to the non-delivery of homes in the Borough. It should be noted that the NPPF establishes the importance of viability to ensure that development identified in the Plan should not be subject to such scale of obligations and policy burden that their ability to be delivered might be threatened.

The Nationally Described Space Standards (NDSS) as introduced by Government, are intended to be optional and can only be introduced where there is a clear need and they retain development viability. As such they were introduced on a ?need to have? rather than a ?nice to have? basis. The Council will need robust justifiable evidence to introduce the NDSS, based on the criteria in the PPG. The HBF does not consider that the Council can provide the evidence to support the need for this optional standard as part of the policy and as such it should be deleted. The HBF considers that if the Government had expected all properties to be built to NDSS that they would have made these standards mandatory not optional.

if the Council wishes to adopt the higher optional standards for accessible & adaptable homes the Council should only do so by applying the criteria set out in the PPG. PPG identifies the type of evidence required to introduce such a policy, including the likely future need; the size, location, type and quality of dwellings needed; the accessibility and adaptability of the existing stock; how the needs vary across different housing tenures; and the overall viability. The Local Housing Needs Assessment provides the Council?s evidence for this policy. Unfortunately, this evidence is severely lacking on the majority of these elements. This lack of evidence does question how the percentages identified in the policy were derived. It is incumbent on the Council to provide a local assessment evidencing the specific case for Warrington which justifies the inclusion of optional higher standards for accessible and adaptable homes in its Local Plan policy

There are requirements for custom and self-build plots however set out within the individual site allocations requirements. The HBF considers that the provision of a certain percentage self-build plots on schemes above a certain size adds to the complexity and logistics of development and may lead to the slower delivery of homes. The provision of self-build plots on new housing developments cannot be co-ordinated with the development of the wider site. At any one time, there are often multiple contractors and large machinery operating on-site, from both a practical and health & safety perspective, it is difficult to envisage the development of single plots by individuals operating alongside this construction activity.

The HBF considers that the Councils should comply with the Government?s intention of setting standards for energy efficiency through the Building Regulations. The key to success is standardisation and avoidance of individual Council?s specifying their own policy approach to energy efficiency, which undermines economies of scale for product manufacturers, suppliers and developers. Heat networks are one aspect of the path towards decarbonising heat, however currently the predominant technology for district-sized communal heating networks is gas combined heat and power (CHP) plants. Over 90% of district networks are gas fired. As 2050 approaches, meeting the Government?s climate target of reducing greenhouse gas emissions to net zero will require a transition from gas-fired networks to renewable or low carbon alternatives such as large heat pumps, hydrogen or waste-heat recovery but at the moment one of the major reasons why heat network projects do not install such technologies is because of the up-front capital cost. The Council should be aware that for the foreseeable future it will remain uneconomic for most heat networks to install low-carbon technologies.

The HBF does not wish to comment upon the acceptability or otherwise of individual sites. It is, however, important that all the sites contained within the plan are deliverable over the plan period and provide a range of development opportunities. The Council?s assumptions on sites in relation to delivery and capacity should be realistic based on evidence supported by the parties responsible for housing delivery and sense checked by the Council based on local knowledge and historical empirical data.43. The Plan should ensure the availability of a sufficient supply of deliverable and developable land to deliver the Council?s housing requirement. This sufficiency of housing land supply (HLS) should meet the housing requirement, ensure the maintenance of a 5 Year Housing Land Supply (5YHLS), and achieve Housing Delivery Test (HDT) performance measurements. When selecting housing sites for allocation the Council should select the widest possible range of sites by both size and market locations to provide suitable land for small local, medium regional and large national housebuilding companies.

This will help to ensure that action will be taken when a target is not met, and a policy needs reviewing.