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Gwrthwynebu

Revised Development Strategy

ID sylw: 59354

Derbyniwyd: 02/08/2013

Ymatebydd: Bishop's Tachbrook Parish Council

Crynodeb o'r Gynrychiolaeth:

The 12,300 new homes proposed in the RDS, 1500 more than the number proposed in the Preferred Options consultation, is not an objective assessment based on the latest projections for the population expected by 2021 and 2029.

It is more than the number for Coventry (11,373) and this is a city currently with population of over 316,000.

Although the high number might be aspirational it is not realistic, as it is beyond the physical capacity of the usable part of the district to provide it, the infrastructure to support it and the local economy to provide related employment.

Because of the large amount of Green Belt in the district (80%) and the limited capability of the urban area to take very much more development, such a large amount of new housing is being allocated to the rural part of the district using greenfield land of equal or better value than the Green Belt.

Warwick urban area density is at least equal to or more than a densely populated city (after allowing for Green Belt Land).

This will not achieve the Strategic Vision of the Authority "to make Warwick District a great Place to Live, Work and Visit," but will be much worse at a range of levels.

The consensus within the Parish, and across the district is that this level of population growth, does not feel right.

There has been an 18% population increase over the last 20 years (1991-2011):

* Can a further 20% over the next 15 years really be required?

* Is a population growth increase from 0.9% p.a. to 1.33% really likely particularly with the current poor economic situation and a long slow recovery ahead?

* How has the district arrived at this unrealistically high growth estimate?

It is important to ensure that the evidence base is up to date in order to meet NPPF 47 requirement for the number of homes to be provided to be objectively assessed using a proper evidence base.

The NPPF, para 6 states that "The purpose of the planning system is to contribute to the achievement of sustainable development.

NPPF paras, 54 and 55 regarding housing in rural areas should be part of that objective assessment as well as NPPF 109 regarding the protection and enhancement of valued landscapes.

The current consultation plan is not sustainable as so defined and will not be accepted by the Inspector..
The proposed aggressive levels of housing growth proposed will require the loss of large areas of outstanding Warwickshire landscape previously recognised has having unique value by planning inspectors, the Council's landscape consultants, residents and visitors.

Thers is also a question of the level of housing and population growth that the district can reasonably absorb, without undermining the quality of life for those that live here and irreparably damaging the historic context of Warwick district.

In this regard, NPPF , para 10 requires "Plans and decisions need to take local circumstances into account, so that they respond to the different opportunities for achieving sustainable development in different areas."

Estimates of housing numbers for the future must be based on ONS statistical projections. [The representation sets out a detailed argument that the population estimates used for calculating the housing target are too high, in the light of 2011 census data. Since 2011, the statistical data shows a reducing population projection which is hovering around the BTPC study result of 5,400 homes.]

The analysis (based on latest ONS projections and Council's December 2012, G L Hearn Economic & Demographic Study) shows that in terms of housing numbers this reduces the ONS projection from the 2011 estimate of 12,150 homes, to the 2012 estimate of 6,500 homes, which is anticipated, if it falls in line with Hearn's estimate, to drop to about 5,970 homes.

The Public Administration Select Committee reported on 28th July 2013 that it had found ONS migration figures are "not fit for purpose". So caution must be exercised. The joint SHMA should come up with the most up to date guide.

How was the 12,300 target arrived at?:

The 12,300 homes target is not adequately explained in the RDS. The conclusion in RDS1.10 suggests that it may be due to the 2011 ONS data (12,130) but it may also have other objectives.

But for very many people in the district it is not believable.

They remember that the existing local plan was adopted in 2007 following a Public Inquiry during 2006 into objections to the proposed plan and was in accordance with the Planning & Compulsory Purchase Act 2004 when the current local plan was adopted in 2007.

The local plan, which is still up to date except where the NPPF is not in agreement with any particular policy, was adopted only 6 years ago and It settled many questions of concern for the community and setting a contract with the community.

The RDS, with its dramatic change to the size of the district and the concentration of very large amounts of new housing on land that is currently subject to Rural Area policies, is seen by many as a breach of that contract.

As a result there is much concern and indeed, anger, at the proposals being consulted on and in the way that the door has been left open by the District Council for planning applications to be made that negate the purpose of any local plan and the consultation process to establish it.

Since the Inquiry was only 6 years ago, BTPC draws attention to certain key findings of the inspector, particularly where he talks about the plan after 2011-

"This Local Plan only covers the period to 2011 in the absence of firm housing or employment figures for the period beyond. The housing figures derived from the RSS for 2011-2021 are indicative only. Nevertheless, the District Council is able to show that there is no need to identify further housing sites. (Para 11.3.8)

The balance of 2,210 dwellings to be provided between 2005 and 2021 equates to 138 dwellings per year. The District Council's estimates of windfall sites (based on past trends and emerging Local Plan policy) equate to an annual average of 282 dwellings in the urban area and 11 dwellings per year in the rural area. On the basis of these figures, I am satisfied that the District Council is justified in not identifying sites to meet the requirement to 2021. "

In paragraph 11.3.10, in respect of whether the Plan should identify a 10 or 15 year supply of housing, he finds that "New Table 5 of revised Appendix 2 shows how the residual housing requirement for the period 2005-2021 can be met. This particular objection is therefore satisfied. "

Table 5 in appendix 2 of the 2007 local plan states the following

Source
Dwellings
RSS housing requirement 2001 - 2021 8,091

Dwellings completed 2001 to 2005
3,324
R
remaining dwellings to be provided
4,767

By the end of 2011/12 the dwellings completed had increased to 6,084. Deducted from the original requirements this leaves 2,007 remaining to be provided by 2021.

If 2,007 is the plan for 10 years, then for 18 years until 2029 it might be 200x18= 3,600.

The December 2012, the Economic and Demographic Forecasts Study prepared by GL Hearn states that for the 18 year plan period a population increase of 8,500 persons is expected or 3,705 dwellings (similar to adopted plan target).This projection (which ties in with census findings - set out in submitted table) suggests an annual increase in the population of 473 people which compares with a previous estimate of 914.

Over the 20 year period 1991 2021 the District has done its part in accommodating growth- with its population growing by 21.74% as compared to 15.32% for England as a whole.

So how did 2,007 become 12,300 when it may have been expected to be about 3,600?

The 2012 Preferred Option document was based on a need for 10,800 homes.

Understand that 87% of respondents considered this to be too high. The RDS 4.1.1 describes it as an interim level of growth dependent on the joint SHMA. This should also take into account employment need.

When plan-making, NPPF, para 155 requires "Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made."

A wide section of the community is engaged and would wish that it was proactively so. But this requires a listening district council.

Homes and jobs go hand in hand:

NPPF, para 156. States Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver the homes and jobs needed in the area.


* Why are significant new jobs required when unemployment in the District is low (1.6% of the working population claiming Job Seekers Allowance June 2013 )

* The District has a jobs density of 0.95 - this means that for every person of working age (16-64) living in the District there are 0.95 jobs in the District.

* (significantly above average for the West Midlands or England (0.75 and 0.78 respectively). "Overall there is a relatively good jobs-homes balance currently." (source: December 2012, the Economic and Demographic Forecasts Study)

* Until the joint SHMA is received, the 12,300 household cannot be considered as a valid consultation.

* Across the neighbouring authorities, jobs ought to follow unemployment so far as it is sensible to do.

* Since Warwick District's unemployment count is very low, and job availability is still very fragile, building a larger volume of homes than ever done before does not seem to be a good strategy.

* It could result in a dramatic employment problem.
* Unemployment is significantly higher in other parts of Warwick (detailed figures given) .New jobs in the region should be directed towards these more deprived areas.

* must not go down the same road as Coventry by getting incomers living here and then hope new jobs will be generated. That is not a good plan
* concerned by a statement made by a Warwick District Council planning officer at the Planning Committee Meeting on 23rd July referring to planning application W0607 that house building is a good thing because it generates jobs in construction.

Employment in construction is a good thing (but is temporary), but it cannot be a justification for approving unnecessary house building

* Even if the Coventry gateway development is approved it would only produce about 1,270 jobs for Warwick district residents and some of those may not be new jobs, just a transfer of location.

* If 5,400 homes are built approximately 10,000 jobs will still be needed and that is at a time when whilst may have the employees, we may have the land, but we still need the employers

Duty to Cooperate

The Inspector Examining of the Coventry Local Development Plan - Core Strategy found Coventry Council had not engaged constructively with neighbouring local planning authorities on the strategic matter of the number of houses proposed in the Plan and consequently it has not sought to maximise the effectiveness of the plan making process.

Coventry had a Core Strategy which made provision for some 33,500 dwellings (of which 3,500 would have been in in Warwick?).

That plan was withdrawn and a new plan( now being examined) made with a provision for 11,373 houses - a significant reduction in housing numbers. (para 5 of the report). Was this 3,500 in Warwick included in the then 10,800 consultation exercise? If so, it was not obvious in the consultation documents.

In the "Statement of Common Ground and Cooperation for the Coventry, Solihull and Warwickshire Sub-Region (SOCG)":

(para 4.2)current evidence shows that all member authorities are capable of meeting their housing requirements within their borders and there is no requirement for any local authority to meet any part of its housing requirements in another area.;

(Para 4.3) local planning authorities in the sub-region will continue to plan to accommodate their own needs. However, if an authority cannot accommodate its own needs (because of an increased housing requirement and because of strong evidence of constraints on the provision of housing sites within its boundaries) then, and only then, would the shortfall be addressed through discussions with neighbouring authorities within and beyond the sub-region.

* Since the outcome of this situation was indeterminate, the Duty to cooperate was not demonstrated;

* This housing arrangement did not take into account employment need;
* if there was an initial inclusion of 3,500 housing in the Warwick target to serve Coventry and this remains in the 12,300 then it should be removed to comply with the SOCG agreement.

Coventry may be correct to limit their increased housing requirement because they already have a housing/ jobs imbalance and it would also reduce the risk of not being able to make their provision within their boundary.

An essential part of the joint SHMA consideration should be to establish the capacity of each area to meet its own need and limit expansion to that capacity.

All the more important to make a realistic assessment of need rather than an aspirational assessment that cannot be made to work.

Stratford has recently announced a new Gaydon development to serve JLR. This will have a significant effect on Warwick district and will reduce demand on it for housing but will be the nearest centre for shopping and other services.

Stratford are not in the SHMA and do not seem to have cooperated with its neighbours. It would seem that there is a danger that when their plan is examined, it will be similarly rejected.

The same could happen to our plan, even though attempts were made to cooperate.

Housing Land Supply:

The May 2013 HLS document uses the current consultation figure of 12,300 which is not substantiated by the joint SHMA yet and the consultation is not yet ended.

Therefore, 10,800 is the figure that has been consulted on and this was objected to by 87% of the respondents.

BTPC's calculation shows that the objectively assessed requirement for the locality is 5,400. This gives 3 options in terms of accommodating the housing increase.

A detailed table at para 3.1 of representation sets out site allocations for the plan period 2011-2029. The table sets out a range of options for meeting the housing land requirement for various range of housing targets including the RDS target, and suggests alternative housing supply solutions.

The option with the maximum support of the community, provides the level of new homes that will be needed , and is achievable in the time scales available as follows:

* Column D is an option for 5,400;
* It omits Kenilworth and Redhouse Farm, Green Belt sites;
* It omits Myton gardens, East of Whitnash and all greenfield sites;
* It reduces villages to 300 across all villages;
* It reduces windfall allowance to 2,150;
* It reduces the requirement for vacant dwelling return to 250 over the 18 year period;
* It omits Old Town regeneration & Warwick Town regeneration.

5 Year Housing Supply:

The June 2013- 5 year housing land supply shows that the District does not have supply of available and developable land identified.

Of 12,300 said to be required, the 5 year supply is calculated as 4,550 giving a 2.8 year supply. This is not in compliance with NPPF requirements in respect to demonstrating a 5 year land supply (para 49).

It is essential to choose a strategy that the district can justify and which provides the 5year supply required. BTPC has found that:

a. The calculation of the 5year supply required for 12,300 is incorrect ; and

b. If the 12,300 option is chosen, not only is it way beyond that which an objectively assessed need requires, it is almost impossible to ever get a 5 year supply because of the time allowed for implementation.

The 5 year housing Land Supply for each of 3 options (12,300, 10,800, 5,400 dwellings)is shown in detailed table at para 4.4 of the representation.

It is concluded that if the correct actions are taken ( as set out in the representation) then the 12,300 option still does not give a 5 year supply whereas both the 10,800 and 5,400 options do give a 5.11 and 10.69 year housing land supply.

In order to protect the District's ability to produce a plan-led Local Plan by complying with NPPF49, the 5 year plan should be brought up to date without delay.