Testun llawn:
The level of housing growth set out in Policy DS6 is 12,860 dwellings over the period 2011-2029, or 714 dwellings per annum. This purports to be based on the objectively assessed need identified in the Coventry & Warwickshire Joint Strategic Housing Market Assessment (SHMA) 2013. However the objectively assessed need set out in Table 97 of the SHMA was in fact a slightly higher figure of 720 dwellings per annum - an additional 108 dwellings over the plan period. This is a small difference but it should be provided for in order for the plan to be robust.
Of greater concern is the fact that the plan does not provide for any of the housing need that is very likely to arise from neighbouring districts that cannot meet their own need. The report to Council on 23rd April 2014 included Appendix 5 concerning the Coventry and Warwickshire Duty to Cooperate. This report stated that a 'significant risk' to the delivery of the Housing Market Area's (HMA) Objectively Assessed Need (OAN) is whether each of the Councils within the HMA have sufficient site capacity within the boundaries to deliver their identified OAN. In particular there is a significant risk that Coventry City Council will not be able accommodate 23,600 dwellings (1,180 dwellings per annum) within the City boundary. In addition, there is a risk that authorities within the Coventry and Warwickshire HMA will be asked to accommodate a growth resulting from a shortfall of housing capacity in Birmingham.
Birmingham City Council's Proposed Submission Draft of its Local Development Plan identifies an initial shortfall in meeting its OAN by around 29,000 dwellings. Coventry City Council's Strategic Housing Land Availability Assessment 2012 set out a capacity of 14,667 dwellings between 2011-2028, whereas the OAN for Coventry between 2011-2031 is 23,600. It therefore seems very clear at this stage that a large amount of housing provision will need to be allocated to neighbouring districts to Coventry and Birmingham under the Duty to Cooperate. The Publication Local Plan makes very little provision for accommodating housing requirements from neighbouring districts under the Duty to Cooperate - this will be discussed further in representations under Policy DS20.
The Publication Plan does not provide for an adequate time horizon. Paragraph 157 of the National Planning Policy Framework says that local plans should be "drawn up over an appropriate time scale, preferably a 15-year time horizon, take account of longer term requirements, and be kept up to date". The plan period is to end in 2029, which at this point provides a time horizon of just under 15 years. However at the likely point of adoption of the Local Plan - April 2015 - it will only have a time horizon of 14 years. The SHMA set out the assessment of OAN to 2031. In order for the Local Plan to provide for the OAN the plan period should be consistent with that used in the SHMA. Rugby Borough Council is currently consulting on a Local Plan Development Strategy which would extend their plan period to 2031, consistent with the SHMA assessment period. It is considered that Warwick District Council should also take the opportunity now to ensure that their plan has a sound time horizon, consistent with guidance in the NPPF.