BASE HEADER
Gwrthwynebu
Publication Draft
ID sylw: 65516
Derbyniwyd: 27/06/2014
Ymatebydd: Sharba Homes Group
Asiant : PJPlanning
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
There is no explanation as to how the figure from the SHMA has been translated from an objectively assessed need ('Policy Off' figure) for Warwick to an overall housing requirement ('Policy On' figure).
A two stage process should be carried out: 1) use of SHMA toi identify OAN. 2) take account of other considerations to arrive at a final housing figure (e.g DTC, SHLAA). This can then give a sound figure for the Plan.
The Plan has only looked at stage one and is therefore a "policy off" figure and is unsound.
The plan proposes a high level of windfall housing (19.3% or 138 dpa). Whilst a degree of windfalls are allowed, this should only be if there is compelling evidence.
The 2014 report on 5 year supply has not been published and the 2013 report makes no allowance for non-implementation.
There is therefore not enogh evidence to demonstrate how this approach can be achieved, and the reliance on windfall sites in this way risks a serious undersupply of housing.
Please see the attached representation submitted by PJ Planning on behalf of Sharba Homes Group