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Publication Draft

ID sylw: 66775

Derbyniwyd: 27/06/2014

Ymatebydd: Bishop's Tachbrook Parish Council

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Crynodeb o'r Gynrychiolaeth:

Wish to help devise a sound local plan, but the publication draft is not sound for a number of reasons. The overriding reason is that the housing requirement doesn't take account of mid 2012 population projections. This means the plan is based on outdated data. The 2012 projections show population growth 28.7% less than used for the Joint SHMA. this changes the no. of dwellings required and means less infrastructure investment is needed. This in turn changes the selection of housing sites and allows brownfield sites to be committed before green field sites. This in turn enables a realistic achievable plan to be prepared.

PPG: 2a-003 "Assessing development needs should be proportionate and does not require local councils to consider purely hypothetical future scenarios, only future scenarios that could be reasonably expected to occur." Ensuring there is a supply of sites is necessary with affordable housing. but the Plan also needs to comply with Para 157 of the NPPF. It is also important to keep a balance between jobs and homes.

DTC is also important the JSHMA achieves this, but this needs to be re-examined to address the ONs projections, taking a particular problem with Coventry in to account. The JSHMA indicated a need for 67,536 homes over 18 years across the HMA. The revised projections (based on 2012 ONS) indicate a need for 68,152. However this masks an issue with Coventry's requirement whereby international migration makes up a significant element of the projected increase in Coventry's population. However international students inflow has increased since 2005, but corresponding outflow has not to the same extent (as students are generally resident for 3 years). This indicates that the increase in inflow may be due to international students on courses that are not yet completed. This temporary anomaly is projected forward in the population projections. It does not make sense to provide housing for this population as they won't be there.

If adjustments are made to reflect this, then a worst case scenario for Coventry would be an inflow of 40,000 (instead of 74,000) which is still lower than the JSHMA figure. This in turn would lead to a reduction in the HMA's housing requirement from 68,152 to 51,327.

with this level of housing Warwick District could justify a lower level of housing at the same time as fulfilling the DTC.

The publication draft provides for too many homes and must be revised to reflect the latest projections. Further the JSHMA used an abstract and subjective concept of headship rates. This is critical because small changes in the average household size can alter homes required significantly. It also bases its average household size on the total population. This gives an incorrect result. ONS calculate the population estimates and projections on the total population less those living in communal establishments adding these back into the total population at the end of any calculation. This gives a true average household size which is different to the SHMA household size and varies the relationship between areas as each has a different communal proportion. If the population growth is going to be less, then the household size to use needs to be addressed. different options produce different outcomes. for instance the 2011 census rate would require 6715 homes for an increase of 15,313 people. However the likelihood is that household size will rise rather than fall.

Two other factors will also affect future measures of household size. Over time as affordable homes are reallocated to existing occupants, vacant spaces will become occupied. For owner occupiers, as people find house prices unaffordable, rather than move they tend to stay where they are but extend their properties to accommodate extra children etc. So a calculated outcome can be used to provide the capacity in a lower but acceptable number of homes.

As well as being better in terms of providing the right tenure mix, it is also better from a sustainability point of view as it takes less land, avoids loss of agricultural land, is better from a CO2 emissions reduction viewpoint both from energy used in homes and travel from fossil fuel vehicles, reduces costs and makes all homes more affordable and spreads the homes required around the district, reducing the amount of infrastructure needed by the additional population.

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