BASE HEADER

Gwrthwynebu

ID sylw: 68986

Derbyniwyd: 22/04/2016

Ymatebydd: CPRE WARWICKSHIRE

Cydymffurfio â’r gyfraith? Nac Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Heb nodi

The updated SHMA has a large number of defects which make its conclusions seriously flawed. At best the resultant Objectively Assessed Need is subject to great uncertainty; at worst it is not credible at all. yet the Local Authorities in the HMA have not done any critical analysis of the report and have accepted its findings in their MOU. inflexible approach is certain to be found wanting as the implementation of the plan unfolds. Meanwhile a great deal of damage will have been done. The position is even more serious because the modification to policy DS20 opens the door for even further housing development in future to meet unspecified housing needs in other areas.
Coventry's inability to meet it housing need results in proposed housing provision of 18,640 over the full twenty year period to 2031, which is over 55% higher than its own OAN. yet the plan does not explain why Coventry can't meet their OAN; how the redistribution has been arrived at. Nor does it take account of GB and other constraints or the wider effects of transferring need.

The Warwick Local Plan is therefore fundamentally unsound, quite apart from its unquestioning reliance on a deeply flawed Strategic Housing Market Assessment. The approach taken is, quite simply, indefensible.

The level of housing proposed (932dpa) is unrealistic.

the over provision will have a range unintended consequences:
-green field sites will be developed rather the brownfield sites
-vacancy rates will accelerate
-increased longer-distance commuting and lead to greater car dependency
-higher service and infrastructure costs
-destructive of the housing opportunities available to newer, younger and less well-off households
-Very substantial areas of Green Belt will be lost
-inhibits necessary adaptations to new problems and unforeseen opportunities

The plan fails to give sufficient weight to national policy in that:
-the presumption in favour of sustainable development does not apply in the Green Belt
-need for housing will rarely be sufficient to constitute the very special circumstances required for inappropriate development in the Green Belt