BASE HEADER
RDS1: The Council is adopting an Interim Level of Growth of 12,300 homes between 2011 and 2029
Gwrthwynebu
Revised Development Strategy
ID sylw: 55439
Derbyniwyd: 29/07/2013
Ymatebydd: Grevayne Properties Ltd
Asiant : Cerda Planning Ltd
It is welcomed that the Council recognise that interim housing figure could and should change as result of more up to date evidence as it emerges.
Important however that the Council recognise the important provisions of the NPPF, in particular the -need to meet the full objectively assessed housing needs, and the need to boost significantly the supply of housing.
The Council are therefore invited to re-assess housing figures increasing the requirements to reflect the historical -local growth; apply the ONS figures with some caution; and recognise the important requirement to meet the -full objectively assessed housing need.
Gwrthwynebu
Revised Development Strategy
ID sylw: 55444
Derbyniwyd: 29/07/2013
Ymatebydd: Jim Darling
Asiant : Cerda Planning Ltd
Policy RDS 1 is concerned with delivering an appropriate level of housing growth across the District. It is -presently noted as an interim figure, at 12,300 homes.
It is welcomed that the Council recognise that interim housing figure -could and should change as result of more up to date evidence as it emerges.
Important however that the Council recognise the important provisions of the NPPF, in particular the -need to meet the full objectively assessed housing needs, and the need to boost significantly the supply of -housing.
The Council are therefore invited to re-assess housing figures increasing the requirements to reflect the historical -local growth; apply the ONS figures with some caution; and recognise the important requirement to meet the -full objectively assessed housing need.
Gwrthwynebu
Revised Development Strategy
ID sylw: 55450
Derbyniwyd: 29/07/2013
Ymatebydd: Circles Network and Sydni Centre
The majority of people commenting did not agree on 12,300 new houses were Necessary neither are they wanted by the local population.
There are many Houses standing empty.
Gwrthwynebu
Revised Development Strategy
ID sylw: 55452
Derbyniwyd: 29/07/2013
Ymatebydd: Thomas Bates & Son LTD
Asiant : Ms Julie Cross
Query the level of windfall provision (2,800) that comprises some 23% of the total housing requirement. Including Small Urban SHLAA Sites' (300) and 'Consolidation of Existing Employment Areas' (450), means that almost 29% of the housing requirement proposed is unidentified.
NPPF advises Local Planning authorities that they may make allowance for windfall sites in the five- year supply if they have compelling evidence that such sites have consistently become available and will continue to provide a reliable source of supply.
This has not been the case in Warwick District that currently has only a 2.6 year supply of housing land.
Refers to recent Government and PINS advice to Maldon District Council:
* confirming the importance of meeting objectively assessed needs and the need to look at all reasonable options to fulfill this, for example by expanding growth on existing preferred sites etc.
* Without a five year land supply the local planning authority were vulnerable in the case of a planning appeal and suggestion that that Council may want to look at the possibility of bringing forward a number of smaller and more deliverable sites in the short term to boost its five year supply.
In the context of the above requests that the local plan should be amended to include a policy or supporting text that confirms that:
Proposals for housing submitted in respect of the allocations as specified, and in accordance with the phasing indicated, will be approved where the proposed scheme is in accordance with the plan.
Gwrthwynebu
Revised Development Strategy
ID sylw: 55462
Derbyniwyd: 29/07/2013
Ymatebydd: Warwickshire County Council Physical Assets Business Unit
Asiant : Savills
Notes the increase in the proposed level of housing growth to 12,300 dwellings, which is above both the former Regional Spatial Strategy target and the latest household projections.
Wishes to reserve its position on the Council's proposal to adopt an interim level of growth and the proposed housing numbers until Joint SHMA has been completed and this evidence base is taken into account as part of the further revision of the Local Plan
Gwrthwynebu
Revised Development Strategy
ID sylw: 55477
Derbyniwyd: 05/07/2013
Ymatebydd: Emma Brown
Too many houses proposed across the District
Gwrthwynebu
Revised Development Strategy
ID sylw: 55480
Derbyniwyd: 27/06/2013
Ymatebydd: Mrs J Bradley
Concerned that there is to be consultation with Coventry City Council on their housing plans.
Gwrthwynebu
Revised Development Strategy
ID sylw: 55481
Derbyniwyd: 05/07/2013
Ymatebydd: Gill and Steve Hawkins
The amount of housing is far too high. Purpose built accommodation for students would release existing housing and reduce the amount of land required
Gwrthwynebu
Revised Development Strategy
ID sylw: 55482
Derbyniwyd: 24/07/2013
Ymatebydd: Roxhill Developments Ltd
Asiant : Oxalis Planning
Notes that an adopted housing requirement of 12,300 homes between 2011 and 2029 is an interim policy position and welcomes the recognition that this may change following the ongoing evidence gathering, and cooperation with neighbouring authorities.
However would also support the retention of the current methodology applied by Warwick District to informing and establishing housing requirements.
It appears the approach has been based around a desire to directly translate local economic aspirations and ambitions into a housing and development strategy (RDS, Section 4.1, pages 10 - 13).
This includes explicit recognition of the economic and job creation opportunities presented by the 'Coventry Gateway' employment development, including a technology park, recently positively considered by both Warwick District and Coventry City Councils.
The employment land policy approach proposed with regard to this sub regionally significant employment site is also supported (Policy RDS8).
Warwick District clearly forms part of a wider housing market with neighbouring authorities, reflected in the fact that various shared evidence and technical work has historically been undertaken jointly between Warwick District, Coventry City, and Nuneaton & Bedworth Councils.
Supports such an approach which is in accordance with NPPF, (para 17).
The Warwick District SHMA of March 2012 appears to have been undertaken in isolation of any consideration of the wider housing market. It was also published in advance of the publication of the final National Planning Policy Framework (NPPF).
Therefore welcome the references to a joint SHMA now being undertaken by Coventry City, Warwick District, Rugby Borough, and Nuneaton & Bedworth Borough Councils which understand will report late summer 2013.
That work was specifically required by the Inspector during the examination of Coventry City's Core Strategy as a response to the significant deficiencies and weaknesses identified in the approach taken by Coventry City.
In the absence of the joint approach now being taken to understanding the housing market, it seems likely that Warwick District's Local Plan would too have faced similar criticisms and questions by an Inspector at examination.
It will also be essential if the Council is to demonstrate that it has met the requirements of the Duty to Cooperate.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56173
Derbyniwyd: 22/07/2013
Ymatebydd: Mr & Mrs George & Jennifer Haynes
Appreciate the need for some new houses but the draft plan for more than 12,000 is totally over the top.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56206
Derbyniwyd: 29/07/2013
Ymatebydd: Budbrooke Parish Council
The overall estimated residential development growth considered unrealistically high and untenable and significantly out of proportion to the local need.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56227
Derbyniwyd: 29/07/2013
Ymatebydd: Ms Ailsa Chambers
Concerned that the number of new houses proposed within the new local plan appears to greatly exceed the projected housing demand in this region. Agrees that the plan should aim to meet projected housing needs but, given the pressure that the proposal already puts on the local environment, exceeding the projected need will only exacerbate these problems.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56230
Derbyniwyd: 25/07/2013
Ymatebydd: Mr. A. Burrows
The assumptions about housing need for the district are still flawed.
Support the concerns raised by Ray Bullen of Bishops Tachbrook which are supported by many of the Parish Councils. Urges the Council to take full heed of this work and to revise proposals accordingly, and significantly reduce the proposed number of new houses.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56246
Derbyniwyd: 29/07/2013
Ymatebydd: Mr Matt Western
Not convinced by the ONS's forecasts for population.
* There should be a forecast for 2030 and another for 2050. Most economists agree that UK population will start to fall away mid-century.
* Surely Local Plan cannot be fully considered through consultation until the Joint SHMA is available and made broader, more fully fledged proposals that meet the needs of the wider area and so avoiding duplication and ensuring?
Despite the huge impact on the area, the matter of HMOs and students seems to get little coverage. Given the scale of the issue, the Local Plan should address how in future it expects to balance the town between long-term residents and students etc. Advocates more block development and a moratorium on the conversion of existing housing stock which has reduced the availability for young home-makers and families. This is contributing to local housing shortage.
Urges WDC to consider the conversion of Riverside House and the Fire Station to student blocks with the Council retaining 51% ownership of the sites for future revenue generation.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56250
Derbyniwyd: 29/07/2013
Ymatebydd: Mr Peter Kerr
The projected figure of an additional 6.600 new houses seems excessively high and with a very large concentration of the same in the area immediately south of Warwick. That, in turn will produce problems with congestion and transport.
There is no mention of sites which have previously had planning permission but have not been developed. (There are a number in Warwick still not started). Nor is there any mention of the number of empty houses available for sale or for rent. Until all those numbers are included in the figures the true need for "new Build" cannot be fully assessed.
Also, it has been reported that Stratford District Council have approved a "draft" strategy to build a new 4000 home "town" in the Lighthorne area just south of Warwick. If that goes ahead it would also have some effect on the infrastructure requirements, within the Warwick Local Plan; yet no mention is made of that scheme has been taken into account when preparing the Warwick Local Plan.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56323
Derbyniwyd: 19/07/2013
Ymatebydd: Mr Keith Harvey
Dismay and horror at numbers of new houses proposed over the coming years.
To my knowledge this is almost twice the number needed to sustain local requirements, and will fuel the ever accelerating expansion of the County's population.
If you respond to market forces, you will continue to build houses for as long as people wish to buy them. Once housing density reaches point where area is no longer attractive, nobody will want to live here?
Halve the number you propose to allow!
Gwrthwynebu
Revised Development Strategy
ID sylw: 56377
Derbyniwyd: 31/07/2013
Ymatebydd: Conservation Advisory Forum
If more students were to be housed on Warwick and Coventry University sites this would release more houses in Leamington Spa for use by families and would reduce the housing need overall.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56382
Derbyniwyd: 24/08/2013
Ymatebydd: Ray Steele
No hard evidence to support the number of 12,300 houses, invented by WDC. The information used is risky and will not stand up to the test of time. The Council should not have set out to place the great majority in one densely packed area so the new residents would need to commute to their work place. Little unemployment in the District compared with neighbouring Coventry, hence very little new housing is necessary. By adopting a lower figure 5,400 homes there will be no need to allow any of the batch of applications now being processed. Planning for the next 18 years is foolhardy and extremely irresponsible. Plan should only be allowing a phased number of houses each year and catering for the needs of Local People and it is not doing so. WDC should have used a more sensible lower figure to cover for the next 5 years, then proposed to update on a rolling basis without the commitment to provide infrastructure for the higher number they have adopted. Meeting demand from existing housing stock that needs upgrading, together with brownfield sites.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56410
Derbyniwyd: 26/07/2013
Ymatebydd: Christopher Popple
I believe the population of Warwick currently to be about 32,000 but the construction of 12,300 new homes could well increase that population by more than 75% based on a family unit of 2.4. What facts and information exist to show that industry, commerce and services can expand to provide employment for such an increase in population? If the sources of employment do not increase by such a factor then even more pressure will be placed on roads and public transport as these new residents commute over longer distances to and from work. Surely the sensible plan is to proceed far more slowly matching residential construction to employment needs.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56413
Derbyniwyd: 25/07/2013
Ymatebydd: Mr & Mrs Poynter
Nifer y bobl: 2
The project housing need of 12,000 homes is far too high. Less than half that number would meet local needs. It is wrong to forecast as far into the future as 2029, and to allocate greenfield land now. It is akin to having no plan at all, allowing uncontrolled growth, just leaving developers to decide what to build when. There are better alternatives for meeting local needs, especially affordable housing, instead of encouraging in migration and gradually releasing land for development as demand groups. Giving priority to using brownfield sites instead of greenfield sites and co-operating with other local authorities with the planned 1900 houses at Lighthorne Heath and plans for Stratford District building on the opposite side of the M40, junction 15.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56425
Derbyniwyd: 29/07/2013
Ymatebydd: Mr & Mrs P Lightfoot
Nifer y bobl: 2
Objects to the RDS Plan for the following reasons: High projection of number of houses required: The historic town of Warwick cannot sustain population growth projections based on the national criteria and formulae used for towns without protected heritage status which have easily enlarged transport routes; The projected numbers have been demonstrated to be too high at several local consultation meetings and require further substantiation to convince us and the majority of local residents of the need for so many new houses.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56446
Derbyniwyd: 02/08/2013
Ymatebydd: Robert Ashby
Horrified at the quantity of new housing proposed in Warwick district overall when the expected need is much less.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56481
Derbyniwyd: 29/07/2013
Ymatebydd: Centaur Homes
Asiant : Turley Associates
Welcomes that the Council recognise that interim figure of 12,300 houses could and should change as result of more up to date evidence as it emerges.
Council should recognise the important provisions of the Framework, in particular the need to meet the full objectively assessed housing needs, and the need to boost significantly the supply of housing.
Paragraph 4.1.10 of the Plan makes reference to the historical local growth rate (GVA) across the District, and has assumed a reduced growth rate across the District in the emerging Plan period for the purposes of determining a housing need figure. This fails the Framework both in terms of the need to boost significantly the supply of housing, and secondly the need to meet the full objectively assessed housing need.
The Plan period will see sustained, buoyant economic growth where household growth is likely to be higher. The Council are therefore invited to re-assess housing figures, increasing the requirements to reflect the historical local growth; apply the ONS figures with some caution; and recognise the important requirement to meet the full objectively assessed housing need.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56540
Derbyniwyd: 29/07/2013
Ymatebydd: Mrs & Mr Anne & Michael Kirby
Nifer y bobl: 2
Questions the need for 12,000 new homes in the WDC area.
Is account taken in the draft plant of proposed developments of 1,400 new homes south of Leamington?
More use of brownfield sites. Ramsay Rd, a derelict industrial area in Leamington, would be an ideal site for attractive development; bordering on Sydenham estate it would benefit from the existing facilities. It is currently a disgraceful tangle of empty units and overgrown environs.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56544
Derbyniwyd: 29/07/2013
Ymatebydd: Burman Brothers
Asiant : CPBigwood Ltd
Cannot understand the rationale of planning for an "interim level of growth of 12,300 homes between 2011 and 2029" when the Strategic Housing Market Assessment projections showed figures of between 11,300 and 14,300 and the employment-led population and household projections pointed to a need for between 13,300 and 13,800 additional homes in the same Plan period.
It would be more appropriate to plan for a growth of 13,300 dwellings in the Plan period at this stage rather than wait a further Review of the Plan and then find that the requirement is considerably higher and there is a shortage of time before the end of the Plan period.
There is sufficient potential housing land within the District to cater for the growth of 13,300 dwellings and request further consideration be given to adopting this higher figure and incorporating the additional 1,000 dwellings in the strategic releases
Gwrthwynebu
Revised Development Strategy
ID sylw: 56595
Derbyniwyd: 29/07/2013
Ymatebydd: Lenco Investments
Asiant : RPS Planning
Supports the increase in housing from the 10,800 dwellings in the previous version of the plan to this Preferred Options consultation document. However, the evidence illustrates that 12,300 dwellings is still insufficient to meet Warwick's own housing needs, let alone assisting with cross-boundary development requirements.
The extensive evidence gathering and scenario testing by the Council to establish a housing and employment figure has not been used or applied consistently.
The 12,300 figure is not justified on GVA terms, nor is it justified through the economic or demographic evidence available in the Economic or Demographic Forecasting Study.
The 12,300 figure will also not support the 10,200 jobs being planned for in accordance with figure 42 of the Councils forecasting study.
It is expected that the 2013 joint SHMA will provide a greater degree of clarity on the housing need for Warwick (including cross boundary need) but in the absence of this, the figure needs to be reflective of the evidence available.
It is also noted that the Inspector for the [Coventry] Core Strategy has indicated that there is a need for an up to date SHMA in order to have effective and robust cross boundary evidence of cooperation. On this basis the figure should be reflective of the economic potential of the district based upon the influence of the Gateway Development and high levels of GVA than 2.5%.
This should therefore be considerably higher than the 13,900 dwellings (figure 42). The justification for this is:
* The authority is planning to provide some 10,200 additional jobs over the plan period which is even higher than the 9,900 associated with 13,900 dwellings RPS recommends is the minimum to be considered ;
* GVA forecasts are predicated to in the range of 2.9% and not 2.4%;
* GVA from the Gateway Development is expected to push GVA up to at least 3%
* The Gateway site already now has planning consent (subject to S106) and will have an impact on the district's requirements including the provision of some 10,000 new jobs;
* The needs of Coventry have not been considered and will need to be taken into account in addition to Warwick's needs;
*The demographic study has used 2011 census household size figures and forecast them across the whole plan period. This is unlikely to occur and trends akin to the 2008 projections or close to them are accepted by many as likely to occur
The 2012 Strategic Housing Land Availability Assessment (SHLAA) inappropriately excludes that site at Baginton. Therefore, it is evident that a greater number of dwellings than the interim level proposed, can be delivered within the District to contribute towards housing needs.
Warwick District Council should work with Coventry to assist in providing a proportion of Coventry's housing requirement in accordance with NPPF requirements.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56600
Derbyniwyd: 29/07/2013
Ymatebydd: Joanna Illingworth
This section contains a major logical flaw. Paragraph 4.1.6 argues that the District cannot achieve economic growth rates in line with national forecasts without inward migration. The following paragraphs go on to forecast how many dwellings will be required to sustain this level of economic growth. However it is impossible for every planning authority to achieve the level set out in the national forecast. Some areas will be above the average, and an approximately equal number will be below it.
The policies in paragraphs 4.1.6 to 4.1.9 appear to be based on the principle of "beggar my neighbour". Apparently Warwick District Council aims to achieve the national forecasts for economic growth by stripping other areas of their populations of working age.
Warwick District Council should be aiming to achieve for its citizens extra wealth and wellbeing per head of population. Simply importing extra people does necessarily do this and can result in the reverse through pressure that it puts on the environment and infrastructure.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56606
Derbyniwyd: 29/07/2013
Ymatebydd: A C Lloyd
Asiant : Framptons
Section 4.1 of the Revised development Strategy (RDS) correctly confirms the fact that the level of housing growth is an interim figure and that this may alter as a result of the findings of the Joint SHMA and the resulting co-operation between the authorities.
Against this background it is considered that the statement at the end of paragraph 1.3 of the RDS is untenable, which states, "the Council believes that the evidence base which underpins the RDS is robust and the housing growth requirements are unlikely to change substantially as a result of the new assessment".
There is no evidence to indicate that the Council's position as expressed at the end of paragraph 1.3 of the RDS is robust. It should be deleted.
Windfall Allowance
It is considered that the windfall allowance is excessive and unjustified. It seems to ignore the evidence from the SHLAA (which provides for 300 dwellings on small urban sites) and assumes an unrealistically high level of windfall sites for the plan period. The Council's evidence is based on a subjective manipulation of past trends rather than any considered examination of the evidence that may exist in terms of the potential capacity of the urban areas to accommodate such a high level of windfall moving forward. Accordingly, in the absence of a clear and robust evidence base from the Council the proposed windfall allowance is rejected.
Further consultation
It is apparent that the publication of the joint SHMA in early 2014 will be an important factor in determining the final format of the Local Plan. As such, it is submitted that the Council should consider a further round of consultation on the output of the SHMA prior to going forward to publish a Submission Draft Plan.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56638
Derbyniwyd: 29/07/2013
Ymatebydd: Whitnash Town Council
The level of housebuilding proposed may exceed the actual population growth and demand within the District. The projected housing need of more than 12,000 new homes is too high. Not convinced with the methodology that has been used to predict the level of growth needed for the area. Also forecasting so far ahead cannot possibly give accurate numbers.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56646
Derbyniwyd: 29/07/2013
Ymatebydd: A C Lloyd Homes Ltd and Northern Trust
Asiant : Framptons
Section 4.1 of the Revised development Strategy (RDS) correctly confirms the fact that the level of housing growth is an interim figure and that this may alter as a result of the findings of the Joint SHMA and the resulting co-operation between the authorities.
Against this background it is considered that the statement at the end of paragraph 1.3 of the RDS is untenable, which states, "the Council believes that the evidence base which underpins the RDS is robust and the housing growth requirements are unlikely to change substantially as a result of the new assessment".
There is no evidence to indicate that the Council's position as expressed at the end of paragraph 1.3 of the RDS is robust. It should be deleted.
Windfall Allowance
It is considered that the windfall allowance is excessive and unjustified. It seems to ignore the evidence from the SHLAA (which provides for 300 dwellings on small urban sites) and assumes an unrealistically high level of windfall sites for the plan period. The Council's evidence is based on a subjective manipulation of past trends rather than any considered examination of the evidence that may exist in terms of the potential capacity of the urban areas to accommodate such a high level of windfall moving forward. Accordingly, in the absence of a clear and robust evidence base from the Council the proposed windfall allowance is rejected.
Further consultation
It is apparent that the publication of the joint SHMA in early 2014 will be an important factor in determining the final format of the Local Plan. As such, it is submitted that the Council should consider a further round of consultation on the output of the SHMA prior to going forward to publish a Submission Draft Plan.