BASE HEADER
RDS2: The housing requirement of 12,300 homes will be met from the following categories of sites
Gwrthwynebu
Revised Development Strategy
ID sylw: 52492
Derbyniwyd: 22/06/2013
Ymatebydd: Rod Bond
Student housing continues to be an issue within the area, with a lot of houses occupied by students, if more purpose built accommodation, like the new development (Station House) opposite Leamington Train Station was created then houses currently occupied by students could either be made available to rent or buy on the open market.
Figures should be collated to show the number of houses currently occupied by students in the area to see if changing these use of these properties and building additional purpose build student accommodation will help.
In addition how many properties are currently empty in the area. Although I doubt this number is significant, it would help in understanding if this could also assist in achieving the housing requirement
Gwrthwynebu
Revised Development Strategy
ID sylw: 52681
Derbyniwyd: 27/06/2013
Ymatebydd: Mr Mark Green
Objects to any proposals to meet changes to the housing requirements as a result of joint SHMA within the green belt north of Leamington.
Cefnogi
Revised Development Strategy
ID sylw: 53358
Derbyniwyd: 22/07/2013
Ymatebydd: Mr Simon Lieberman
A sensible mix of what is required.
Gwrthwynebu
Revised Development Strategy
ID sylw: 53412
Derbyniwyd: 24/07/2013
Ymatebydd: Mr Richard Emmett
The District Council's proposal for 12,300 new homes by 2029 exceeds the local need which is for about 6,000 new houses. I belive that concentrating 4,500 of these homes on land south of Warwick would create a huge new built-up area. This would result in a rapid growth in population that would put unsustainable pressure on the road infrastructure, hospital and school services, local water supplies and drainage. It would also increase traffic congestion and pollution. Siting these houses on existing agricultural land would leave brownfield industrial sites in the area underexploited.
Cefnogi
Revised Development Strategy
ID sylw: 53441
Derbyniwyd: 24/07/2013
Ymatebydd: Sport England
Sport England can not and will not support the release of any land for housing which is currently used or was formally used for sport unless the land in question is shown to be surplus for sport through a robust assessment. Sport England is aware that WDC is producing a Playing Pitch Strategy, but until it is adopted Sport England would expect any planning application to show through a robust assessment, that the sports land/facilities are no longer required.
Gwrthwynebu
Revised Development Strategy
ID sylw: 53556
Derbyniwyd: 28/07/2013
Ymatebydd: Mrs Jean Drew
As I believe the number of homes required is only around 5,000-6,000 there is no need for any further allocation of development.
Gwrthwynebu
Revised Development Strategy
ID sylw: 53602
Derbyniwyd: 26/07/2013
Ymatebydd: Mr John Lock
The increase in housing estimates from 10,800 to 12,300 is without foundation, being still subject to review against adjoining authorities (e.g. Coventry and Stratford) and being based on challengeable methods. Indeed an alternative authoritative report by Bishop's Tachbrook Parish Council suggests a likely requirement of 5,400 homes, less than half the WDC estimate. Even this number will add over 10,000 people and some 15,000 vehicles to the area, resulting in additional traffic congestion and air pollution, both already at unacceptable levels.
Local MP Chris White has written to Cllr. Doody on 24 June 2013 expressing concerns about the housing estimate and urging WDC to "respect the views of local residents".
Gwrthwynebu
Revised Development Strategy
ID sylw: 53621
Derbyniwyd: 26/07/2013
Ymatebydd: Mrs Kay Lock
The increase in housing estimates from 10,800 to 12,300 is without foundation, being still subject to review against adjoining authorities (e.g. Coventry and Stratford) and being based on challengeable methods. Indeed an alternative authoritative report by Bishop's Tachbrook Parish Council suggests a likely requirement of 5,400 homes, less than half the WDC estimate. Even this number will add over 10,000 people and some 15,000 vehicles to the area, resulting in additional traffic congestion and air pollution, both already at unacceptable levels.
Local MP Chris White has written to Cllr. Doody on 24 June 2013 expressing concerns about the housing estimate and urging WDC to "respect the views of local residents".
Gwrthwynebu
Revised Development Strategy
ID sylw: 53714
Derbyniwyd: 27/07/2013
Ymatebydd: Mrs Margaret Ellis
I object to the plan on the grounds that I do not accept the need for
12,000 new house in the District. The infrastructure is not capable of
support such a development even if you tweak the roads there will still be
traffic chaos.
The will be a huge impact on pollution, schools and the hospital.
Good agricultural land will destroyed while smaller brownfield sites are
vacant.
This plan has been put together to suit developers not the needs of the
local population.
Gwrthwynebu
Revised Development Strategy
ID sylw: 53761
Derbyniwyd: 28/07/2013
Ymatebydd: Emma Thompson
Windfall Sites: Concern about the estimate number of windfall sites and the lack of clarity at this stage as to where these would be - they would have significant impact on village sites in addition to the numbers already proposed for these locations
Gwrthwynebu
Revised Development Strategy
ID sylw: 53862
Derbyniwyd: 28/07/2013
Ymatebydd: Mrs Jacqueline Crampton
The existing identification of 6,000 homes is sufficient for natural growth and can be accommodated without the need for massive infrastructural changes. An additional 6,600 homes are simply unnecessary. Any growth should be incremental to existing settlements and distributed evenly.
Gwrthwynebu
Revised Development Strategy
ID sylw: 53867
Derbyniwyd: 28/07/2013
Ymatebydd: Mrs Helen Clark
An estimate of 2,800 windfall sites has been made, but there is no clarity on either their location or their nature other than I understand that WDC has stated that the rural figure is 504. The possible implications for a village, such as Lapworth, are not clear and are of concern.
Gwrthwynebu
Revised Development Strategy
ID sylw: 53940
Derbyniwyd: 28/07/2013
Ymatebydd: Miss Amanda FAWCETT
You are seeking to allocate far too many homes within this plan - with no assurance that they are or will be needed. You should reconsider other lower suggestions and increase numbers later only if further need is identified.
Cefnogi
Revised Development Strategy
ID sylw: 54323
Derbyniwyd: 29/07/2013
Ymatebydd: Midland Red (South) Ltd. dba Stagecoach Midlands
Stagecoach Midlands has no comment to make.
Gwrthwynebu
Revised Development Strategy
ID sylw: 54494
Derbyniwyd: 29/07/2013
Ymatebydd: Mr John Watkins
The whole of this strategy is based on a false set of figures which do not reflect the population growth of the resident population. This will give rise to the possibility of a judicial review on the grounds that the figures have been incorrectly prepared and, if that was a deliberate act by councillors, could lead to either a surcharge on the councillors or proceedings for misrepresenting the statistics in a manner causing damage to the local environment and ignoring the wishes of the electorate expressed in the previous consulation..
Gwrthwynebu
Revised Development Strategy
ID sylw: 54555
Derbyniwyd: 29/07/2013
Ymatebydd: Mr Edward Walpole-Brown
Asiant : Brown and Co
The table is premature as work is still continuing on the Strategic Housing Market Assessment which covers not only Warwick District Council, but other neighbouring authorities. Also, the growth should be greater as is evidenced by recent reports/studies. The figures should be in line with at least the ONS 2008 Household Projections. The tables at RDS2 and RDS4 are, therefore, inappropriate and premature.
In addition:
1-Aware of the fact that recent decisions have meant that some of the major sites proposed are not deliverable.
2-HS2 has not been taken into consideration adequately.
3-The number of houses in the Primary and Secondary Service Villages should be increased with less reliance on the Strategic Urban Extensions. These sites produce more desirable locations for housing and will help support sustainable growth and support existing and new community facilities. This is in keeping with other Plan policies, particularly the strategy as defined in 3.3 on page 7 of the RDS.
Cefnogi
Revised Development Strategy
ID sylw: 55195
Derbyniwyd: 29/07/2013
Ymatebydd: Coventry City Council
Please note that this letter has not yet been formally endorsed by Members, we will confirm for you in due course as this happens.
Welcomes the recognition that the interim housing target is subject to change as a result of the joint SHMA and Duty to Cooperate. Wonder whether the windfall sites allowance is optimistic, given the 'policy on' trend, but anticipate this issue being resolved following the joint SHMA. Do not anticipate any significant direct impact on the infrastructure of Coventry to result from any of your proposed site allocations. May wish to consider the relationship between the committed employment schemes of Friargate in Coventry City Centre, Warwickshire Gateway, and the proposed office allocation at Thickthorn, Kenilworth.
Gwrthwynebu
Revised Development Strategy
ID sylw: 55336
Derbyniwyd: 28/07/2013
Ymatebydd: Graham Parker
The process for assessing the housing target is deeply flawed and that the housing target set by the draft Strategy in para 4.1.10 and RDS2 will therefore be inadequate and will lead to the Plan being found unsound.
1-despite best practice and government advice, the SHMA only covers a part of the identified Strategic Housing Management Area (see paragraph 10.6 of the SHMA). Thus it does not assess the "full, objectively assessed needs for market and affordable housing in the housing market area" as required by paragraph 47 of the NPPF and ignores the duty to cooperate imposed on this Local Plan by Section 110 of the Localism Act 2011.
2- the Strategy is based on out of date household and population projections. The reference to the 2011 ONS Projections in paragraph 4.1.5 is cursory and the implications of these projections clearly have not been absorbed into the strategy.
3- housing needs are based on much more than simple household projections, as is set out in the SHMA itself.
4-the SHMA itself makes massive assumptions about in-commuting, which have significant implications both for Warwick and for nearby authorities. These assumptions are unsupported by evidence.
5-the absence of a 5 year supply of deliverable housing land would not, in itself, render the plan 'unsound' the Inspector will clearly have in mind that it is sensible to ensure that the plan begins on a firm footing, which this Strategy does not.
In addition to underestimating the district's overall housing needs throughout the plan period, no account has been taken of the undersupply from the previous period . Thus:
* Even with the lower WMRSP2 requirement of 550 dpa, given the shortfall from the previous period and the fact that Warwick is certainly a 20% buffer authority, the requirement in the first 5 years is likely to be some 900 dpa.
* If one takes the Strategy's interim assumption of 680 dpa for the whole plan period,
the requirement in the first 5 years is likely to be in the order of 1100 dpa, and this is
still without using a proper analysis of need, or an up to date assessment.
* As it stands, the Strategy is clearly incapable of providing sufficient deliverable sites in the first five years of the plan period.
Until all of these matters are demonstrated, the Strategy is unsound in all four of the
required ways set out in the NPPF:
* It is not based on objectively-assessed development requirements, including unmet
requirements from either neighbouring authorities or shortfalls of delivery in recent
years. It is not, therefore 'positively prepared'.
* It has not been demonstrated to be the most appropriate strategy, when considered
against the reasonable alternatives, based on proportionate evidence. It is not,
therefore, 'justified'.
* It is not demonstrated to be deliverable and is not based on effective joint working on
cross-boundary strategic priorities. It is not, therefore,. 'effective'.
* It does not enable the delivery of sustainable development in accordance with the
policies in the Framework - in this case, specifically, sustainable development and
Green Belt policies. It is not, therefore, consistent with national policy
Objects to the level of housing (12,300) said to be required in the plan period which is likely to be a severe underestimate and, if pursued, the plan would be materially unsound.
Also objects to the lack of suitable, sustainable and deliverable land proposed to meet even this severely under-estimated need, meaning that there is in fact no plan to meet their need, making the plan further materially unsound.
Notes that the local planning authority itself only refers to this as an 'Interim' conclusion and that it will be revised following a re-evaluation of the housing requirements taking into account the latest ONS projections and the S110 duty to co-operate.
Questions why:
* The Council did not heed the warnings given at the earlier Preferred Option stage (specifically about the faults in the SHMA, and the duty to co-operate) rather than waiting for the Coventry Inspector's instruction.
* The RDS has been published in its current form rather than waiting amendments to the housing requirement.
Gwrthwynebu
Revised Development Strategy
ID sylw: 55415
Derbyniwyd: 29/07/2013
Ymatebydd: Lone Star Land LLP
Asiant : Alliance Environment & Planning Ltd
Housing Supply:
At present Warwick District Council is unable to demonstrate a 5 year housing land supply which is acknowledged at para 5.1.32 of the consultation document and confirmed in the Council's most recent Annual Monitoring Report (2012) as being 2.6 years. This is contrary to NPPF (para 47) in respect to 5 year supply of deliverable sites and an additional buffer of 5% or 20% where there is a persistent record of under delivery of houses.
No reference has been made by the Council in the RDS as to whether they consider themselves to be a 5% or 20% authority in order to be compliant with Framework para 47.
Furthermore, in the absence of a demonstrable 5 year land supply, the Council will be required to identify and release more land for housing development beyond those locations set out in RDS5.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56386
Derbyniwyd: 24/07/2013
Ymatebydd: Mr Iqubal Pannu
Have empty homes and brownfield sites been considered as a more sustainable option? Can existing business/office buildings be converted into residential properties? Why are additional offices being suggested if the existing office space is empty?
Gwrthwynebu
Revised Development Strategy
ID sylw: 56392
Derbyniwyd: 23/07/2013
Ymatebydd: Mr Paul Karnik
Plans are ill thought out, incompetent and not in the interests of anyone other than developers. In the last 5 years a total of 251 homes have been taken back into supply but 6305 homes in the district lie empty. The Council should focus more effort into utilising what is already available rather than build more than is necessary. New developments at Warwick Gates and Chase Meadow have proved unsustainable. Recent survey has posted that 76% of traffic passing through Warwick is transient and Warwick is a Conservation Area. How will this plan affect the conservation area? The answer is no one knows as this plan does not cover this point.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56440
Derbyniwyd: 29/08/2013
Ymatebydd: Bloor Homes
Asiant : Marrons Planning
These submissions relate to the proposals for meeting the housing requirement referred to in Policy RDS1. This proposal will need to be reviewed by the Council following the proper assessment of the housing requirement for the District. However, the following comments are made on the basis of the proposal at this stage. The proposal contains a heavy reliance (23%) on sites not identified or to be allocated within the final plan (i.e. windfalls), and it is questioned whether such an approach is consistent with the Framework in requiring the Council to demonstrate it is planning positively to meet the development requirements of the area.
Moreover, the evidence base to support the assumptions about windfall rates does not justify the level of growth indicated as it is primarily informed by past trends in a stronger economic climate and a far more relaxed planning policy context towards windfalls.
By way of example, on the basis of the evidence put forward in the GL Hearn Employment Land Review Update 2013, the vast majority of employment sites will be protected by the Council for such uses in the future and therefore rates of redevelopment of large sites for residential development are not likely to return to previous levels seen prior to 2007 and the adoption of the current Local Plan Policy SC2. If the Council are to rely on such levels of windfalls delivering the housing growth it requires to meet its needs in its draft Plan, it will need to demonstrate that the other policies of its Plan are framed in such a way as to enable such proposals to come forward.
Cefnogi
Revised Development Strategy
ID sylw: 56479
Derbyniwyd: 29/07/2013
Ymatebydd: Bloor Homes
Asiant : Pegasus Group
Alternative site at Common lane, Kenilworth is consistent with RDS2 in that it will contribute to windfall target of 2800.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56545
Derbyniwyd: 29/07/2013
Ymatebydd: Burman Brothers
Asiant : CPBigwood Ltd
Table 1 should be amended indicating a total of 13,300 and the table should reflect the need to provide sites to accommodate these extra 1,000 dwellings
Similarly, table 2 needs to be amended to take account of proposals for three parcels of land submitted for housing development at Hatton Park.
Gwrthwynebu
Revised Development Strategy
ID sylw: 56817
Derbyniwyd: 29/07/2013
Ymatebydd: Taylor Wimpey UK Ltd
Asiant : Barton Willmore
Housing supply: Warwick DC cannot demonstrate a five-year supply of deliverable housing. If the CS is not to be out of date on adoption it is important that the land supply requirement is achieved. If there were not reasonable certainty that this would be the case then the plan would not be sound as it would be neither effective nor consistent with national policy. Without a five year housing land supply, the Council should aim to identify and release more development land in a range of locations or formulate a deliverable strategy that will provide for housing needs across the Plan period. The local plan needs to demonstrate maximum flexibility to ensure delivery of an objectively assessed housing need in accordance with NPPF. As part of this the Council the provision of 5% or 20% buffer in its land supply must be addressed to be compliant with Paragraph 47 of the NPPF.
Cefnogi
Revised Development Strategy
ID sylw: 57673
Derbyniwyd: 29/07/2013
Ymatebydd: John Bausor
Asiant : Keyhaven Consulting Limited
The development of the Thickthorn area as intended in the RDS is supported, however this may put an over reliance on this site to produce the majority of Kenilworths needs and restrict the choice of housing available for those wishing to live in Kenilworth. As a consequence this submission promotes a further adjustment to the Green Belt boundary in the area north of Crew Lane and east of Glasshouse lane to bring two smaller parcels of land into the equation. It is considered that these are well related to the schools and Leyes Lane shops (Local centre) and should be brought into consideration as they can be delivered relatively quickly/ easily.
Gwrthwynebu
Revised Development Strategy
ID sylw: 57793
Derbyniwyd: 23/07/2013
Ymatebydd: Mr and Mrs Roy & Maria Hirons
Object to the 12300 homes required in the RDS. The objectors have seen a 'report' stating that 4405 is a more accurate reflection of need. 12300 homes will spoil the countryside and lead to even more traffic congestion, as there is already a need to queue to get into Warwick and Leamington.
Gwrthwynebu
Revised Development Strategy
ID sylw: 59224
Derbyniwyd: 29/07/2013
Ymatebydd: Mr Terence Stanford
Understand that only 6000 new homes needed so why is council looking for 12000?
Gwrthwynebu
Revised Development Strategy
ID sylw: 59319
Derbyniwyd: 24/07/2013
Ymatebydd: Colin Quinney
Windfalls: There is a large increase between the original and the revised Plans in the number of units being added through windfalls within existing planning boundaries, reducing the units required on new land by 1,500 or almost 20% (the change was very clear in the public presentation). This huge revision suggests that the assumptions made for windfall or infill developments coming forward during the Plan period of slightly under 200 units per year (page 13 table 2) - there were 600 in the last year alone - may be significantly understated. 50 additional units a year would remove a further 750 from the newbuild total, roughly equivalent to the proposed greenbelt expansion. The assumption should be carefully reviewed.
Gwrthwynebu
Revised Development Strategy
ID sylw: 59666
Derbyniwyd: 29/07/2013
Ymatebydd: Hallam Land Management and William Davis
Asiant : Marrons
Supports southern expansion of Warwick, Leamington and Whitnash however the scale of development to be accomodated across the district may need to be adjusted. The assumed level of windfall is too high and should not constitute any more than 10% of the outstanding level of housing provision, the plan is therefore 2,523 dwellings short of meeting the requirement.