Based on the amount of housing that ONS statistics from the last 10 years indicate, we will only need 5,400 new houses. We have a 5 year housing land supply and in addition it can be achieved in the time scale with the minimum infrastructure cost for the local authority.

The proposed level of growth has never been convincing and is almost universally rejected by the public. The mid-2012 ONS projections confirm this view.

Instead of 21,474 more people moving to the areas of Warwick, Leamington and Kenilworth over the next 18 years, the new ONS calculation predicts a population growth of 15,313 which is 29% less.
y 
my reckoning this means the number of new homes that 
are required to be built between 2011 and 2029 is not the 12,860 of the district plan but 9,217.

According to a report in the Leamington Courier on 6th June the latest Office of National Statistics forecast figures for project population growth show that the figures used in this plan are overestimated and should be revised down from 21,474 to 15,313 for the plan period. Consequently the required level of housing supply should be revised downwards.

The evidence in the Coventry and Warwickshire SHMA suggests that Warwick District has close links with the Coventry housing market area, but that there are modest migration flows only from Birmingham and Solihull. The housing target in the Publication Draft is within 100 dwellings of the appropriate level of provision identified in the Coventry and Warwickshire SHMA.

The level of housing growth set out in Policy DS6 is 12,860 dwellings over the period 2011-2029, or 714 dwellings per annum. This purports to be based on the objectively assessed need identified in the Coventry & Warwickshire Joint Strategic Housing Market Assessment (SHMA) 2013. However the objectively assessed need set out in Table 97 of the SHMA was in fact a slightly higher figure of 720 dwellings per annum - an additional 108 dwellings over the plan period. This is a small difference but it should be provided for in order for the plan to be robust.

Of greater concern is the fact that the plan does not provide for any of the housing need that is very likely to arise from neighbouring districts that cannot meet their own need. The report to Council on 23rd April 2014 included Appendix 5 concerning the Coventry and Warwickshire Duty to Cooperate. This report stated that a 'significant risk' to the delivery of the Housing Market Area's (HMA) Objectively Assessed Need (OAN) is whether each of the Councils within the HMA have sufficient site capacity within the boundaries to deliver their identified OAN. In particular there is a significant risk that Coventry City Council will not be able accommodate 23,600 dwellings (1,180 dwellings per annum) within the City boundary. In addition, there is a risk that authorities within the Coventry and Warwickshire HMA will be asked to accommodate a growth resulting from a shortfall of housing capacity in Birmingham.

Birmingham City Council's Proposed Submission Draft of its Local Development Plan identifies an initial shortfall in meeting its OAN by around 29,000 dwellings. Coventry City Council's Strategic Housing Land Availability Assessment 2012 set out a capacity of 14,667 dwellings between 2011-2028, whereas the OAN for Coventry between 2011-2031 is 23,600. It therefore seems very clear at this stage that a large amount of housing provision will need to be allocated to neighbouring districts to Coventry and Birmingham under the Duty to Cooperate. The Publication Local Plan makes very little provision for accommodating housing requirements from neighbouring districts under the Duty to Cooperate - this will be discussed further in representations under Policy DS20.

The Publication Plan does not provide for an adequate time horizon. Paragraph 157 of the National Planning Policy Framework says that local plans should be "drawn up over an appropriate time scale, preferably a 15-year time horizon, take account of longer term requirements, and be kept up to date". The plan period is to end in 2029, which at this point provides a time horizon of just under 15 years. However at the likely point of adoption of the Local Plan - April 2015 - it will only have a time horizon of 14 years. The SHMA set out the assessment of OAN to 2031. In order for the Local Plan to provide for the OAN the plan period should be consistent with that used in the SHMA. Rugby Borough Council is currently consulting on a Local Plan Development Strategy which would extend their plan period to 2031, consistent with the SHMA assessment period. It is considered that Warwick District Council should also take the opportunity now to ensure that their plan has a sound time horizon, consistent with guidance in the NPPF.

The level of housing set out, of which a large percentage will be south of Warwick, is excessive and not justified by the local need - re para 1.42. It is built on a possible overspill need of Coventry and Birmingham. This fails the sustainabilty test as there is little provion for employement in the plan in the area where development is focussed.

In principal Sport England supports this, however any allocation should not result in the loss of any sports facilities/playing fields, unless they are either replaced or shown through the emerging playing pitch strategy and sports strategy that they are surplus to requirements.

The numbers of homes does not reflect projected needs under the latest National Statistics-WC should use the most current data which indicates lower numbers. The argument that Warwickshire should absorb housing from Coventry and Birmingham is unfair bearing in mind that some green belt in these araes is much lower quality than geeen fields south of Warwick. The greenbelt should be revised.

We note that the Council will provide for 12,860 new homes between 2011 and 2029. Paragraph 2.20 of the draft Plan makes reference to the CWSHMA and that Warwick District aims to meet its objectively assessed need. Whilst we would support the Council in seeking to meet its objectively assessed need for new market and affordable housing, the CWSHMA indicates that the overall assessed need for Warwick District amounts to 720 dwellings per annum over the period 2011 - 2031, equivalent to 12,960 for the period 2011 - 2029. In light of this, we would query why the draft Plan proposes a lower requirement (albeit that the difference is minor).

In addition, and conscious that the Plan is unlikely to progress to adoption until mid-2015, at best, we would suggest that the Council extends the Plan period to 2031 so that it aligns with the CWSHMA, as the relevant evidence base, and more importantly, ensures that the Plan will have a 15-year life span in accordance with paragraph 157 of the NPPF.

I believe that the figures for housing growth are incorrect. The Office of National Statistics has since done a recalculation of the housing needs and they have reduced the quantity. Warwick District Council have ignored these new figures. In addition there are already planning approved housing for around 6000 homes that have not been included in WDC figures

Deeley Group object to the proposed level of housing growth of 12,860 new homes between 2011 and 2029. As stated in our objection to Paragraph 1.29, it is considered that the plan period used should be 2011 to 2031. The current approach is considered 'unsound' as it does not conform with the provisions of NPPF which requires Plans to cover an appropriate time period, preferably a 15 year time horizon, but which takes account of longer term requirements. Since the plan is unlikely to be adopted before 2015 this period appears too short. This would bring it into line with the evidence base in the Coventry and Warwickshire Joint SHMA. Accordingly, it is considered that the appropriate level of housing should be increased by at least of 1,428 dwellings to provide for the additional 2 years and the plan period should extend to 2031.

A further concern is that the current approach to meeting the housing requirement for the District does not take into consideration any shortfall of housing within the sub-regional housing market area (in particular on Coventry) or within adjoining housing market areas (in particular Birmingham).

It is acknowledged that this issue is already recognised at paragraph 1.24 of the Plan albeit it states that Warwick is unlikely to have to directly accommodate any shortfall from Birmingham. Objection is raised to this statement on the basis it is premature and considered unlikely given the scale of the anticipated shortfall in Birmingham and the good transport links between the two areas. Furthermore, since the interim findings of the Greater Birmingham and Solihull LEP (GBSLEP) Strategic Housing Needs Study is due for publication in July 2014, it is clear that the implications from that Plan may well start to become apparent within a sufficiently near timescale as to be considered as part of the evidence base against which to establish the overall objectively assessed need for Warwick District.

A C Lloyd Homes object to the proposed level of housing growth of 12,860 new homes between 2011 and 2029. As stated in our objection to Paragraph 1.29, it is considered that the plan period used should be 2011 to 2031. The current approach is considered 'unsound' as it does not conform with the provisions of NPPF which requires Plans to cover an appropriate time period, preferably a 15 year time horizon, but which takes account of longer term requirements. Since the plan is unlikely to be adopted before 2015 this period appears too short. This would bring it into line with the evidence base in the Coventry and Warwickshire Joint SHMA. Accordingly, it is considered that the appropriate level of housing should be increased by at least 1,428 dwellings to provide for the additional 2 years and the plan period should extend to 2031.

A further concern is that the current approach to meeting the housing requirement for the District does not take into consideration any shortfall of housing within the sub-regional housing market area (in particular in Coventry) or within adjoining housing market areas (in particular Birmingham).

It is acknowledged that this issue is already recognised at paragraph 1.24 of the Plan albeit it states that Warwick is unlikely to have to directly accommodate any shortfall from Birmingham. Objection is raised to this statement on the basis it is premature and considered unlikely given the scale of the anticipated shortfall in Birmingham and the good transport links between the two areas. Furthermore since the interim findings of the Greater Birmingham and Solihull LEP (GBSLEP) Strategic Housing Needs Study is due for publication in July 2014, it is clear that the implications from that Plan may well start to become apparent within a sufficiently near timescale as to be considered as part of the evidence base against which to establish the overall objectively assessed need for Warwick District.

Warwick District Council Local Plan 2014 Publication Draft DS 6 and DS 7. Paragraph Numbers 2.20 to 2.30.

The Council's provision of 12,860 new homes between 2011 and 2029 (para 2.20) is based on economic projections for the area including projections of POPULATION numbers through 2029 (from the SHMA of 2013). However,
(1) The Plan projections use the old out-of-date data on population from the ONS which only covers the period until the year 2021. The revised ONS data (May 2014) that cover the full period to 2029 and also show much slower growth are ignored.
(2) The Plan projections are questionable because in translating population numbers into the number of dwellings required, the consultants have assumed a significant decline in the size of the average Warwick household: to a figure eventually reaching 2.181 persons per households by 2029 - lower than the average figure of 2.294 from the 2011 Census.

Warwick District Council Local Plan 2014 Publication Draft DS 6 and DS 7. Paragraph Numbers 2.20 to 2.30.

The Council's provision of 12,860 new homes between 2011 and 2029 (para 2.20) is based on economic projections for the area including projections of POPULATION numbers through 2029 (from the SHMA of 2013). However,
(1) The Plan projections use the old out-of-date data on population from the ONS which only covers the period until the year 2021. The revised ONS data (May 2014) that cover the full period to 2029 and also show much slower growth are ignored.
(2) The Plan projections are questionable because in translating population numbers into the number of dwellings required, the consultants have assumed a significant decline in the size of the average Warwick household: to a figure eventually reaching 2.181 persons per households by 2029 - lower than the average figure of 2.294 from the 2011 Census.

These housing numbers are completely ridiculous - at odds with other professional opinion and assessed over too long a time frame with no "breaks" for reassessment

Despite WDC's use of the 'Objectively Assessed' buzzword, the proposed growth of 12,860 homes is based on highly subjective analysis. Equally competent studies show a need of 5,500 homes, which is in line with public opinion. Why are site allocations being made on the 'highest-case' basis?

WDC's work to co-operate with neighbouring local authorities is surely not
complete. Why therefore again are site allocations being made based on
the maximum 12,860? For example Coventry and Nuneaton are rumoured to be encouraging more growth and WDC admits that the status of neighbouring councils' housing plans are not established.

Although the Plan has been presented to the public at the various stages of its evolution, there has been little change as a result of the response from the public opposing the overall scale of development, urbanisation of the South of the District, and encroachment on the Green Belt.

Housing numbers: This calculation is highly speculative and inevitably based on poor quality evidence and data. The LPA calculate a need for approximately 12,900 dwellings, while another equally competent assessment reached a figure of 5,500.

As the plan is subject to review during its 15 year life it would be safer to plan for the lower figure. It could be revised upwards if need were demonstrated.

The recently published ONS population projection shows a 29% reduction on its previous estimate. This illustrates the difficulty of making such predictions, and thus the need for caution in using this data in consequent planning decisions. The process of 'development' is not reversible.

The level of housing growth set out in Policy DS6 is 12,860 dwellings over the period 2011-2029, or 714 dwellings per annum. This purports to be based on the objectively assessed need identified in the Coventry & Warwickshire Joint Strategic Housing Market Assessment (SHMA) 2013. However the objectively assessed need set out in Table 97 of the SHMA was in fact a slightly higher figure of 720 dwellings per annum - an additional 108 dwellings over the plan period. This is a small difference but it should be provided for in order for the plan to be robust.

Of greater concern is the fact that the plan does not provide for any of the housing need that is very likely to arise from neighbouring districts that cannot meet their own need. The report to Council on 23rd April 2014 included Appendix 5 concerning the Coventry and Warwickshire Duty to Cooperate. This report stated that a 'significant risk' to the delivery of the Housing Market Area's (HMA) Objectively Assessed Need (OAN) is whether each of the Councils within the HMA have sufficient site capacity within the boundaries to deliver their identified OAN. In particular there is a significant risk that Coventry City Council will not be able accommodate 23,600 dwellings (1,180 dwellings per annum) within the City boundary. In addition, there is a risk that authorities within the Coventry and Warwickshire HMA will be asked to accommodate a growth resulting from a shortfall of housing capacity in Birmingham.

Birmingham City Council's Proposed Submission Draft of its Local Development Plan identifies an initial shortfall in meeting its OAN by around 29,000 dwellings. Coventry City Council's Strategic Housing Land Availability Assessment 2012 set out a capacity of 14,667 dwellings between 2011-2028, whereas the OAN for Coventry between 2011-2031 is 23,600. It therefore seems very clear at this stage that a large amount of housing provision will need to be allocated to neighbouring districts to Coventry and Birmingham under the Duty to Cooperate. The Publication Local Plan makes very little provision for accommodating housing requirements from neighbouring districts under the Duty to Cooperate - this will be discussed further in representations under Policy DS20.

The Publication Plan does not provide for an adequate time horizon. Paragraph 157 of the National Planning Policy Framework says that local plans should be "drawn up over an appropriate time scale, preferably a 15-year time horizon, take account of longer term requirements, and be kept up to date". The plan period is to end in 2029, which at this point provides a time horizon of just under 15 years. However at the likely point of adoption of the Local Plan - April 2015 - it will only have a time horizon of 14 years. The SHMA set out the assessment of OAN to 2031. In order for the Local Plan to provide for the OAN the plan period should be consistent with that used in the SHMA. Rugby Borough Council is currently consulting on a Local Plan Development Strategy which would extend their plan period to 2031, consistent with the SHMA assessment period. It is considered that Warwick District Council should also take the opportunity now to ensure that their plan has a sound time horizon, consistent with guidance in the NPPF.

We support the Council's intention to plan for the full Objectively Assessed Housing Need in the District, as set out in Policy DS2. However, we believe that there is an error in the number reported.

The supporting text refers to the Joint Coventry and Warwickshire Strategic Housing Market Assessment 2013 (SHMA) which objectively assessed the future housing needs of the Housing Market Area and the six local authority areas within it. The supporting text states that the Objectively Assessed Need in Warwick District is 12,860 new homes between 2011 and 2029.

The SHMA recommends at Table 97: Overall Assessed Need for Housing (per annum 2011-2031) that the Objectively Assessed Need for Warwick District is 720 per annum, which over the 18 years of the plan equates to a total of 12,960 dwellings. It is not clear why Warwick are planning to under-provide by 100 dwellings with no justification presented, particularly as policy DS7 Meeting the Housing Requirement, allocates sites for 12,964 new homes over the plan period.

It has widely been reported that the sub-national population projections (SNPP) published in May 2014 suggest a lower level of growth than that contained in the consultation document.

However, the figures contained in the Joint Coventry and Warwickshire Strategic Housing Market Assessment (2013) still represent the most up-to-date evidence of the district's objectively assessed housing need. The SNPP numbers represent the starting point for assessing housing need, but the SHMA represents the most up-to-date assessment of objectively assessed need.
The NPPF requires local planning authorities to "boost significantly the supply of housing" and "use their evidence base to ensure that their Local Plan meets the full objectively assessed needs for market and affordable housing" (paragraph 47). It also requires local planning authorities to prepare a SHMA to assess their full housing needs which meets household and population projections (paragraph 159).
The NPPG is clear (Paragraph: 015 Reference ID: 2a-015-20140306) that "Household projections published by the Department for Communities and Local Government should provide the starting point estimate of overall housing need." (my emphasis)

It goes on to explain further:
"The household projections are trend based, ie they provide the household levels and structures that would result if the assumptions based on previous demographic trends in the population and rates of household formation were to be realised in practice. They do not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour.
The household projection-based estimate of housing need may require adjustment to reflect factors affecting local demography and household formation rates which are not captured in past trends. For example, formation rates may have been suppressed historically by under-supply and worsening affordability of housing. The assessment will therefore need to reflect the consequences of past under delivery of housing. As household projections do not reflect unmet housing need, local planning authorities should take a view based on available evidence of the extent to which household formation rates are or have been constrained by supply."

Therefore, it is clear that the newly published SNPP numbers are the raw data, and the starting point for assessing the objectively assessed need whereas the Joint SHMA makes adjustments to take account of factors affecting local demography or household formation rates, including supply constraints.

To reduce the housing requirement below the level demonstrated by the evidence base on the basis of the new SNPP figures would render the Plan unsound as it would not comply with paragraph 47 of the NPPF.

See attachment

The Office of National Statistics figures project a significantly reduced population growth rate up to 2029 than the figures you use meaning the growth plans are uncalled for. They also vastly outnumber the numbers requested during public consultation

Response of Kenilworth Town Council to the Warwick District Local Plan Consultation
June 2014
General
As the District Council will be aware, the Town Council has drafted and continues to refine a Town Action Plan which makes detailed proposals for the development of the sites proposed in the Local Plan and which the Town Council hoped would be incorporated into the Local Plan. The Local Plan deals with many of our requirements in general terms but we feel that this is not in sufficient detail and would press for the incorporation of the detailed requirements set out in our Action Plan into the Master Plans suggested for each main site.
Subject to this general comment, these responses are delivered on the basis required by the Consultation as to whether the Plan is:
a) Sound
b) Deliverable
c) Sustainable
d) Followed proper process.

Housing Growth (Policy DS6)
Kenilworth Town Council has responded to all of the previous consultations on the Plan on the basis that it must not only provide for the specific needs of Kenilworth itself but also has to bear in mind that the town is part of the District and must reflect the amount of housing necessary across the District. As such the Town Council has appreciated the necessity to accept more development than is needed on a parochial basis as part of the larger community whose benefits we enjoy.
However the recent ONS forecast of population growth has indicated that the actual needs of the District, which we had accepted, may now have been superseded as it indicates a significantly smaller increase in need for the District as a whole. In these circumstances we feel there is a requirement for those figures to be investigated, and if a lesser figure is indicated then this must lead to a re-evaluation of the needs of the District as a whole, including Kenilworth, which saw an increased share in the latest version of the Plan.
As the forecast for Coventry has increased, we are concerned that the pressure may return for over the border development. However the analysis for the previous RSS showed that even with the revised figures there will be spare capacity within the Coventry boundary and therefore any cross-border pressure should be firmly resisted by the District Council. In particular there must be no development for the benefit of Coventry on Green Belt land in Warwick District, when development on Green Belt land in Coventry is not being considered.
The Town Council's view was that the development within the Town at Thickthorn should cease at Rocky Lane and should not include the Crackley Triangle. In the light of the new figures these two areas may need to be revisited.

Crackley Triangle (Policy DS11 Ref H05)
In relation to the Crackley Triangle, it is the Town Council's view that this is a very sensitive area, which although not within the Green Belt, is very much part of the barrier between Coventry and Kenilworth where the Green Belt is extremely narrow. Further, it is likely to be devastated by HS2 and as such the barrier against coalescing with Coventry will become almost meaningless unless further protection is given.
No consultation took place in respect of this area by the District Council in its consultations on the Plan. Whilst the Town Council's views were known as a result of it's draft Action Plan, this area was not referred to in the public consultation, so the public's views have not been ascertained.
Further, we do not believe that this area is deliverable because it has no access (except on to a narrow bridge with a difficult configuration which cannot be widened or straightened) and as such is not really safe or sufficient even for current traffic.
We feel therefore that this area should be revisited as to whether there is need, whether it is deliverable and whether due process has been followed.
Note: There is a current outline planning application for this site to which the Town Council has objected on access and drainage grounds.

Kenilworth School Relocation Site (Policy DS11 Ref ED2)
Whilst the Town Council acknowledges that it was likely that Kenilworth School would find it necessary to relocate onto a larger site because of current numbers, coupled with the increase likely to arise as a result of the new developments within the Town, no formal consultation has taken place upon the proposed move, or the site concerned. The site proposed is within the Green Belt and as such requires very careful consideration including enquiry as to the need for relocation, its siting and the deliverability of this relocation, particularly from a financial stand point.
Kenilworth School Sites in Leyes Lane and Rouncil Lane (Policy DS11 Refs H09 and H12)
The Plan now provides that the possible move of the Kenilworth School makes it's existing sites in Leyes Lane and Rouncil Lane available for development. This however has also not been previously proposed and again no formal consultation has taken place. Whilst the main site in Leyes Lane is within the Town envelope, the Rouncil Lane site falls within the existing Green Belt and therefore again must meet the tests appropriate to sites being taken out of the Green Belt. The Town Council is concerned whether the Plan is sound, having regard to there having been no formal consultation in regard to either sites.

Thickthorn Sites School Provision (Policy DS12)
In relation to the sites at Thickthorn it has always been the Town's contention that a development of this size must provide for a primary school within the development. The object of siting it within the development is to encourage families to walk to the School and thus decrease the use of transport and also promote a healthy life style. The proposal that this new primary school should be on the Southcrest Farm site is completely contrary to this logic and would lead to additional and unnecessary traffic movements, thus making it unsustainable.
It also could result in some of the existing primary schools being closer to the residents of Thickthorn than the one provided by the plan for this development. This would in our view make the Plan in this regard unsustainable in these respects.

Sports Fields (Policy HS4 and HS5)
Whatever the final agreed extent of housing and employment development at Thickthorn, there will be a need for some relocation of the existing sports facilities. Although there have been discussions, we note that no relocated sports sites feature in the Local Plan. Whilst we appreciate that alternative sites need not be identified until the planning permission stage we wonder whether there should have been some indication given here in order to ensure deliverability.

Local Plan Policies Maps (Maps 1 and 5)
We note that the Great Mere of Kenilworth Castle, a nationally Listed II* Historic Park and Garden is not identified on the relevant Policies Maps 1 and 5 although Policy HE4 clearly states that such areas are defined on the Policies map. We have not checked to see whether this serious omission is repeated for any other locations.

Retail Area Map (Map 5a)
We note and approve that the Kenilworth Town Centre Map 5a has been amended to include the Waitrose store within the Retail Area but note that the actual building has not been added to the map and the car park entrance has not been updated. There is also a missing building at the North end of Abbey End where the Almanack and flats are. Although the houses in Harger Court remain outside the Retail area, the houses in Harger Mews have been included together with houses in Bertie Road. We feel the boundary should exclude all these houses unless there is a specific reason to include them. When the map is corrected it would be useful to update the Wilton Court site development as well, although that is not within the Town Centre boundary.

Due to the proposed plan period, it appears that there has been some deviation from Warwick's assessed need of 720 dwellings per annum as set out in the Joint Coventry and Warwickshire Strategic Housing Market Assessment (SHMA) where the plan will deliver 714 dwellings per annum.
It is not transparent within either the Local Plan or any other supporting document how the housing target contained within DS6 for the 2011‐29 plan period has been arrived. It is however, understood that a background paper will be produced for the Submission Local Plan which will detail the approach taken. It is acknowledged that through policy DS7 that the authority have identified sufficient sites capable of meeting the assessed need identified (up to 2029), as identified within the Joint SHMA, at table 97.
In consideration of the above, in order to meet the full SHMA assessed need (2011 - 31), Warwick District Council must plan for the delivery of their remaining housing need as identified within the SHMA in the final two years of the SHMA period, through any review of the plan.

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