This modification is unsound on the basis that the housing requirement has changed from 12860 to 16776 without any justification and supporting data.

MM3 proposes stepping the annual average housing requirement. Between 2011/12 and 2016/17 the requirement is 600 dwellings per annum, reflecting the District's housing need, and from the adoption of the Local Plan in 2017/18 the requirement will increase to 1,098 dwellings per annum to reflect the Council's commitment to accommodate a part of Coventry's unmet housing need and the allocation of sites to provide for this. This has the convenient result of providing a 5 year supply of housing from 2017/18 to 2021/22, if the trajectory in Appendix A to the Main Modifications is taken at face value.

Unmet needs from Coventry have arisen since 2011/12 and therefore housing supply needs to be significantly boosted now in order to address the deficit that has accumulated. To provide this boost the answer should not be to skew the figures so that it appears as though there is a step change in housing delivery, but to provide more land for housing now in order to facilitate this step change. The plan period for the current Local Plan for the district expired in 2011, having been adopted only 4 years earlier. The approach taken to stepping the housing trajectory appears to reward the Council for failing to plan for housing over the last 6 years.

If the housing requirement is annualised at a consistent rate over the plan period (932 dwellings per annum) then the housing delivery set out in the trajectory in Appendix A to the Main Modifications would result in a 4.74 year supply, including a 20% buffer. This does not boost significantly the supply of housing and it would result in a Local Plan with policies for the supply of housing that are already out of date upon adoption of the Local Plan.

Coupled with providing sufficient flexibility in overall provision, further housing sites should be allocated in order to significantly boost housing delivery from the date of adoption of the Local Plan and provide a 5 year supply against the annualised average requirement of 932 dwellings from 2011/12 to the end of the plan period.

This modification is unsound on the basis that the housing requirement has changed from 12860 to 16776 without any justification and supporting data.

It is not proposed to add to the debate on the detail of this matter although the principle of now providing for substantially more new homes in the plan period is supported.

This is unsound because Coventry chooses not to meet its own housing need within its own boundaries. They impose a criteria for preserving their own greenbelt and allocating sites but then require WDC to take the overspill into WDC greenbelt. This is not a sound and consistent approach.