The delivery of affordable housing is a key Government objective aimed at enabling everyone to have a decent home that they can afford. However, through the new Local Plan we believe the provision of affordable housing -linked to open market housing development- must be realistic with regard to economic viability and at the same time flexible to variations between sites and changes in market conditions over the plan period.

In the Council's Affordable Housing Viability Assessment (AHVA, Nov 2011) it is recognised that most residential developments are presently not only expected to provide affordable housing as part of Section 106 Agreements, but also to contribute to other costs imposed by the local authority on the development, such as highway works, provision of community facilities, education payments, etc. These additional development cost were therefore taken into account by factoring in an allowance of £6,650 per unit for S106 contributions under each the viability scenario tested; an average contribution figure on recently approved schemes in Warwick District. By comparison, in the Draft Infrastructure Plan we note that the total indicative cost for highway infrastructure alone is in the region of £48m or approximately £5,000 per new home.

At this time, therefore, while the full costs of infrastructure required to deliver the Plan and thus the CIL rate which the Council intends to charge remain unknown, we consider that it is premature for the Council to require any specific affordable housing percentage requirement. Furthermore, we note that the SMHA recommended an affordable housing target of 30%, while in the AHVA a 40% affordable housing target was only considered viable across the district under 'improved market conditions' i.e. similar conditions to those seen in early 2007. However, average house prices are not forecast to hit 2007 levels again until 2018 (UK housing market forecast, Knight Frank). The current downturn in residual land values will obviously have a considerable impact on the viability development schemes especially in Phase1 of the plan and this factor should be reflected in a revised policy PO5.

In response to these conditions, we believe to ensure that Policy PO5 is truly flexible the Council should:

* Set an affordable housing target which covers the lifetime of the Local Plan subject to monitoring of changing housing need and market conditions.

* Negotiate the overall quantity, type and tenure of on-site affordable housing on a site-by-site basis, having regard to scheme viability; viability assessments should not simply be based on addressing particular on-site constraints.

COMMENT

We acknowledge that in developing the preferred option for affordable housing the Council has had regard to an addendum to the AHVA which we understand was issued in May 2012. Unfortunately we have not been able to locate this document on the Council's website and thus are only able to comment on the suitability of the policy having regard to the other evidence base documents.

COMMENT/ CLARIFICATION SOUGHT

Under Policy PO6, bullet 'A', clarification is sought as to what policies set out the required mix of housing on development sites. We also consider that it would be better for the policy to refer to "latest published available housing market data" to confirm the required mix than referring specifically to the "latest" SHMA.

Though desirable, meeting Lifetime Homes standards is not a national requirement, and so must be supported by viability studies. If policies promote requirements outside national guidance, then there needs to be convincing local evidence to justify this.

We object to the blanket requirement that all strategic sites will need to include Extra Care Housing (ECH). Whilst our clients are considering this form of housing as part of development proposals on land north of Gallows Hill/west of Europa Way, the final decision on whether or not this is appropriate for the site will have to have regard to overall scheme viability and market demand. With regards the latter consideration we are aware that the Council has recently received a number of planning applications for ECH schemes within the District, including sites in the south Warwick area. If these schemes are approved then the local market may well become saturated with resultant implications for the viability of new schemes in the early phases of the Plan. We recommend that through the policy, rather than simply 'require' ECH on all "strategic sites", the Council should provide an accompanying qualification that the requirement will be subject to market testing/viability. It would also be helpful if the District liaised with WCC and commissioned a specific study on ECH looking at both location and extent of existing and emerging supply, as well as forecast demand across the District.

We broadly support the stated purpose of Policy PO8, namely ensuring the availability of a wide range of employment land and buildings which are able to meet the needs of businesses into the future. We object, however, to the Council's proposed allocation of "a proportion" of land north of Gallows Hills/west of Europa Way for employment uses (please refer to separate comments under PO4). We also object to the current wording under the fourth bullet of the policy. It is our considered view that the loss of employment land and floorspace as a result of a change of use, including residential use, should only be permitted where there is no reasonable prospect of the site or building being used for employment purposes.

Under the first bullet the policy makes reference to supporting the delivery of priorities in the Council's emerging Economic Development and Regeneration Strategy but does not state what these priorities are nor is there any reference to them in the policy's justification. At the time of writing this comment we are also not able to say whether or not we support the priorities in the emerging Strategy as no draft appears to be currently available.

COMMENT

As stated at para 8.21 we believe that there is a need for further work to help determine the employment needs of the District over the plan period to 2029 and, recognise that the work presented in the Preferred Options is based on the Council's "initial" review of committed employment land. Within this context, however, we question the Council's proposed allocation of "a proportion" of land north of Gallows Hills/west of Europa Way for employment uses and a re-allocation of the committed employment site at Warwick Gates for housing. In conflict with draft policy PO8 we have not seen any evidence to explain why the Warwick Gates site is no longer considered suitable to accommodate employment uses/projected employment needs.

The Council states that the Local Plan "must" provide employment opportunities in locations to meet the needs of new housing, and that "...the selection of sites is guided by those identified for housing" (para 8.27). While it remains a national policy to seek to reduce the need to travel (by means other than the private car) and that achieving a balance between employment and housing growth is an important element in planning for a sustainable pattern of development, the Council's stated approach to determine the most appropriate location for new employment land within the District appears neither robust nor rigorous. By proposing that strategic sites allocated for housing should also include an allocation of employment land, we believe the Council has failed to recognise that not all proposed strategic site allocations are the same.

Land north of Gallows Hills/west of Europa Way is surrounded by existing employment opportunities, and within walking distance of major committed employment sites (Warwick Gates and the Leamington Gateway/former Ford Foundry site). Furthermore, the District has an existing healthy supply of employment sites which, given existing levels of demand, is unlikely to be taken up in Phase 1 of the Plan period nor possibly in Phase 2 if the Coventry and Warwickshire Gateway scheme comes forward.

The Europa Way Consortium and Warwickshire County Council are, in line with Policy PO4, committed to bring forward land north of Gallows Hills/west of Europa Way in Phases 1 and 2, and consider that it is preferable to bring forward much needed housing on this site rather than have part of the site sat undeveloped awaiting take-up by employment development market.

We support the Council's decision to take forward the NPPF's suggested approach that large urban extensions should follow the principles of garden cities and garden suburbs. Many of the garden city principles accord with our own ambitions for the kind of development we wish to see brought forward on land north of Gallows Hill/west of Europa Way. In fact in the interest of providing a high quality environment for its residents and engendering a sense of community, we are consulting with Bournville Village Trust over masterplanning considerations and long term stewardship of the site, and are keen to work with the local community and stakeholders to bring this exiting development opportunity forward.

The government has indicated that there will be consultation later this year about how local authorities and developers might apply garden city principles to new developments. It will be interesting to see what comes forward as part of this consultation and how the Council's own prospectus compares with this.

We acknowledge reference to the use of 'design codes' to also support the garden city initiative. It would, however, be helpful if the Council explained how it sees design codes being developed and brought forward. Is this something the Council will be undertaking itself so that there is a common approach to different types of development/ locations across the District, or is the Council looking for developers to prepare design codes themselves or in partnership? Furthermore, how is the design coding intended to link with requirement for Development Briefs as called for under Policy PO4? If the developer is expected to prepare design codes as an integral part of the development brief, then we feel that those promoting Phase 1 sites could be unfairly burdened with undertaking work which would likely be taken forward and applied by developers of the strategic site allocations phased later in the plan period.

Policy PO11, which seeks to protect the historic environment from inappropriate development and ensure its economic viability for future generations, is supported.

We consider the present extent of the proposed allocation of land south of Gallows Hill/west of Europa Way to be in conflict with this policy.

It is recognised that on-site renewable and low carbon energy technologies will have a roll to play in achieving nationally prescribed standards on new development sites. However, we consider that this all needs to be subject to feasibility and viability testing - a crucial caveat that needs to be mentioned in the preferred option, consistent with Para 96 of the NPPF. District heating is one technology to consider amongst many, and whilst it may be technically feasible for larger mixed use sites, the up front capital costs, complexities regarding implementation for phased developments and lack of experience in setting up these networks for residential-led schemes in the UK are significant challenges.

We consider that PO12: Climate Change should be updated to accord with the provisions of the NPPF. At para 95 the Government advises in the Framework that when setting any local requirement for a building's sustainability, local authorities should do so in a way that is "... consistent with the Government's zero carbon buildings policy and adopt nationally prescribed standards.". The proposed preferred option - which includes the requirement for a 20% carbon reduction via renewable and low carbon technologies - is not seen as consistent with the Government's zero carbon buildings policy or nationally prescribed standards.

It is at the national level, via on-going revisions to Part L of Building Regulations, that the Government is implementing its zero carbon buildings policy. These revisions to Building Regulations necessitate higher standards of energy performance in dwellings and the use of on-site renewable and low carbon energy. Future changes are expected to include a mechanism for off-site carbon reduction measures called 'allowable solutions'. Building Regulations are therefore the primary driver for the use of renewable and low carbon energy and so we recommend removing the 20% carbon reduction target proposed for the Local Plan.