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.

Draft Policy DS7 sets out the various categories from which the overall housing requirement will be delivered. In general terms, given our comments above in respect of the overall housing requirement, there will be a need to identify additional sites for development.

More specifically, we note that the breakdown includes sites with planning permission at 1st April 2013 and sites with planning permission granted between 1st April 2013 and 31st December 2013. It is not clear from the supporting text, and we would therefore query, whether any discount has been applied to this figure or whether there is an assumption that all of the sites with planning permission will be delivered in full within the plan period. It would be normal practice to apply a 10% reduction to committed sites for non-implementation and to ensure robustness.


2.



We also note that there is a substantial allowance for deliveries from windfalls, small urban sites assessed in the SHLAA and a consolidation of existing employment areas. It is not clear whether there is any 'double-counting' of sites and we would query the robustness of including a windfall allowance if allowances are being included for small SHLAA sites and the consolidation of existing employment sites, given that these categories are likely to make up a large proportion of what would normally be regarded as windfall sites.

In this respect, we are concerned that the Plan may not be effective in that it does not ensure the delivery of the housing requirement within the Plan period.

In view of our comments above in respect of the need to increase the overall housing requirement and the robustness of the existing sources of supply, we consider that there is a need to identify additional sites for residential development.

We consider that land at the Woodside Management Centre (SHLAA Ref: K19) is suitable, available and achievable for residential development and could provide a valuable contribution towards meeting the full objectively assessed needs of the District over the plan period.

In coming to this view we are mindful that the land is located between draft housing allocation H06 (Thickthorn) and draft education allocation ED2 (Southcrest Farm), both of which are proposed to be released from the Green Belt for development. Should these draft allocations go forward to adoption, which we would support, the land at the Woodside Management Centre would effectively remain as a wedge of isolated Green Belt surrounded by built development and the A46. With this in mind, and conscious that the land already includes significant areas of built development and hardstanding, it is our view that the land would fail to meet any of the five stated purposes of including land within the Green Belt.

The site has been assessed by the Council in the 2014 update of the SHLAA which concludes that the site is potentially suitable. We can confirm that development of the site would not involve the loss of any high quality agricultural land and the site is readily available and could be delivered in the 0-5 year period. Having considered the potential constraints to development, it is our view that the extent of land available would allow significant landscape buffers to be retained and new planting introduced to provide an appropriate off-set from the nearby scheduled ancient monument and ancient woodland and to protect occupiers from any potential noise disturbance from the A46.

Initial feasibility work suggests that approximately 6.5 hectares of net developable land could be available which could accommodate between 150 - 200 dwellings together with associated open space, landscaping, access arrangements and sustainable drainage features. The development would be readily assimilated in to the existing residential development to the west and would provide key connectivity between draft allocations H06 to the south and ED2 to the north.

In terms of access to the site, there would appear to be two viable options. Firstly, it is possible to construct a new access to the site broadly in the location of the existing secondary access to the Management Centre, opposite the existing junction between Glasshouse Lane and Stansfield Grove. Alternatively, or as an additional point of access, there would appear to be potential to deliver an access point to the south in to the draft allocation H06. This could be delivered through an existing break in the woodland, without the need for significant tree felling. This link would also improve pedestrian and cycle links between the principal housing allocation for Kenilworth (H06) and the draft allocation for the new secondary school site (ED2), improving the sustainability of both sites.

Land at Woodside Training Centre SHLAA 14 Reference K19 remains in the draft proposals as a wedge of isolated Green Belt surrounded by built development (allocation ED2 and HO6) and the A46. With this in mind and conscious that the land already includes areas of significant built development and hardstanding, it is our view that this land fails to meet any of the five stated purposes of including land within the Green Belt.

In general terms we support draft Policy H2 which seeks to secure affordable housing as part of new development. In particular, we support the recognition that the location and means of delivery will be the subject of negotiation and will account of site specific factors such as viability, in accordance with paragraphs 173 and 174 of the NPPF. We would also support a policy which provides flexibility in terms of the sizes, types and tenures of affordable homes provided and which does not seek to set out a prescribed mix. The affordable housing mix needs to respond to the evolving requirements of Registered Providers and allow for flexibility to assist with delivery to meet housing need and align with their funding constraints.

We welcome the flexibility in the wording of this policy and would recommend that it is not amended to include the specific percentage splits. The NPPF seeks to ensure that a wide choice of high quality homes are provided and requires local planning authorities to "plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community" (paragraph 50, bullet 1). It therefore recognises the importance of allowing flexibility to adapt to market trends through development. As drafted, the policy would provide the flexibility to ensure the Plan remains consistent with paragraph 50 of the NPPF over the course of the plan period.