Revised Development Strategy

Object

Representation ID: 55424

Received: 29/07/2013

Respondent: Gladman Developments

Note that the current consultation focuses on the overall development strategy for Warwick District rather than providing full suite of emerging policies for the authority's Local Plan. Elements of the Strategy are still being formulated. Look forward to the opportunity of reviewing a more complete draft Local Plan in the future.

Question the Council's decision to consult on a housing requirement when its evidence of objectively assessed needs is yet to be published.

Until the Joint SHMA for Warwick, Coventry, Nuneaton and Bedworth has been prepared the Council cannot know what their objectively assessed housing requirement should be.

Relying on an interim figure in the meantime is considered unsound.

Support

Representation ID: 55425

Received: 29/07/2013

Respondent: Gladman Developments

Agent: Stansgate Planning

Support the identification of Radford Semele as one of the five Primary Service Villages as:
-Radford Semele is one of the largest villages in the District with a population of nearly 2000, and just over 800 dwellings.
-It lies close to Leamington Spa but is physically separate from it, having its own identity and its own community.
-As a settlement it is largely self sufficient for day to day things, having a Post Office, local shop, newsagent, hairdresser, primary school and nursery.
-There are some employment opportunities within the village, but also good public transport links to both Leamington Spa and Southam where a wider range of employment is available, together with further shopping facilities.
-There is a good variety of social activities available within the village which encourages community spirit and limits the need or desire to travel elsewhere for entertainment (i.e. White Lion Public House, Recreation Ground, Church).

Object

Representation ID: 60193

Received: 29/07/2013

Respondent: Gladman Developments

The interim housing requirement being progressed through the RDS is also arbitrarily low.

There is no justification for deviating from the housing projections presented in the Council's most recent 2012 Economic and Demographic Forecasts Study. Further the Council may be ignoring the current shortfall of housing against their Regional Strategy requirements.

This historic backlog cannot just be written off.

The NPPF is clear that local planning authorities should identify and meet their full objectively assessed housing needs, informed by a SHMA that has been prepared with neighbouring authorities where housing market areas cross administrative boundaries.

The housing requirement and Core Strategy cannot be found sound if they are inconsistent with this requirement.

Until the joint SHMA has been prepared the Council cannot know what their objectively assessed housing requirement should be. Relying on an interim figure in the meantime is considered unsound.


Notwithstanding the above issues, whilst recognising that the interim requirement is an increase on the Council's Regional Strategy requirement Gladman further question the process for identifying this target and submit that it is arbitrarily low.

The 2012 Warwick SHMA set out a range of projections for future housing requirements in the District.

In December 2012 this work was updated by the Warwick and Coventry Economic and Demographic Forecasts Study to take account of a now approved major technology and business park adjacent to Coventry airport, updated economic forecasts and the 2011 Census. Housing projections from both studies are set out in Table 1 in the representation.


The Council's interim requirement does not align to any of the projections presented in its evidence.

Whilst recognising that it is an increase on the Council's Regional Strategy requirements it is noticeably lower than the economic-based housing projections prepared for the Economic and Demographic Forecasts Study, including the revised baseline economic scenario.

It appears to be predicated on 2011 ONS household and population projections and an assumed GVA rate of 2.4%.

There is no justification for the Council's decision to ignore its objectively assessed housing needs and it has not demonstrated that there would be any adverse impacts of delivering a higher housing requirement to support its full economic potential.

Housing Backlog

The under supply of housing against the RSS target of 550 dpa in Warwick District equates to a shortfall of 1,281 units for the period 2006/07-2010/11.

It is not clear from the Council's evidence or RDS whether this shortfall has been taken into account when proposing the interim housing requirement, which has a base date of 2011.

Unmet need will not just disappear and therefore it is fundamental that it is taken into account in the targets moving forwards. It cannot just be written off.

The failure to include past shortfall in housing delivery in the proposed housing target should be considered unsound.

The delivery of any shortfall should be made up as soon as possible, and in the absence of evidence to suggest a longer timescale, the shortfall should be caught up within the first 5 years of the plan.

Duty to Co-operate

Until a jointly prepared SHMA for Warwick, Coventry, Nuneaton and Bedworth has been published the Council cannot fulfil its Duty to Co-Operate requirement.

This may reveal a requirement for the Council to meet the
housing needs of these adjacent authorities, and vice versa.
The importance of complying with the Duty to Co-operate is clear from the preliminary hearings on the Coventry City Core Strategy held in December 2012.

Object

Representation ID: 60194

Received: 29/07/2013

Respondent: Gladman Developments

Supports the Council's decision to direct development to the main urban areas and the sustainable Primary Service Villages.

However this should not preclude development coming forward in lower order, but still sustainable settlements.

Proposals according with the Council's guidelines for village development should be considered acceptable.

Where suitable, unconstrained sites are available this suggests that a village can support housing growth at the upper end of its allocated dwelling range.

It may also be preferable to focus more growth in villages that are unconstrained by Green Belt designations.

Object

Representation ID: 60195

Received: 29/07/2013

Respondent: Gladman Developments

Land to the north of Southam Road, Radford Semele represents the best opportunity to provide further housing growth in the village.

Support

Representation ID: 60196

Received: 29/07/2013

Respondent: Gladman Developments

support the identification of Radford Semele as sustainable location for further development.

Object

Representation ID: 60197

Received: 29/07/2013

Respondent: Gladman Developments

One of NPPF key changes relates to the need to "significantly boost the supply of housing" and this should be reflected in the plan making process.

What is clear from significant experience of involvement in the Local Plan process since introduction of NPPF is that many local authorities have not fully addressed its requirements when preparing their Local Plans and this has led to significant concerns being expressed by Inspector's on the soundness of their plans in their current format.

The main concerns centre upon the requirement in the NPPF to "use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area" (P47).

The process of undertaking an objective assessment is clearly set out in the Framework principally in P14, P47, P152 and P159 and should be undertaken in a systematic and transparent way to ensure that the plan is based on a robust evidence base.

The starting point for this assessment -to have a clear understanding of housing needs in their area -involves the preparation of a SHMA working with neighbouring authorities where housing market areas cross administrative areas.

The SHMA s[should] identify "the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which:
* Meets household and population projections taking account of migration and demographic change;

* Addresses the need for all types of housing including affordable housing and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes); and

* Caters for housing demand and the scale of housing supply necessary to meet this demand."

Key points that are worth noting from the above is that the objective assessment should identify the full need for housing before the Council consider undertaking any process of assessing the ability to deliver this figure.

In addition,P159 specifically relates to catering for both housing need and housing demand within the authority area.

Any assessment of housing need and demand within a SHMA must also consider the following factors; falling household formation rates, net inward migration, the need to address the under provision of housing from the previous local plan period, the preliminary results of the Census 2011, housing vacancy rates including the need to factor in a 3% housing vacancy rate for churn in the housing market, economic factors to ensure that the economic forecasts for an area are supported by sufficient housing to deliver economic growth, off-setting a falling working age population by providing enough housing to ensure retiring workers can be replaced by incoming residents, addressing affordability and delivering the full need for affordable housing in an area.

A majority of the SHMAs that were prepared under the current guidance on SHMA preparation are not NPPF compliant and do not consider the full range of factors that are outlined in P159.

To avoid these issues at Examination, SHMAs should be updated to take account of the NPPF and ensure plans are based on robust and up-to-date evidence.

Indeed, the Government have noted the deficiency in SHMAs and are updating the guidance on SHMA preparation to fully reflect the guidance given in the Framework.

Following the exercise to identify the full, objectively assessed need for housing in an area, the local planning authority should then seek to undertake the assessment outlined in P152 of the Framework.

This statement clearly sets out that local planning authorities should seek to deliver the full, objectively assessed need and that this should be tested through the evidence base.

Only where the evidence shows that this is not achievable should they then test other options to see if any significant adverse impacts could be reduced or eliminated by pursuing these options.

If this is not possible then they should test if the significant adverse impacts could be mitigated and where this is not possible, where compensatory measures may be appropriate.

The final stage of the process is outlined in P14 and involves a planning judgement as to whether, following all of the stages of the process outlined above, "any adverse impacts of meeting the objectively assessed needs would significantly and demonstrably outweigh the benefits, when assessed against the policies in this framework taken as a whole or specific policies in this Framework indicate development should be restricted."

The final part of this sentence refers to footnote 9 which sets out the types of policies that the Government consider to be restrictive.

Although this list is not exhaustive it is clear that local landscape designations, intrinsic value of the countryside, the character of areas, green gaps etc are not specifically mentioned as constraints.

Object

Representation ID: 60198

Received: 29/07/2013

Respondent: Gladman Developments

The NPPF sets out presumption in Favour of Sustainable Development seen as a golden thread of through both plan making and decision taking.

The Local Plan should set out how the Presumption will be applied locally in Warwick District and this should be included in a policy at the beginning of the document to show that the Presumption underpins the Council's development strategy.

The Council may consider using the model Presumption in Favour of Sustainable Development policy published by the Planning Inspectorate.

Object

Representation ID: 60199

Received: 29/07/2013

Respondent: Gladman Developments

Policy RDS2 sets out the components of the Council's housing land supply. In particular it makes a windfall allowance of 2,800 dwellings over the Plan period.

Remind the Council of the guidance set out in P48 of the NPPF, which states that "Local planning authorities may make an allowance for windfall sites in the five-year supply if they have compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply"

Object

Representation ID: 60200

Received: 29/07/2013

Respondent: Gladman Developments

The Council's preferred approach directs development to within and the edge of exiting urban areas. It allows for a higher level of growth in more sustainable villages with a reasonable level of services, and limited growth to smaller villages and hamlets of a scale appropriate to the existing settlement. It recognises that development directed towards villages may need to be located within or adjacent to the existing village envelope, and in some instances within the Green Belt.

In principle support the Council's distribution strategy. It recognises that growth should be directed to key towns and villages with established sustainability credentials, ensuring the creation of sustainable communities that have good access to a range of jobs, housing, community facilities and key services and infrastructure.

However, it should be noted that whilst the main settlements should accommodate a larger proportion of housing growth, this should not prevent development coming forward in lower order, sustainable settlements, which could also help to sustain existing facilities and services.


One of the principles of the Council's development strategy is to avoid development which could potentially result in the coalescence of settlements.

Would welcome further clarification on the decision making criteria that would be used to implement this policy.

In particular it should be recognised that development which results in a physical loss in separation can often be accommodated without eroding the character and identity of individual towns and villages.


Sustainable Urban Extensions and Housing Supply

A significant proportion - 66% - of the of the Council's proposed housing requirement is to be met through the allocation of sustainable urban extensions (SUE).

Whilst recognising the sustainability benefits that can arise from SUEs, placing too much emphasis on these sites could further result in an under-supply of housing in the District.

Large SUEs often require extensive infrastructure and planning prior to housing being delivered. As a result often they fail to come forward as anticipated, or only start to deliver in the medium to longer term.

If the Council cannot demonstrate a five-year housing land supply upon adoption of its Local Plan there's a risk that its housing policies will be out-of-date as soon as the Plan comes into effect.


In light of the above, and to ensure housing comes forward as anticipated, the Council need to allow for the release of additional housing sites, and earlier in the Plan period to meet its housing needs.

In doing so it should consider sites that result in sustainable development and continue to support the Plan's strategy.

Village Development

The Council's 2013 Settlement Hierarchy Strategy allocates an initial range of housing growth to each of the Primary and Secondary Services Villages.

It describes how these initial figures have been based on feedback from Parish Council's and Neighbourhood Plan teams, apportioning housing based on existing settlement size, and an outline assessment of key delivery factors, e.g. services and facilities, environmental impacts and the suitability of sites.

The initial dwelling ranges for the District's Primary Service Villages are set out in Table 3 (as submitted).

With reference to the distribution strategy for the Primary and Secondary Service Villages the Council is reminded that it should not be progressing a political strategy to apportion development to settlements where people do not want to (and will not) live.

Whilst recognising the role of parish council's and local communities in shaping the development of their areas first and foremost growth should be distributed on the basis of meeting housing needs.
There may also be a need to update the village dwelling allocations in light of the Joint SHMA findings.

The Strategy goes on to state that the initial dwelling ranges for each village will be reviewed in light of ongoing work on Green Belt assessment, habitat and landscape impact and identifying the most appropriate sites - that minimise environmental impacts, contribute to the built quality of the village and deliver an appropriate scale of development - which could deliver housing in each village.

This suggests that where suitable, unconstrained sites are available a village can support housing growth at the upper end of its allocated range.

It may also be preferable to focus more growth in villages that are unconstrained by Green Belt designations.

Policy RDS5 provides further guidelines on how housing within the villages should be accommodated. These criteria include:

* Ensuring an appropriate mix of dwelling types and sizes, including affordable housing

* Ensuring acceptable design, layout and scale through a collaborative approach involving Parish Council's, Neighbourhood Plan teams and residents

* Carefully considering the quality of development and how this relates to local vernaculars; and

* Ensuring landscaping will be used positively to contribute to and protect the quality of place


Where a proposal accords with these criteria it should be considered acceptable and sustainable.

However it is noted that two further guidelines for village development set out that housing growth should be located within the village envelope and give priority to the redevelopment of brownfield and previously used sites.

Gladman Object to these guidelines in their current form.


Whilst locating sites within existing village envelopes is desirable, under Policy RDS4 the Strategy recognises that there may be a need to locate further village growth adjacent to existing settlements. This should be emphasised in Policy RDS5.

Further, whilst it is recognised that the development of brownfield sites is important, a priority should not be placed on this which would act to arbitrarily restrict development on sustainable Greenfield sites. It is also worth noting that there are likely to be brownfield sites that are less sustainable than Greenfield land options.

Infrastructure Requirements

The RDS sets out requirements for the provision of infrastructure where it has identified specific site allocations and a range of Borough-wide highway improvements.

The Council are reminded of the guidance on viability set out in p173 of the Framework, which states that "Plans should be deliverable.

Therefore, the sites and scale of development identified in the Plan should not be subject to such a scale of burdens that their ability to be developed viably is threatened".


It is noted note that the Council is yet to publish an Infrastructure Delivery Plan or test the viability of its infrastructure requirements.

The robustness of these requirements in their current form. is therefore questioned.

The requirement to provide new infrastructure should only apply where there is a clear and evidenced deficiency in the provision of existing facilities to accommodate a development.