Revised Development Strategy

Object

Representation ID: 55389

Received: 28/07/2013

Respondent: Crest Strategic Projects

Agent: d2planning

Duty to Cooperate

Local Planning Authorities are expected to demonstrate evidence of having effectively cooperated to plan for issues with cross boundary impacts when their local plans are submitted for examination. NPPF (para 181)

The duty to cooperate is particularly pertinent here since the inspector who recently considered the Coventry City Core Strategy (July 2013) concluded that it was not sound due to a lack of duty to cooperate on cross boundary issues namely in meeting Coventry's housing needs.

It is not disputed that Warwick District forms part of a larger strategic housing market assessment area which includes Coventry.

Following on from the inspector's conclusion on the Coventry City Core Strategy a new Joint Strategic Housing Market Assessment is underway. The results of that will not be known for some time yet.

Part of Coventry's need may have to be identified in Warwick District, as previously identified in the RSS, and should be acknowledged in this Local Plan.

This will entail identifying opportunities in the most sustainable location which is to the south of Coventry on land currently within the green belt.

Recommendation

Make explicit the request regarding the duty to cooperate and also the potential to accommodate some of Coventry's housing provision within Warwick District.

Object

Representation ID: 60176

Received: 28/07/2013

Respondent: Crest Strategic Projects

Agent: d2planning

Objects to this policy on the basis that the overall housing provision does not meet the identified housing requirements set out in the evidence base.

This level of growth is insufficient as it is lower than the evidence in the SHMA as well as recent household projections.

The is not complete given that the joint Strategic Housing Market Assessment is not finalised.

Agree with the general premis, that there is a direct relationship between new jobs in the District and the demand for new houses.

It is however necessary to adopt an as realistic approach as possible. Given the location of the District i.e. close to the large employment centres of Solihull, Coventry and Birmingham, there inevitably will be a demand for housing in the District from people who work outside the District.

SHMA

The SHMA indicates that the annual need for affordable housing will be 698 dwellings per annum.

This exceeds the preferred option for housing growth and more importantly only addresses the affordable housing need, not the need for open market housing which will largely provide the affordable housing.

The SHMA does not address what the market need will be in the District in addition to the affordable need.

Accordingly the SHMA does not satisfy the requirements of paragraphs 159 of the NPPF.

The SHMA needs to set out what the quantity of need is for both market housing and affordable housing for the plan period.

At present the preferred option does not explain why it is disputing the evidence of need in the SHMA.

Household Projections

The plan makes reference to the interim 2011 based population projections.

However these are incomplete and so the 2008 based projections are at present the most reliable source until more up to date population projections are published and are complete.

The 2008 based household projections indicate an increase of 13,000 households in the period from 64,000 in 2013 to 77,000 in 2028 9 (roughly comparable to the proposed plan period)

The Council may find that economic growth and housing demand are stronger than expected and the plan (in accordance with NPPF)will need to have the flexibility to respond to rising demand - something at present it does not have.

Housing demand is not solely related to employment prospects.

The District will experience continued inward migration from affluent households who work elsewhere e.g. Birmingham, Coventry etc.

The Council will need to cater for these requirements but also increase the overall level of supply in order to deal with those on low to medium incomes so that they are not priced out of the market by affluent incomers.

Relying on the recession would be contrary to the Government's 'Policy for Growth Agenda' which requires the planning process to deliver increased levels of growth.

Duty to Cooperate
If the Council is unable to meet its objectively assessed housing need through its plan, it will need to plan to ensure that these needs can be met elsewhere within the District.

To do so, it will need to plan, in tandem, with other Councils.

The draft Local Plan makes no reference to this issue.

Other adjoining Authorities are progressing plans which do not meet all of their own objectively assessed housing needs e.g. Solihull and Stratford.

In addition Coventry are at the early stages of preparing their Local Plans and have commenced a Joint Strategic Housing Market Assessment.

Providing part of Coventry's housing requirement in Warwick District has previously been proposed. The RSS preferred option identified 3,500 dwellings adjacent to Coventry but located within Warwick District, and necessitating a green belt review.

The land owned by Crest at Westwood Heath is ideally placed to meet these requirements because:

i) The Coventry Joint Green Belt Review identified the site is one of the least constrained proposals of land to the south of Coventry which could potentially be released from the Green Belt;

ii) The SHLAA has assessed the site's potential and concluded that: "Potentially suitable in part only (18.5 hectares) excluding southern extensions to the site which could impact upon potential SINCS. Any development would be subject to satisfactory measures to mitigate against impact on areas of high landscape value."

iii) The Strategic Transport Study concluded that development in the Westward Heath Road area has minimal impact on the surrounding road network.

iv) The site is not within an area liable to flooding.

v) The site lies in a highly sustainable location next to the University of Warwick, employment operators and good public transport linkages; and.

vi) The High Speed Two Rail Link route would cross to the south of the site which would potentially provide a further defensible boundary.

if some adjoining Authorities e.g. Coventry City are not proposing to meet all of their own identified requirement then it is unlikely that they will accommodate any of Warwick's . unmet need.

This is an issue that needs to be resolved before the Examination.

Recommendations

The level of housing provision needs to be assessed against updated strategic housing market assessment.

The level of housing provision needs to be increased and sites identified/released from the green belt to be able to accommodate Coventry's future housing requirement e.g. land at Westwood Heath Road.

Object

Representation ID: 60177

Received: 28/07/2013

Respondent: Crest Strategic Projects

Agent: d2planning

Objects to supply of housing sites identified in Table 1.

The recent appeal decision on land south of St Fremund Way, Whitnash Leamington Spa identified that the Council could only demonstrate a 2.6 year supply of housing land (May
2013).

Table 1 does not make any provision for a 5% or 20% buffer as required by paragraph 47 of NPPF.

Given the Leamington Spa appeal decision it would appear that the Council has consistently underperformed in its housing delivery and accordingly there should be a 20%
buffer applied.

There is no reference within this policy or the supporting text to the Council consistently underperforming in meeting its housing needs. Furthermore, paragraph 47 of NPPF states that identified sites should be deliverable.

It is unclear how the Council has arrived at its 300 small urban SHLAA sites as being deliverable since these sites usually exhibit complex ownership and assembly issues.

It is unclear whether this level of development can be achieved for these sites.

In addition there appears to be 'no compelling evidence' to justify the proposed level of windfall, as required by paragraph 48 of NPPF.

Recommendation
Reassess the supply of housing sites and identify more deliverable sites.

Object

Representation ID: 60178

Received: 28/07/2013

Respondent: Crest Strategic Projects

Agent: d2planning

Proposed Alternative Housing Allocation at C13 Lodge Farm, Westward Heath Road, Coventry:

There is a recognised and identified need for additional housing within the District not just to meet the District's housing needs but also those of adjoining Districts such as Coventry.

The Core Strategy should and must provide the necessary certainty that those needs will be met. This can only be achieved if additional land is identified for housing development.

It is considered that in meeting the actual housing needs for the District (and those of adjoining Districts) that land currently within the green belt will need to be released.

Whilst the site is currently located within the green belt, the joint green belt review (2009) (site C14C -see plan submitted with representation) concluded that the site was relatively free from constraints and should be taken forward for further consideration.

The site is considered available, suitable and achievable.

There are no constraints to the delivery of the site in respect of school capacity, highways, landscape and visual impact, biodiversity, heritage assessment, drainage or ground conditions.

The release of the site has the potential to be developed in accordance with the principles of sustainable garden towns as set in the Council's Garden Towns, Village & Suburbs Prospectus.

Recommendations The site should be released from the green belt and allocated for a housing land development of up to 880 dwellings within the Local Plan. That development should adhere to the principles of sustainable garden towns as set out in the Council's Garden Towns, Village & Suburbs Prospectus (see plan submitted with representation).