Revised Development Strategy

Object

Representation ID: 55482

Received: 24/07/2013

Respondent: Roxhill Developments Ltd

Agent: Oxalis Planning

Notes that an adopted housing requirement of 12,300 homes between 2011 and 2029 is an interim policy position and welcomes the recognition that this may change following the ongoing evidence gathering, and cooperation with neighbouring authorities.

However would also support the retention of the current methodology applied by Warwick District to informing and establishing housing requirements.

It appears the approach has been based around a desire to directly translate local economic aspirations and ambitions into a housing and development strategy (RDS, Section 4.1, pages 10 - 13).

This includes explicit recognition of the economic and job creation opportunities presented by the 'Coventry Gateway' employment development, including a technology park, recently positively considered by both Warwick District and Coventry City Councils.

The employment land policy approach proposed with regard to this sub regionally significant employment site is also supported (Policy RDS8).

Warwick District clearly forms part of a wider housing market with neighbouring authorities, reflected in the fact that various shared evidence and technical work has historically been undertaken jointly between Warwick District, Coventry City, and Nuneaton & Bedworth Councils.

Supports such an approach which is in accordance with NPPF, (para 17).

The Warwick District SHMA of March 2012 appears to have been undertaken in isolation of any consideration of the wider housing market. It was also published in advance of the publication of the final National Planning Policy Framework (NPPF).

Therefore welcome the references to a joint SHMA now being undertaken by Coventry City, Warwick District, Rugby Borough, and Nuneaton & Bedworth Borough Councils which understand will report late summer 2013.

That work was specifically required by the Inspector during the examination of Coventry City's Core Strategy as a response to the significant deficiencies and weaknesses identified in the approach taken by Coventry City.

In the absence of the joint approach now being taken to understanding the housing market, it seems likely that Warwick District's Local Plan would too have faced similar criticisms and questions by an Inspector at examination.

It will also be essential if the Council is to demonstrate that it has met the requirements of the Duty to Cooperate.

Object

Representation ID: 59433

Received: 24/07/2013

Respondent: Roxhill Developments Ltd

Agent: Oxalis Planning

The emerging shared SHMA evidence base is likely to have direct implications not only for the quantum of development required to meet housing needs across the housing market, but also the distribution of development within the component local authority areas.

The RDS seeks to focus development in and around the largest urban areas (Leamington and Warwick), with less but still significant development elsewhere, including Kenilworth, as well as some development in the smaller urban areas and villages.

Anticipate the outcome of the joint SHMA having implications for the development strategy in Warwick. In particular, building on the earlier shared evidence base such as the Joint Green Belt Review, there is likely to be a need for strategic residential development within Warwick District to help meet shared needs generated by virtue of the strong functional relationships with Coventry City.

It is noted that there is no explicit reference to Joint Green Belt Review of 2009 in the RDS, and would welcome confirmation from WDC that this existing element of the evidence base remains a key shared resource to inform strategic policy choices.

However, note the reference in policy RDS3 to "protect the Green Belt from development where alternative non-Green Belt sites are suitable and available" (our emphasis), and read this as a positive sign that the Council will consider Green Belt locations where no other suitable options exist to ensure housing needs in the housing market area are fully met.


Alternative:
In the context of the NPPF's requirement to plan positively to deliver sustainable development, this policy should be amended to explicitly refer to '...alternative sustainable non Green Belt sites are suitable and available'.

Such a change would recognise, as reflected in earlier Preferred Options and other work published by Warwick District that Green Belt locations are often more sustainable and suitable development locations than non-Green Belt locations.

The introduction of changes to accommodate growth to meet development needs in sustainable locations close to the urban area of Coventry would be well aligned with the clear local preferences expressed during the Council's 'Options' consultation exercise.

Similarly, the subsequent 'Core Strategy Preferred Options' of June 2009 also reflected the need to identify sites and locations close to the urban area to accommodate the development needs of Coventry.

While further work has subsequently been undertaken on the capacity of non-Green Belt locations south of Leamington and Warwick, the imperative to produce 'joined-up' and coherent plans which meet wider needs across boundaries will require such previously preferred options to be revisited.

An evidence base already exists to help inform decisions about the suitability of strategic development locations south of Coventry.

It is vital, particularly in the context of the recent approach taken by the Inspector at Coventry City's examination that WDC is proactive in considering the needs arising in the wider housing market area, and is able to demonstrate effective cooperation and joint working to meet development needs across the local authority boundary.