Proposed Modifications January 2016

Object

Representation ID: 69039

Received: 22/04/2016

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Proposed Modification Mod 1 seeks to update Strategic Policy DS2 to advise that full housing provision will be provided for the Objectively Assessed Housing Need (OAHN) for the District "and for unmet housing need arising from outside the District where this has been agreed." HOW Planning support the principle of Mod 1, however consider that as drafted the policy is too vague.

Object

Representation ID: 69205

Received: 22/04/2016

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

There is no meaningful MOU and there is no agreement to apportionment of the HMA's OAHN. It is fundamental that this is resolved so that the evidence base to support the Local Plan can be developed. Without a supporting evidence base, the Local Plan cannot progress as the sites allocated and the policies detailed within the Local Plan are not positively prepared and the Local Plan is therefore not justified.

Object

Representation ID: 69206

Received: 22/04/2016

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

In order for Policy DS6 to be consistent with the NPPF, the policy should be amended to identify that 16,776 units is the minimum requirement.
The Council's identification of 600 dwellings per annum as the justified OAN for Warwick is understated as it does not take proper account of proposed market signals, as required by national planning guidance.
Warwick's total requirement should be 1,022 dwellings per annum, equating to 18,396 units over the Plan period.

Object

Representation ID: 69208

Received: 22/04/2016

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

In order for Policy DS6 to be consistent with the NPPF, the policy should be amended to identify that 16,776 units is the minimum requirement.
The Council's identification of 600 dwellings per annum as the justified OAN for Warwick is understated as it does not take proper account of proposed market signals, as required by national planning guidance.
Warwick's total requirement should be 1,022 dwellings per annum, equating to 18,396 units over the Plan period.

Object

Representation ID: 69210

Received: 22/04/2016

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Policy DS7 identifies that 1,134 units will be delivered via windfall allocations over the period April 2015 to March 2029, equating to 81 dwellings per annum. No updated evidence to support this approach to windfall development.
As new allocations have been provided to deliver needs of the Borough, Council cannot assume that historic rate of windfall development will continue.
Yield from windfalls in first few years of the plan period will come mostly from sites with planning permission. At the start of the assessment period, doubtful whether the full averaged annual allowance of 81 additional windfall dwellings will be delivered.

Object

Representation ID: 69211

Received: 22/04/2016

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Acknowledge and support, to an extent, increased level of growth directed to the Growth Villages, however the Council's distribution of the updated OAN requirement to Growth Villages does not go far enough.
Policy DS10 is not justified as the approach to the release of a significant amount of land from the Green Belt is not based upon a robust evidence base.

Object

Representation ID: 69213

Received: 22/04/2016

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Proposed Modification Mod 14 requests the submission of either a Development Brief or a Layout and Design Statement as appropriate to the Local Planning Authority. HOW Planning consider that the policy should be updated to ensure clarity that the Development Brief or Layout and Design Statement are to be submitted the Local Planning Authority as part of any planning application submission for an identified Strategic Site. This ensures that the policy is not ambiguous, as at present the policy serves to complicate matters and delay development.

Object

Representation ID: 69216

Received: 22/04/2016

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Approach taken by the Council is not justified. The release of Green Belt land is based on no and, at fundamentally, flawed evidence. The evidence published alongside the Local Plan Proposed Modifications does not provide a robust evidence base to justify the quantum of Green Belt to be released or the sites selection for release.
Policy DS19, as modified, is unsound as the approach is not justified. Specifically, sites on edge of Coventry should not be carried forward and the requirement of 2,300 dwellings should be accommodated elsewhere in the district.

Object

Representation ID: 69217

Received: 22/04/2016

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Should Nuneaton and Bedworth remain removed from the MOU, and the HMA distribution of development remain as set out at Table 1, then on adoption the Local Plan would immediately trigger an early review.
It would be beneficial if the policy contained a trigger mechanism, specifically in respect of the monitoring of housing delivery, to ensure that the policy is not ambiguous.
As drafted, Clause (D) is not meaningful and should be reviewed in order to provide a clear policy.

Object

Representation ID: 69219

Received: 22/04/2016

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Council's justification for the release of such a quantum of Green Belt land is not justified and, furthermore, the parcels identified to be removed from the Green Belt are assessed as providing a great contribution to the role and function of the Green Belt.
The inclusion of this policy, and the subsequent updates to those policies which seek to identify development site, materially change the Local Plan's strategic and spatial strategies and therefore cannot be considered to be an update to the Local Plan.