Proposed Modifications January 2016

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Object

Proposed Modifications January 2016

Mod 5 - para 2.20

Representation ID: 69064

Received: 22/04/2016

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Warwick figure of 600 dwellings per annum is an acceptable starting point for the calculation of OAHN but the Updated SHMA Report provides insufficient justification for no further uplifts. Therefore 10,800 dwellings may be too low as an OAHN for Warwick. Council's own evidence in the up dated SHMA Report identifies :-

 - greater affordability issues in warwick
 - average house prices above national average

- affordable housing need however represents a higher % of demographically based need inWarwick District. In these areas some adjustment to overall housing provision might be appropriate to increase delivery of affordable housing"

Full text:

See attached

Object

Proposed Modifications January 2016

Mod 2 - Para 2.6

Representation ID: 69509

Received: 22/04/2016

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

uncertainty about whether or not OAHN for the C&W HMA will be met in full.
The resolution of this strategic matter remains uncertain because of inclusion of a figure of 14,060 dwellings (703 dwellings per annum) for Nuneaton & Bedworth rather than the 10,040 dwellings (502 dwellings per annum) as set out in the Pre Submission Local Plan consulted upon in December 2015 which makes no provision for unmet needs from Coventry so full OAHN will not be met.

From a letter dated 14 October 2015 Warwick District Council will be objecting to the Nuneaton & Bedworth Local Plan.

Full text:

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Object

Proposed Modifications January 2016

Mod 17

Representation ID: 69511

Received: 22/04/2016

Respondent: Home Builders Federation Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

This is a serious failing of co-operation between the C&W HMA authorities which has consequences for the soundness of individual Local Plans. Therefore the question remains whether or not the proposed Modifications 17 & 18 to Policy DS20 which set out triggers to action a review of the Warwick Local Plan adequately deal with and resolve the strategic matter of unmet housing needs arising in the C&W HMA.

It is also uncertain whether Modifications 17 to Policy DS20 cover the relationship between the C&W HMA and adjacent HMAs in which unmet housing needs are also arising, for example in Birmingham.

Full text:

See attached

Object

Proposed Modifications January 2016

Mod 18 - paras 2.82 to 2.87

Representation ID: 69513

Received: 22/04/2016

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Not specified

Representation Summary:

This is a serious failing of co-operation between the C&W HMA authorities which has consequences for the soundness of individual Local Plans. Therefore the question remains whether or not the proposed Modifications 17 & 18 to Policy DS20 which set out triggers to action a review of the Warwick Local Plan adequately deal with and resolve the strategic matter of unmet housing needs arising in the C&W HMA.

It is also uncertain whether Modifications 17 to Policy DS20 cover the relationship between the C&W HMA and adjacent HMAs in which unmet housing needs are also arising, for example in Birmingham.

Full text:

See attached

Object

Proposed Modifications January 2016

Mod 1 - Policy DS2

Representation ID: 69518

Received: 22/04/2016

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Council's calculation of the 5YHLS, MARCH 2016 is also questionable because it is based on OAHN of 600 dwellings per annum rather than a housing requirement of 932 dwellings per annum as set out in the Plan.

There is also uncertainty about whether or not an OAHN for Warwick is higher than 600 dwellings per annum which is based on demographic projections only and if a demonstrable 5 YHLS will exist on adoption of the Warwick Local Plan.

Full text:

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