Local Plan Main Modifications 2017

MM3 proposes stepping the annual average housing requirement. Between 2011/12 and 2016/17 the requirement is 600 dwellings per annum, reflecting the District's housing need, and from the adoption of the Local Plan in 2017/18 the requirement will increase to 1,098 dwellings per annum to reflect the Council's commitment to accommodate a part of Coventry's unmet housing need and the allocation of sites to provide for this. This has the convenient result of providing a 5 year supply of housing from 2017/18 to 2021/22, if the trajectory in Appendix A to the Main Modifications is taken at face value.

Unmet needs from Coventry have arisen since 2011/12 and therefore housing supply needs to be significantly boosted now in order to address the deficit that has accumulated. To provide this boost the answer should not be to skew the figures so that it appears as though there is a step change in housing delivery, but to provide more land for housing now in order to facilitate this step change. The plan period for the current Local Plan for the district expired in 2011, having been adopted only 4 years earlier. The approach taken to stepping the housing trajectory appears to reward the Council for failing to plan for housing over the last 6 years.

If the housing requirement is annualised at a consistent rate over the plan period (932 dwellings per annum) then the housing delivery set out in the trajectory in Appendix A to the Main Modifications would result in a 4.74 year supply, including a 20% buffer. This does not boost significantly the supply of housing and it would result in a Local Plan with policies for the supply of housing that are already out of date upon adoption of the Local Plan.

Coupled with providing sufficient flexibility in overall provision, further housing sites should be allocated in order to significantly boost housing delivery from the date of adoption of the Local Plan and provide a 5 year supply against the annualised average requirement of 932 dwellings from 2011/12 to the end of the plan period.

MM4 reduces the overall housing provision to 17,139 against the requirement of 16,776. This only provides 363 dwellings flexibility, which equates to less than 5 months' supply or 2% above the requirement. This is a negligible degree of flexibility. Paragraph 14 of the Framework says that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole; or specific policies in the Framework indicate development should be restricted. In the Inspector's letter of 1st June 2015 to the Council (EXAM 23, paragraph 37), he advised the housing provision provided no flexibility should site allocations not come forward as expected, concluding the supply of housing land for the plan period as a whole would fall short of that necessary to meet requirements and provide even a modest level of flexibility by several hundred dwellings.

The position taken in the Main Modifications does not seem to follow through with providing for flexibility should site allocations not come forward as expected. A deficit could easily result if the delivery of just one of the proposed site allocations did not come forward as expected, for example if H43 Kings Hill (1,800 units) was delayed by 2 years this would result in a loss of 460 units to the housing provision.

The Local Plans Expert Group report to the Communities Secretary and the Minister of Housing and Planning (March 2016) recommended at paragraph 11.4 that the Framework is amended to make clear that Local Plans should ensure a more effective supply of developable land for the medium to long term (over the whole plan period), plus make provision for, and provide a mechanism for the release of, developable Reserve Sites equivalent to 20% of their housing requirement, as far as is consistent with the policies set out in the Framework, to provide land that can be brought forward to respond to changes in circumstances. It is considered that the plan should provide for further safeguarded land sufficient to provide developable Reserve Sites equivalent to 20% of the housing requirement (3,355 units). This would be consistent with paragraph 85 of the Framework and would ensure sufficient flexibility to respond to rapid change.

Furthermore, it is noted that since the close of the examination Nuneaton & Bedworth Borough Council (NBBC) has consulted on their Regulation 19 Publication Borough Plan. This plan falls approximately 1,902 dwellings short of meeting NBBC's part of the redistributed housing requirement from Coventry under the Duty to Cooperate. Paragraph 8 of EXAM 181 says that the Nuneaton & Bedworth Local Plan is set to be submitted with approximately 1,902 dwellings of Coventry's housing need still unmet, so it would appear that despite objections from the other Housing Market Area authorities (EXAM 182) NBBC propose to plough ahead. Indeed, on 24th May NBBC is to hold an Extraordinary Council meeting to decide whether to submit their Local Plan for examination.

These circumstances would trigger a review of the Warwick District Local Plan under policy DS20 unless the changes required could be accommodated under the plan's strategy. Given the very limited degree of flexibility in the housing provision, there would be no opportunity to address unmet needs still 'floating' in the Housing Market Area without an immediate review of the Local Plan. This provides another strong reason to provide sufficient flexibility within the plan's strategy to respond to changing circumstances and avoid having to review the Local Plan immediately after its adoption.