Preferred Options

Ended on the 25th September 2009
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10. Housing

Core Strategy Strategic Objective

To help meet current and future housing needs through ensuring sufficient suitable land for housing is available and able to be developed to meet future requirements, and that new housing development is of the right type, size and tenure.

Related SCS Strategic Aim

Everyone's housing needs are met

Why is this a strategic objective?

10.1 Housing is a basic human need and its quality, cost and availability are crucial to the individual's quality of life. Maintaining a supply of decent homes in good quality environments that can meet the needs of all of the community is fundamental to maintaining strong communities with a healthy and mixed population, as well as a strong and growing economy.

10.2 The population of the District is increasing and is expected to continue to increase up to 2026. At the same time household size is getting smaller with more people living alone, and notwithstanding the current downturn in the housing market, there will be an increasing need for more new homes over the coming years. The Core Strategy must plan for the long term (at least 15 years) and show how it will meet this housing need in suitable locations which can offer a range of community facilities and with good access to jobs, key services and infrastructure. The homes must also be of the right types, sizes and tenures and in safe, attractive and sustainable environments where people want to live.

10.3 Warwick District is a popular place in which to live and as a result house prices in the District have been amongst the highest in the West Midlands. It is very difficult therefore for those on low incomes to find housing that they can afford in the District even allowing for the recent fall in house prices. The Core Strategy must therefore include measures to help ensure that the needs of those in the community that cannot afford open market housing are also met in the longer term.

Evidence:

Participation

10.4 In response to the consultation on the "Issues Paper", respondents considered that "meeting the housing needs of the whole community including providing adequate affordable housing" was one of the top three priorities for the District, with over 60% considering it a high priority. There was also strong agreement by respondents (79%) that the provision of sufficient affordable housing to meet projected needs was an important issue. In terms of where new housing should go, just over half of respondents thought that it was acceptable to build new homes on greenfield land on the edge of towns and a majority of respondents (63%) thought housing should be built at densities which reflected the local character of the area.

10.5 The "Options Paper" identified 15 broad "directions of growth" outside of the existing towns where housing development could be located. These included areas south of Coventry, south and east of Kenilworth, south and west of Warwick, north and east of Leamington, and south of Whitnash. Respondents were asked which areas they supported and which areas they objected to. Treating all respondents equally, the three directions to the south of Coventry (around Baginton, Finham and Kirby Corner) received the most support from respondents. The directions to the north and east of Leamington, and south of Whitnash received the most objections. Respondents also identified other areas where housing development could be located and these have been investigated separately as part of the Strategic Housing Land Availability Assessment (see below).

Research

10.6 The Council have identified the following documents which also guide and inform its approach to housing issues:

  • Warwick District Strategic Housing Land Availability Assessment 2009 and supporting documents;
  • South Housing Market Area Assessment 2008;
  • Warwickshire Supporting People Strategy 2008;
  • Joint Housing Assessment for South Warwickshire 2006;
  • West Midlands Regional Housing Strategy 2005;
  • Warwickshire Black & Minority Ethnic Housing Needs Study 2005; and,
  • Warwick District Homelessness Strategy 2005.

National and Regional Planning Policies

10.7 National planning policy for housing is contained within Planning Policy Statement 3: Housing, published in November 2006. This places a number of requirements on the local planning authority in terms of its approach to housing issues, including a requirement to include policies within a local development document that:

  • Achieve high quality housing;
  • Achieve a mix of housing (both market and affordable);
  • Make effective use of existing housing stock, e.g. vacant properties;
  • Provide housing in suitable locations;
  • Make effective and efficient use of land, including previously developed land; and,
  • Demonstrate delivery of a flexible supply of land for housing for at least a 15 year period, including allocating strategic sites, within the Core Strategy.

10.8 Regional planning policy for housing is set out in the West Midlands Regional Spatial Strategy (RSS). The RSS contains policies encouraging the recycling of land and buildings for housing, and delivering affordable housing and mixed communities. It also establishes requirements for the amount of new housing to be built for the period 2001 to 2021. The requirement for Warwick District is calculated as 8,286 dwellings, of which nearly 7,000 dwellings had already been built or granted planning permission at April 2008. In terms of the adopted RSS, the Core Strategy only therefore needs to plan for approximately 1,300 new dwellings for the period to 2021.

10.9 However, the RSS is currently under review and national planning policy requires the local planning authority to plan to meet the level of housing provision within the emerging Phase Two Revision. The Phase Two Revision requires the provision of 10,800 dwellings for the period 2006 to 2026. The Core Strategy will therefore need to demonstrate sufficient land can be made available for housing to meet the emerging RSS Phase Two Revision requirement for a 15 year period from the date of its adoption (i.e. for the period 2011 to 2026). Taking into account homes already built or granted planning permission since 2006, the housing requirement for this fifteen year period has been calculated to be 8,100 new homes. This figure would be made up of approximately 2,100 homes which are anticipated to come forward on sites which are currently in other uses but will become available for housing during the period to 2026 (i.e. windfall sites), and approximately 6,000 homes from sites to be identified. This is explained in the following table.

Source of New Homes

No. of Homes

Total Number of New Homes Required

(RSS Phase 2 Requirement 2006 to 2026)

10,800

New homes built between 2006 and 2008

1,045

New homes under construction at April 2008

530

New homes with planning permission at 2008 (allowing for 2.5% of homes with permission not being built and permission lapsing)

1,125

Balance to be found to meet the RSS Phase 2 requirement

8,100

New homes which are expected to come forward on urban and rural windfall sites, i.e. sites that are currently in other uses but become available between now and 2026

2,100

New homes for which sites/locations need to be identified from 2011 onwards

6,000

10.10 In addition to and separate from the above figures, the RSS Phase Two Revision requires that where Coventry City Council cannot identify sufficient land for new homes in order to meet its requirements, they may have to be allocated adjacent to the city but within Warwick District or Nuneaton & Bedworth. This is part of the sub-regional strategy which directs a proportion of the expected household growth up to 2026 from Warwickshire, and particularly Warwick District, to Coventry in order to support its urban regeneration and help meet more of its own needs in order to avoid the outward movement of people and jobs to areas like Warwick and Leamington.

10.11 The Core Strategy may therefore need to demonstrate sufficient land can be made available to meet an element of Coventry City Council's emerging RSS Phase Two Revision housing requirement which it cannot provide for within its administrative area. The Draft Core Strategy for Coventry identifies that it can accommodate 26,510 dwellings within its administrative area. This leaves a shortfall of 6,990 dwellings against its RSS Phase Two Revision requirement to be provided on its boundary either within Warwick District or Nuneaton & Bedworth Borough later within the plan period to 2026. Nuneaton & Bedworth are not sufficiently advanced with their Core Strategy to have identified any sites within their area at this stage and therefore it is not yet possible to quantify how much might be required to be found within Warwick District.

10.12 The RSS Phase Two Revision also includes policies requiring the phasing of housing development to support regeneration, the re-use of brownfield land before greenfield sites, the development of green belt sites to be phased later in the plan period, the efficient use of land, and the delivery of affordable housing and mixed communities.

What are the options?

10.13 The Core Strategy will need to take into account all of the above evidence and national and regional policy and set out the ways in which new housing will be provided for in terms of:

  • the location of new housing;
  • the mix and affordability of new housing; and,
  • housing density and the effective use of land.

'Options' for the Location of New Housing

10.14 The options for the Core Strategy have been drawn from the Strategic Housing Land Availability Assessment (SHLAA). This is a technical document that forms part of the evidence to support the Core Strategy and is available on the Council's website. The primary roleof the SHLAA is to identify buildings or areas of land (including previously developed land and greenfield) that could have development potential for housing, including within mixed use developments.

'Red Sites' - Sites submitted to the Council for Housing Development

10.15 Over 150 possible housing sites across the District were submitted to the Council by developers/landowners for assessment within the SHLAA and plans for each of the sites can be found within the SHLAA report. For the purposes of identifying sites for possible inclusion in the Core Strategy, only urban or edge of urban sites were considered at this stage, as national and regional policy requires housing development in the rural areas to be limited to meeting local needs which have been identified by the local community.

10.16 It is acknowledged that there are issues around the long term sustainability of village communities and services that additional housing directed to villages through the Core Strategy could help to address. However, the scale of housing that may be needed to ensure viable village services in the long term is difficult to predict, but it is likely to be significant. This scale of growth would be likely to conflict with wider transport and sustainability objectives in relation to reducing the need to travel. Sites within the rural area are not therefore included as options within the Core Strategy, although it is acknowledged there are issues around the future viability of village services, the loss of which could in themselves contribute to increased need to travel and less sustainable patterns of development. This issue is considered further within the 'Rural Communities' section of the Preferred Options.

10.17 The SHLAA sites within or surrounding the urban area (excluding very small urban sites) are highlighted in 'red' on the plans attached as Appendix One and Two. Each of the 'red' sites put forward within the SHLAA was assessed in terms of its:

  • availability, i.e. where the owner is willing to bring forward the site for development, or where there is a likelihood of the site being brought forward for development within the period to 2026;
  • achievability, i.e. where development could be expected to take place, subject to improvements to infrastructure and a strong housing market; and finally,
  • suitability, i.e. where there are no known environmental or physical constraints, such as flooding or access difficulties, which cannot be overcome and therefore prevent the whole site from being developed.

10.18 A number of sites were discounted at this stage as they were not considered suitable for housing development. This was for reasons such as:

  • inadequate means of vehicular access;
  • site has important historic, landscape or ecological value;
  • site within an area at risk of flooding;
  • poor site configuration or topography;
  • site is high value agricultural land;
  • unsatisfactory environment due to noise and pollution from nearby uses; and,
  • remote from urban area and not capable of contributing towards sustainable communities.

'Amber Sites' - Sites considered by the Council as 'Options' for Housing Development

10.19 The remaining sites that passed each of the three tests above are highlighted in 'amber' on the plans attached at Appendix Three and Four and listed in the following table. These are therefore potentially suitable housing sites and comprise the 'options' for the Core Strategy.

10.20 An estimation was made of the number of homes that could be built on each site having regard to an average density of 40 dwellings per hectare net, and the need to exclude land required for other supporting uses, such as open space, allotments, natural areas, community and health facilities, schools and leisure facilities, roads and paths, employment areas and local centres. The number of homes has also been reduced where constraints have been identified on part of the site, e.g. protected woodlands or allotments.

'Options ' - the Amber Sites

No. of Homes

Leamington, Warwick & Whitnash Urban Area

Small urban brownfield sites (see SHLAA)

450

Land at Warwickshire College, Warwick New Road, Leamington

300

Land at Station Area, Leamington (Fords Foundry and Station Approach)

225

Employment Land at former IBM car park, Birmingham Road, Warwick

100

Leamington, Warwick & Whitnash Urban Edge Greenfield Sites

Land North of Milverton to Sandy Lane, Old Milverton

1,500

Land South of Sydenham and east of Whitnash

200

Land at Woodside Farm, north of Harbury Lane, Whitnash

250

Land east of Buckley Road, Lillington

200

Land at Lower Heathcote Farm, south of Harbury Lane

2,500

Land west of Europa Way, Warwick

1,250

Employment Allocation, west of Stratford Road, Warwick

100

Employment Allocation, north of Harbury Lane, Warwick

250

Kenilworth Urban Area

Small urban Brownfield sites (see SHLAA)

25

Kenilworth Urban Edge Greenfield Sites

Land at Thickthorn, between Kenilworth and the A46

800

Land east of Glasshouse Lane/south of Crew Lane

750

South of Coventry Urban Area

Small brownfield sites (see SHLAA)

25

Land at Kings Hill, south of Green Lane, Finham

3,250

10.21 It is evident from the above table that there is more capacity within the 'options' listed than required to meet the requirement within the emerging RSS Phase Two Revision. It is necessary therefore to choose the 'preferred option' from these 'options' and this has been informed by the following:

  • the Spatial Vision and Strategy (see Section 3 of this Paper) directs the majority of growth to the south of the urban area of Warwick/Leamington/Whitnash in order to protect the Green Belt to the north of the towns and to reduce the amount of traffic movements through the historic town centres to the main employment areas and transport connections (Leamington Station and the M40 junctions) to the south. This results in the discounting of the 'options' at land north of Milverton and land east of Buckley Road, Lillington;
  • the Employment Land Review (see Strategic Objective 1: Employment) identifies the need to protect existing suitable employment land supply in order to meet future requirements, unless particular site specific reasons exist. This results in the discounting of the 'options' at land at former IBM Car Park, and the employment allocations west of Stratford Road, and north of Harbury Lane;
  • the evidence, including the responses to the "Options for Growth" consultation; and,
  • the Sustainability Appraisal and its assessment of each site against the objectives.

Feedback - Options for Housing Locations
(2129) Do you agree that the Council has identified all reasonable options for the location of new housing?
Please explain your response when answering this question.

Green Sites - 'Preferred Option' for the Location of New Housing

10.22 The Preferred Option for the Core Strategy to meet the RSS Phase Two Revision requirement for Warwick District are the sites highlighted in 'green' on the plans within Appendix Five and Six, and listed below in the following table. However, it should be noted that the Core Strategy can only allocate strategic sites for development and non-strategic smaller sites may need to be allocated through another Development Plan Document (DPD).

10.23 The delivery of new housing would also need to be phased in order to ensure development is evenly spread out over the period to 2026. In order to deliver the total requirement for the period 2011-2026 of 8,100 dwellings, the phasing would seek to ensure approximately 2,700 dwellings were delivered in each five year period after the adoption of the Core Strategy in 2011. This requires an assumption to be made about when new homes might be developed on the 'preferred option' sites and on the windfall sites and these are explained in the SHLAA and set out in the table below.

'Preferred Option' - the Green Sites

No. of Homes

2011-2016

No. of Homes

2016-2021

No. of Homes

2021-2026

Total No. of Homes

2011-2026

New homes on urban and rural windfall sites

275

550

1,275

2,100

Non-strategic urban brownfield sites (see SHLAA)

30

260

185

475

Land at Former Fords Foundry, Leamington

75

 

 

75

Land at Station Approach, Leamington

150

 

 

150

Land at Warwickshire College, Warwick New Road

 

 

300

300

Land South of Sydenham and east of Whitnash

200

 

 

200

Land at Woodside Farm, north of Harbury Lane, Whitnash

250

 

 

250

Land at Lower Heathcote Farm, south of Harbury Lane

450

1,050

1,000

2,500

Land west of Europa Way, Warwick

1,250

 

 

1,250

Land at Thickthorn, between Kenilworth and the A46

 

800

 

800

Total

2,680

2,660

2,760

8,100


Feedback - Preferred Housing Locations
Do you support or object to the following preferred locations of new housing?
(119) (i) Land at Former Ford Foundry, Leamington
(112) (ii) Land at Station Approach, Leamington
(84) (iii) Land at Warwickshire College, Leamington
(1145) (iv) Land south of Sydenham and east of Whitnash
(1148) (v) Land at Woodside Farm, north of Harbury Lane, Whitnash
(1216) (vi) Land at Lower Heathcote Farm, south of Harbury Lane
(756) (vii) Land west of Europa Way, Warwick
(180) (viii) Land at Thickthorn, Kenilworth
(303) (ix) Land at Kings Hill, south of Green Lane, Finham
Please explain your response when answering these questions.

10.24 It is important to note that the Council will annually monitor the delivery of new homes on all sites during the period to 2026. If new homes on windfall sites are built faster than predicted above (e.g. more brownfield sites in the urban area become available), then the Council would review its Core Strategy and potentially control the release of strategic greenfield land towards the end of the plan period in order to avoid too many new homes being built contrary to the regional and sub-regional strategy.

10.25 In addition to the above sites, and only if it can be demonstrated to be required through the Core Strategy for Coventry, the Preferred Option for meeting part of the RSS Phase Two Revision requirement for Coventry City that cannot be accommodated within its area would be the 'option' identified at land at Kings Hill, south of Green Lane, Finham. This is highlighted on the plan attached at Appendix Six. The phasing of this site should not prejudice the redevelopment of brownfield land within Coventry and will therefore be dependent upon the rate of housing development coming forward within the city.

10.26 If these sites are taken forward and allocated in the draft Core Strategy, or any other sites following this consultation, then further work will be undertaken on assessing what infrastructure will be required to enable sustainable communities to be developed without harming existing communities. The Council will be asking various organisations a number of questions, such as what transport improvements will be required, what new schools are needed, what health/community and leisure facilities should be included, what public open space and green spaces should be provided, and what benefits will the wider community receive from development. The responses will be pulled together into an Infrastructure Delivery Plan which will accompany the draft Core Strategy to show what improvements will be required, and when and how they will be delivered.

10.27 In addition, further work will also be undertaken on designing and masterplanning these areas to show which parts of the site might be developed for housing, where community and other uses might go, and what areas will be protected for public open space or for flood alleviation works. This work will feed into later stages of the Core Strategy and the detailed planning of the sites.

Preferred Options for the Mix of New Housing

10.28 The Core Strategy must include policies to ensure that new housing includes a mix of different types, sizes and tenures to meet the identified needs. This will help to ensure that new communities are mixed and balanced and people are able to move to more suitable accommodation within their existing neighbourhoods.

10.29 Recent housing market studies have revealed a demand for all types of housing in the District but, in particular, for small to medium family homes with gardens and, to a lesser extent, two bedroom flats. There is also a need for homes, of different types and price ranges, specifically designed to meet the needs of older people. In the rural areas, some villages have a shortage of small to medium sized homes suitable for people wishing to downsize from the family home or for young people looking for their first home.

10.30 Large housing sites are more able to accommodate a mix of housing, including housing for older people, due to their scale. It is also recognised that smaller urban sites may be constrained in the types of housing that can be built, for example in conversion schemes or small town centre locations.

10.31 One option would be for the Core Strategy to set out a desired mix of housing to be achieved on all sites reflecting the evidence of housing need in recent studies. However, the preferred option would be to only apply this approach to strategic sites where it is more feasible to accommodate a mix, and to apply the policy more flexibly on small urban sites.

Feedback - Preferred Option for Mix of Housing
(141) Do you support or object to the preferred option for securing a mix of new housing?
Please explain your response when answering this question.

Preferred Options for the Affordability of New Housing

10.32 In terms of the affordability of housing, Warwick District has the highest unmet need for affordable housing in the south of the region and this is a key issue for the District. The Core Strategy must include policies to ensure that affordable housing is provided as part of new housing developments.

10.33 The District's current policy for affordable housing is set out in the Local Plan and is based on up to date evidence of need. This policy requires development sites of 10 or more homes to provide 40% of the homes to be affordable. Affordability is defined using information about local incomes and house prices. In rural areas, the proportion of 40% is applied to development sites of 3 homes or more. This reflects the fact that housing development is rural areas is so constrained that sites tend to be very small. This affordable housing policy has yet to be tested since its adoption as the Council has operated a policy of restraint on new housing development during that time.

10.34 In terms of the options for the proportion of affordable housing to be secured from new developments, one option for the Core Strategy would be to carry forward the Local Plan requirement of 40% or alternatively, bearing in mind the severity of the affordability problems in the District, increase the proportion to 50%. Another option would be to lower the requirement to 30% given the current economic circumstances but to review this once the housing market was stronger.

10.35 In terms of the options for the size of site that triggers an affordable housing contribution, the existing thresholds of 10 dwellings in the urban areas and three in the rural areas are an option. However, an alternative option for the Council would be to seek financial contributions on sites below these thresholds. These contributions would then be used to support the provision of affordable housing on alternative sites.

10.36 The Preferred Option would be to increase the proportion of affordable housing on new development to 50% and lower the thresholds for affordable housing given the significance of the problem within the District. However, further evidence is required to test the viability of this approach and this will be undertaken prior to the Draft Core Strategy.

Feedback - Preferred Option for Affordable Homes
(154) Do you support or object to the preferred option for securing affordable homes?
Please explain your response when answering this question.

Preferred Options for Housing Density and the Effective Use of Land

10.37 The density of new housing is important because it is a reflection of the amount of land used in a development. Density may be determined by the type of site, its location and the types of homes which are built. A balance needs to be achieved between the efficient use of land and the provision of quality housing environments where family homes have gardens and where there is adequate provision for open space, parking and other amenities. Lower densities inevitably lead to more costly developments and a higher take up of greenfield land.

10.38 The use of density policies can ensure that higher density policies are achieved in more accessible locations, such as town centres, and that best use of land is achieved in greenfield developments. Additionally, in areas where the existing density is an important aspect of the character of an area, policies can help ensure that this character is protected.

10.39 The options within the Core Strategy are to establish a policy requiring higher densities across all sites, however, the preferred option would be to allow some flexibility by adopting a policy with a range of densities across the plan area.

10.40 The Core Strategy must also encourage the effective use of land by re-using previously-developed (brownfield) land for housing. The national annual target is that 60% of housing should be provided in this way. In the past 10 years this proportion has been achieved in the District. However, it has not been possible to identify large numbers of brownfield sites in a long term plan in this District because sites often come forward unexpectedly and do not stay vacant for long due to the strength of the housing market.

10.41 The only option for the Core Strategy is to include a windfall allowance within its housing land supply, for a proportion of development to come forward on brownfield land as opposed to identifying greenfield sites and to encourage and monitor progress in its delivery.

Feedback - Preferred Option for Housing Density
(128) Do you support or object to the preferred option for the density of new housing?
Please explain your response when answering this question.

Higher Levels of Housing Growth

10.42 National planning policy also requires local authorities to consider the implications of different levels of development taking place within the period of the Core Strategy. As noted earlier, the RSS Phase Two Revision is only emerging policy and has yet to be tested. This will take place during spring/summer 2009 at an Examination-in-Public. A number of participants at that Examination are suggesting the housing requirement for Warwick District should be higher than 10,800 for the period 2006-2026. These include the Government Office for the West Midlands who are recommending the housing requirement for Warwick District should be increased by 10,000 to 20,800 dwellings during this period.

10.43 The Council does not accept that it is appropriate or even possible to accommodate that number of dwellings within the District during that period, and it will be arguing this point very strongly at the Examination-in- Public. The higher level of housing growth would undermine the regional and sub-regional strategy's approach to urban renaissance of the major urban areas of the region. Furthermore, as shown within the SHLAA, there is insufficient suitable land to accommodate that level of housing unless land which is environmentally or physically constrained is developed.

10.44 Notwithstanding its position, the Council is required to consider the impact of the Government Office for the West Midlands recommendations for Warwick District in order to test their implications and to allow the public and other stakeholders to comment.

10.45 The Government Office for the West Midlands recommended the figure of an additional 10,000 dwellings based upon the work of Nathaniel Lichfield & Partners. This concluded that such a level of development would need to be met by two major 'urban extensions' of 5,000 dwellings around Warwick/Leamington, one of which could be to the north of Leamington. The amount of land required to accommodate a 5,000 dwelling urban extension, including all other supporting land uses such as open space, community facilities and employment land, is approximately 250 hectares or about one square mile (based upon an average density of 40 dwellings per hectare).

10.46 It is important to note that this suggestion is in addition to the land already identified within the Preferred Option and shown on the plans within Appendix Five and Six. It cannot and does not therefore form part of this Core Strategy. Additional development at this scale would have significant adverse implications for the District's towns and villages, the Green Belt, existing and proposed infrastructure. It is not possible for the Core Strategy to establish a single strategy that could accommodate such an increased range of housing provision, which would go beyond the usual level of flexibility expected by national planning policy.

10.47 The implications of higher housing numbers on the demand for additional employment land and retail floorspace to meet the increased population's needs are set out within the Employment Land Review and Retail and Leisure Study. The implications for the environment and infrastructure will vary depending on its location. Some of the potential adverse implications are described below:

  • significant loss (up to two square miles) of Green Belt land;
  • the coalescence of the urban areas with the surrounding villages, such as Old Milverton and Blackdown, Bishops Tachbrook, Radford Semele or Leek Wootton, and eroding of the gaps between the main urban areas, and between Kenilworth and Coventry;
  • development within areas of high landscape value, with potential significant adverse impacts on Historic Parks and Gardens, such as the Grade I registered Warwick Castle Park, the Grade 2* registered Kenilworth Castle Park, the Grade II historic park and garden at Guy's Cliffe, and the Grade II Registered Park and Garden associated with Mallory Court;
  • development within areas of ecological importance and ancient woodlands;
  • development within areas of flood risk; and,
  • significant infrastructure works, particularly in relation to roads including major highway alterations to the M40 and A46 junctions, and the road network through the historic town centres of Warwick, Leamington Spa and Kenilworth where such works could have a significant adverse effect on the character of the designated Conservation Areas.

10.48 The Council does not therefore support higher levels of housing growth as suggested by the Government Office for the West Midlands. The purpose of putting this information in the public domain through the Preferred Options consultation is to enable all interested, and potentially affected, parties to be aware of the suggestion that has been made in order to enable them to respond and comment accordingly.

Feedback - Higher Levels of Housing Growth
(233) Do you support or object to levels of housing growth higher than those proposed by the Preferred Options?
Please explain your response when answering this question.

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