Object

Representation ID: 55336

Received: 28/07/2013

Respondent: Graham Parker

The process for assessing the housing target is deeply flawed and that the housing target set by the draft Strategy in para 4.1.10 and RDS2 will therefore be inadequate and will lead to the Plan being found unsound.

1-despite best practice and government advice, the SHMA only covers a part of the identified Strategic Housing Management Area (see paragraph 10.6 of the SHMA). Thus it does not assess the "full, objectively assessed needs for market and affordable housing in the housing market area" as required by paragraph 47 of the NPPF and ignores the duty to cooperate imposed on this Local Plan by Section 110 of the Localism Act 2011.

2- the Strategy is based on out of date household and population projections. The reference to the 2011 ONS Projections in paragraph 4.1.5 is cursory and the implications of these projections clearly have not been absorbed into the strategy.

3- housing needs are based on much more than simple household projections, as is set out in the SHMA itself.

4-the SHMA itself makes massive assumptions about in-commuting, which have significant implications both for Warwick and for nearby authorities. These assumptions are unsupported by evidence.

5-the absence of a 5 year supply of deliverable housing land would not, in itself, render the plan 'unsound' the Inspector will clearly have in mind that it is sensible to ensure that the plan begins on a firm footing, which this Strategy does not.

In addition to underestimating the district's overall housing needs throughout the plan period, no account has been taken of the undersupply from the previous period . Thus:

* Even with the lower WMRSP2 requirement of 550 dpa, given the shortfall from the previous period and the fact that Warwick is certainly a 20% buffer authority, the requirement in the first 5 years is likely to be some 900 dpa.

* If one takes the Strategy's interim assumption of 680 dpa for the whole plan period,
the requirement in the first 5 years is likely to be in the order of 1100 dpa, and this is
still without using a proper analysis of need, or an up to date assessment.

* As it stands, the Strategy is clearly incapable of providing sufficient deliverable sites in the first five years of the plan period.


Until all of these matters are demonstrated, the Strategy is unsound in all four of the
required ways set out in the NPPF:

* It is not based on objectively-assessed development requirements, including unmet
requirements from either neighbouring authorities or shortfalls of delivery in recent
years. It is not, therefore 'positively prepared'.

* It has not been demonstrated to be the most appropriate strategy, when considered
against the reasonable alternatives, based on proportionate evidence. It is not,
therefore, 'justified'.

* It is not demonstrated to be deliverable and is not based on effective joint working on
cross-boundary strategic priorities. It is not, therefore,. 'effective'.

* It does not enable the delivery of sustainable development in accordance with the
policies in the Framework - in this case, specifically, sustainable development and
Green Belt policies. It is not, therefore, consistent with national policy


Objects to the level of housing (12,300) said to be required in the plan period which is likely to be a severe underestimate and, if pursued, the plan would be materially unsound.

Also objects to the lack of suitable, sustainable and deliverable land proposed to meet even this severely under-estimated need, meaning that there is in fact no plan to meet their need, making the plan further materially unsound.


Notes that the local planning authority itself only refers to this as an 'Interim' conclusion and that it will be revised following a re-evaluation of the housing requirements taking into account the latest ONS projections and the S110 duty to co-operate.

Questions why:
* The Council did not heed the warnings given at the earlier Preferred Option stage (specifically about the faults in the SHMA, and the duty to co-operate) rather than waiting for the Coventry Inspector's instruction.

* The RDS has been published in its current form rather than waiting amendments to the housing requirement.