Object

Representation ID: 56595

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

Supports the increase in housing from the 10,800 dwellings in the previous version of the plan to this Preferred Options consultation document. However, the evidence illustrates that 12,300 dwellings is still insufficient to meet Warwick's own housing needs, let alone assisting with cross-boundary development requirements.

The extensive evidence gathering and scenario testing by the Council to establish a housing and employment figure has not been used or applied consistently.

The 12,300 figure is not justified on GVA terms, nor is it justified through the economic or demographic evidence available in the Economic or Demographic Forecasting Study.

The 12,300 figure will also not support the 10,200 jobs being planned for in accordance with figure 42 of the Councils forecasting study.

It is expected that the 2013 joint SHMA will provide a greater degree of clarity on the housing need for Warwick (including cross boundary need) but in the absence of this, the figure needs to be reflective of the evidence available.

It is also noted that the Inspector for the [Coventry] Core Strategy has indicated that there is a need for an up to date SHMA in order to have effective and robust cross boundary evidence of cooperation. On this basis the figure should be reflective of the economic potential of the district based upon the influence of the Gateway Development and high levels of GVA than 2.5%.

This should therefore be considerably higher than the 13,900 dwellings (figure 42). The justification for this is:

* The authority is planning to provide some 10,200 additional jobs over the plan period which is even higher than the 9,900 associated with 13,900 dwellings RPS recommends is the minimum to be considered ;

* GVA forecasts are predicated to in the range of 2.9% and not 2.4%;

* GVA from the Gateway Development is expected to push GVA up to at least 3%

* The Gateway site already now has planning consent (subject to S106) and will have an impact on the district's requirements including the provision of some 10,000 new jobs;

* The needs of Coventry have not been considered and will need to be taken into account in addition to Warwick's needs;

*The demographic study has used 2011 census household size figures and forecast them across the whole plan period. This is unlikely to occur and trends akin to the 2008 projections or close to them are accepted by many as likely to occur

The 2012 Strategic Housing Land Availability Assessment (SHLAA) inappropriately excludes that site at Baginton. Therefore, it is evident that a greater number of dwellings than the interim level proposed, can be delivered within the District to contribute towards housing needs.

Warwick District Council should work with Coventry to assist in providing a proportion of Coventry's housing requirement in accordance with NPPF requirements.