Object

Representation ID: 57023

Received: 29/07/2013

Respondent: Mr Armitage, Mrs Grimes and Richborough Estates

Agent: Strutt & Parker

Paragraphs 4.1.2 to 4.1.10 in the RDS set out the Council's justification for the proposed interim level of housing growth, although no credible explanation can be found.

Nor has the Council adequately demonstrated why the higher housing requirement (e.g. 14,300 dwellings) would not be appropriate. It is accepted that the evidence base is in the process of being updated and clearly the findings of the Joint SHMA will be critical to the soundness of the Plan.

Nevertheless departures from 'objectively assessed' evidence need to be clearly and concisely justified.

Objects to the proposed level of housing growth as set out within the RDS as it does not provide an appropriate level of growth in line with the evidence base underpinning the RDS. For the RDS to be found sound, it must first be positively prepared. This means that the Plan must meet objectively assessed development requirements (paragraph 182 of the Framework). Presently, there is no credible evidence base to justify the interim level of housing growth.

As such the Plan has not been positively prepared, it cannot be justified or effective and neither is it consistent with national policy.

With the abolition of the Regional Spatial Strategies and the withdrawal of Coventry's 2012 Core Strategy, the planning policy context has changed substantially.

New cross boundary issues will arise specifically in respect of housing numbers. Based on the evidence currently available to both Warwick and Coventry, it is inevitable that Warwick will be required to meet a proportion of Coventry's housing need.

Seeking to meet such need is part of the soundness test of a Plan being positively prepared.

The evidence base underpinning the RDS indicates that Warwick will experience a growth in employment of 9,500 over the identified Plan period with the Gateway development scheme providing a further opportunity to boost workplace employment in Warwick District - delivering up to 9,500 additional jobs within the District's boundaries.

Consequentially, the impact of this means that the objectively assessed need currently underpinning the NLP equates to 726 - 772 dwellings per annum.

Furthermore, the 2012 SHMA completed by GL Hearn on behalf of the Council, identifies a net affordable housing need within the District of 698 units per annum - over and above the need for new market housing.

Whilst it is acknowledged that this is significantly above both likely and/or realistic levels of housing delivery, conclusions can be drawn that the Council has an acute need for more affordable housing.

It is clearly evident from the evidence base that the level of housing growth set out within the RDS falls short of the objectively assessed need for both open market and affordable housing.