Object

Representation ID: 60177

Received: 28/07/2013

Respondent: Crest Strategic Projects

Agent: d2planning

Objects to supply of housing sites identified in Table 1.

The recent appeal decision on land south of St Fremund Way, Whitnash Leamington Spa identified that the Council could only demonstrate a 2.6 year supply of housing land (May
2013).

Table 1 does not make any provision for a 5% or 20% buffer as required by paragraph 47 of NPPF.

Given the Leamington Spa appeal decision it would appear that the Council has consistently underperformed in its housing delivery and accordingly there should be a 20%
buffer applied.

There is no reference within this policy or the supporting text to the Council consistently underperforming in meeting its housing needs. Furthermore, paragraph 47 of NPPF states that identified sites should be deliverable.

It is unclear how the Council has arrived at its 300 small urban SHLAA sites as being deliverable since these sites usually exhibit complex ownership and assembly issues.

It is unclear whether this level of development can be achieved for these sites.

In addition there appears to be 'no compelling evidence' to justify the proposed level of windfall, as required by paragraph 48 of NPPF.

Recommendation
Reassess the supply of housing sites and identify more deliverable sites.