Object

Representation ID: 60193

Received: 29/07/2013

Respondent: Gladman Developments

The interim housing requirement being progressed through the RDS is also arbitrarily low.

There is no justification for deviating from the housing projections presented in the Council's most recent 2012 Economic and Demographic Forecasts Study. Further the Council may be ignoring the current shortfall of housing against their Regional Strategy requirements.

This historic backlog cannot just be written off.

The NPPF is clear that local planning authorities should identify and meet their full objectively assessed housing needs, informed by a SHMA that has been prepared with neighbouring authorities where housing market areas cross administrative boundaries.

The housing requirement and Core Strategy cannot be found sound if they are inconsistent with this requirement.

Until the joint SHMA has been prepared the Council cannot know what their objectively assessed housing requirement should be. Relying on an interim figure in the meantime is considered unsound.


Notwithstanding the above issues, whilst recognising that the interim requirement is an increase on the Council's Regional Strategy requirement Gladman further question the process for identifying this target and submit that it is arbitrarily low.

The 2012 Warwick SHMA set out a range of projections for future housing requirements in the District.

In December 2012 this work was updated by the Warwick and Coventry Economic and Demographic Forecasts Study to take account of a now approved major technology and business park adjacent to Coventry airport, updated economic forecasts and the 2011 Census. Housing projections from both studies are set out in Table 1 in the representation.


The Council's interim requirement does not align to any of the projections presented in its evidence.

Whilst recognising that it is an increase on the Council's Regional Strategy requirements it is noticeably lower than the economic-based housing projections prepared for the Economic and Demographic Forecasts Study, including the revised baseline economic scenario.

It appears to be predicated on 2011 ONS household and population projections and an assumed GVA rate of 2.4%.

There is no justification for the Council's decision to ignore its objectively assessed housing needs and it has not demonstrated that there would be any adverse impacts of delivering a higher housing requirement to support its full economic potential.

Housing Backlog

The under supply of housing against the RSS target of 550 dpa in Warwick District equates to a shortfall of 1,281 units for the period 2006/07-2010/11.

It is not clear from the Council's evidence or RDS whether this shortfall has been taken into account when proposing the interim housing requirement, which has a base date of 2011.

Unmet need will not just disappear and therefore it is fundamental that it is taken into account in the targets moving forwards. It cannot just be written off.

The failure to include past shortfall in housing delivery in the proposed housing target should be considered unsound.

The delivery of any shortfall should be made up as soon as possible, and in the absence of evidence to suggest a longer timescale, the shortfall should be caught up within the first 5 years of the plan.

Duty to Co-operate

Until a jointly prepared SHMA for Warwick, Coventry, Nuneaton and Bedworth has been published the Council cannot fulfil its Duty to Co-Operate requirement.

This may reveal a requirement for the Council to meet the
housing needs of these adjacent authorities, and vice versa.
The importance of complying with the Duty to Co-operate is clear from the preliminary hearings on the Coventry City Core Strategy held in December 2012.