Object

Representation ID: 60230

Received: 27/07/2013

Respondent: Gallagher Estates

Agent: Pegasus Group

The recognition that the quantum of development set out in RDS1 is interim (emphasis supplied) only is welcomed.

This is on the basis that the Authority, in proposing 12,300 dwellings, is at risk of under providing for arising need and failing to boost significantly the supply of housing contrary to the provisions of the NPPF.

The Authority must take on board any implications arising out of the Joint SHMA work.

Additional concerns about the interim figure are:

They are based on the 2011 interim sub national population projections. They assume a continuation of the 2010 based projections in fertility, mortality and migration. The 2011 projections indicate that in the period 2011 to 2021 there will be an increase of 625 households per year.

The most recent household projections that go beyond 2021 are the CLG based 2008 based household projections. These projections suggested the need for the provision of 15,500 households over the period 2011 to 2029. This is equivalent to 861 dwellings per annum.

The main reason for the difference between the 2008 and 2011 based projections is that the 2011 based projections show a slower growth in households compared to the 2008 projections. It is not, though, likely that this reduced household formation rate will continue into the future as economic conditions improve, thus beyond 2021 it would be reasonable to assume that household formation rates will increase and there will be an increased growth again beyond 2021.

This is especially the case in a district such as Warwick where the housing market will be more robust than elsewhere in the West Midlands.

The likelihood is therefore that the figure of 625 dwellings per annum, which is predicated on the existing conditions assumed in the 2011 projections continuing, will increase as households begin to form more readily following an improvement in their economic circumstances.

It is also important to recognise that household projections do not equal dwellings required. In order to arrive at a figure for dwellings required there is a need to add an allowance to deal with unmet need or backlog (concealed households and reduction in sharing households), take account of second homes and also add a figure for vacancies.

This accords with the requirement in the NPPF to address the need for all types of housing and also to cater for housing demand.

[In this context], the Warwick District Housing Market Assessment (HMA) of March 2012 is instructive and demonstrates that, as of 2012 there was an unmet net affordable housing need of 1,144 households.

These need to be added to the projection as does a suitable allowance for second homes and vacancies.

When this process is undertaken it is likely to direct the Authority to a figure in excess of the 11,500 new homes proposed at paragraph 4.1.5.

The Authority has also produced other evidence, including the Economic and Demographic Forecasts Study (December 2012) which has identified a need for additional homes ranging from 13,300 and 13,800 between 2011 and 2029.

Policy RDS2 sets out how the proposed interim housing requirement is proposed to be met., and includes a large windfall allowance of 2,800 dwellings.

Remain unconvinced that such a windfall allowance is justified in terms of paragraph 49 of the NPPF and have concerns that the Authority will be unable to demonstrate a supply of 12,300 dwellings if this approach to windfall development is to persist.