Object

Representation ID: 63511

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

The Council has indicated that the 12,300 figure may change once the joint SHMA is published in August 2013. Given the evidence and that this is an interim figure, it has to be accepted that the figure will change and 12,300 is therefore not sufficiently robust. This is particular the case as there is no cross boundary element. Cross boundary arrangements will need to be implemented to facilitate the needs of Coventry in Warwick. 12,300 is evidence that WDC is unable to fix a definitive figure for its strategy given that it will have to accept addition need from Coventry. RPS therefore supports the increase in housing from the previous version of the plan to this Preferred Options document. However 12,300 is still insufficient. To meet Warwick's needs, let alone assisting with cross-boundary requirements.

The RDS as presented is currently not sound, justified or positively prepared based on the basis that 12,300 is only an interim figure. It is not clear how the evidence has actually informed or justified the final 12,300 figure.

The NPPF clearly sets out in paragraph 159 that LPA's should prepare a SHMA to assess their full housing needs and work with neighbouring authorities where housing markets cross administrative boundaries. The SHMA will also assess housing needs, population changes and migration and demographic changes. It is therefore clear that the need for a SHMA that addresses the cross boundary issues is required. The SHMA guidance also sets out that SHMA should include local economic forecasting as part of the housing needs evidence base.

Due to the cross boundary needs of Coventry it is vital that Warwick's own Objectively Assessed Need for market and affordable housing is established in accordance with paragraph 47 of the NPPF before any need associated with Coventry is considered. In this context, the Council has commissioned a number of studies including an updated SHMA which is due to be published in August 2013. However, until this is available the Council has based the interim figure on evidence already in the public domain. This presumably comprises principally the 2012 SHMA and the 2012 Economic and Demographic Forecasts Study (EDFS). These have been informed by a series of population and household projection, including some of the most recent 2011 census data.