Object

Representation ID: 63552

Received: 20/01/2014

Respondent: Trustees of the F S Johnson 78NEL

Agent: Tyler-Parkes Partnership

We raise OBJECTION to the 'Warwick Local Plan Village Housing Options and Settlement Boundaries' DPD on the grounds that it is not 'sound' and it fails to meet the requirements of the National Planning Policy Framework (Framework) or fully meet the legal Duty to Cooperate.
It is apparent that the approach taken to housing land allocations preferred options within the document is not wholly consistent with the Framework which, amongst other matters, seeks to: provide certainty by planning for the long term; locate development in the most sustainable locations; protect the future viability of settlements; ensure a variety of housing is provided to meet identified needs; ensure a 5 year housing land supply is maintained; alter Green Belt boundaries in exceptional circumstances (such as required to meet housing need) to ensure they are capable of enduring beyond the Plan period; and ensure the legal Duty to Cooperate has been satisfied. the DPD is not sound because it fails to - provide certainty over the long term; identify sufficient land within or adjacent to the Villages to meet the housing requirement over the plan period;include sufficient deliverable sites to respond to a 20% buffer in the 5 year housing land supply; fails to fully consider the implications on Warwick District of the potential housing land shortfall in the Housing Market Area as required under the Duty to Cooperate; offer developers sufficient deliverable housing land choices to ensure a rolling 5 year housing land supply is maintained; alter Green Belt boundaries to meet the identified growth requirement in line with the findings of the Settlement Hierarchy and the Local Plan Revised Development Strategy proposed policies; ensure that Green Belt boundaries are capable of enduring beyond the plan period through the identification of 'areas of development restraint' or 'safeguarded land' including in/adjacent to the most sustainable Villages; identify a quantum of housing land allocations appropriate to the scale and sustainability of settlements as evidenced by the Council's own research; provide sound, accurate evidence to justify discounting the site for housing development; and remove part of our client's sustainable and deliverable land from the Green Belt, include it within the Settlement Boundary and allocate it for residential.

Warwick District therefore had a significant annual housing shortfall in delivery, following cessation of the housing moratorium at the end of 2009. This we believe is a 'persistent' annual under delivery when measured against the annual housing requirement. Once a 'persistent under delivery' has been proven, which we contend it has, the 5 year housing land requirement would rise by a 20% buffer rather than a 5% buffer. The 'Village Housing Options and Settlement Boundaries Consultation' DPD is therefore unsound because it does not identify sufficient preferred housing sites to contribute towards meeting the need for a five year annual housing target of between 1040 and 1102 units, which includes a 20% buffer. It fails to address the need to ensure sufficient deliverable sites are identified and available to be developed in the 5 year timeframe. Without additional sustainable sites being identified in the most sustainable villages, there is a risk that the emerging housing policies will not be considered up-to-date.