Object

Publication Draft

Representation ID: 65267

Received: 25/06/2014

Respondent: A C Lloyd Homes Ltd

Agent: Delta Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

A C Lloyd Homes object to the proposed level of housing growth of 12,860 new homes between 2011 and 2029. It is considered that the plan period used should be 2011 to 2031. The appropriate level of housing should be increased by at least 1,428 dwellings to provide for the additional 2 years and the plan period should extend to 2031.

The current approach to meeting the housing requirement for the District does not take into consideration any shortfall of housing within the sub-regional housing market area or within adjoining housing market areas.

Full text:

A C Lloyd Homes object to the proposed level of housing growth of 12,860 new homes between 2011 and 2029. As stated in our objection to Paragraph 1.29, it is considered that the plan period used should be 2011 to 2031. The current approach is considered 'unsound' as it does not conform with the provisions of NPPF which requires Plans to cover an appropriate time period, preferably a 15 year time horizon, but which takes account of longer term requirements. Since the plan is unlikely to be adopted before 2015 this period appears too short. This would bring it into line with the evidence base in the Coventry and Warwickshire Joint SHMA. Accordingly, it is considered that the appropriate level of housing should be increased by at least 1,428 dwellings to provide for the additional 2 years and the plan period should extend to 2031.

A further concern is that the current approach to meeting the housing requirement for the District does not take into consideration any shortfall of housing within the sub-regional housing market area (in particular in Coventry) or within adjoining housing market areas (in particular Birmingham).

It is acknowledged that this issue is already recognised at paragraph 1.24 of the Plan albeit it states that Warwick is unlikely to have to directly accommodate any shortfall from Birmingham. Objection is raised to this statement on the basis it is premature and considered unlikely given the scale of the anticipated shortfall in Birmingham and the good transport links between the two areas. Furthermore since the interim findings of the Greater Birmingham and Solihull LEP (GBSLEP) Strategic Housing Needs Study is due for publication in July 2014, it is clear that the implications from that Plan may well start to become apparent within a sufficiently near timescale as to be considered as part of the evidence base against which to establish the overall objectively assessed need for Warwick District.