We support the Council's intention to plan for the full Objectively Assessed Housing Need in the District, as set out in Policy DS2. However, we believe that there is an error in the number reported.

The supporting text refers to the Joint Coventry and Warwickshire Strategic Housing Market Assessment 2013 (SHMA) which objectively assessed the future housing needs of the Housing Market Area and the six local authority areas within it. The supporting text states that the Objectively Assessed Need in Warwick District is 12,860 new homes between 2011 and 2029.

The SHMA recommends at Table 97: Overall Assessed Need for Housing (per annum 2011-2031) that the Objectively Assessed Need for Warwick District is 720 per annum, which over the 18 years of the plan equates to a total of 12,960 dwellings. It is not clear why Warwick are planning to under-provide by 100 dwellings with no justification presented, particularly as policy DS7 Meeting the Housing Requirement, allocates sites for 12,964 new homes over the plan period.

It has widely been reported that the sub-national population projections (SNPP) published in May 2014 suggest a lower level of growth than that contained in the consultation document.

However, the figures contained in the Joint Coventry and Warwickshire Strategic Housing Market Assessment (2013) still represent the most up-to-date evidence of the district's objectively assessed housing need. The SNPP numbers represent the starting point for assessing housing need, but the SHMA represents the most up-to-date assessment of objectively assessed need.
The NPPF requires local planning authorities to "boost significantly the supply of housing" and "use their evidence base to ensure that their Local Plan meets the full objectively assessed needs for market and affordable housing" (paragraph 47). It also requires local planning authorities to prepare a SHMA to assess their full housing needs which meets household and population projections (paragraph 159).
The NPPG is clear (Paragraph: 015 Reference ID: 2a-015-20140306) that "Household projections published by the Department for Communities and Local Government should provide the starting point estimate of overall housing need." (my emphasis)

It goes on to explain further:
"The household projections are trend based, ie they provide the household levels and structures that would result if the assumptions based on previous demographic trends in the population and rates of household formation were to be realised in practice. They do not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour.
The household projection-based estimate of housing need may require adjustment to reflect factors affecting local demography and household formation rates which are not captured in past trends. For example, formation rates may have been suppressed historically by under-supply and worsening affordability of housing. The assessment will therefore need to reflect the consequences of past under delivery of housing. As household projections do not reflect unmet housing need, local planning authorities should take a view based on available evidence of the extent to which household formation rates are or have been constrained by supply."

Therefore, it is clear that the newly published SNPP numbers are the raw data, and the starting point for assessing the objectively assessed need whereas the Joint SHMA makes adjustments to take account of factors affecting local demography or household formation rates, including supply constraints.

To reduce the housing requirement below the level demonstrated by the evidence base on the basis of the new SNPP figures would render the Plan unsound as it would not comply with paragraph 47 of the NPPF.