Object

Publication Draft

Representation ID: 65468

Received: 27/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The housing target in policy DS6 should be clearly identified as a minimum to enable the full objectively assessed needs to be met.
We strongly support Strategic Policy DS2 which provides a clear commitment to providing "in full for the Objectively Assessed Housing Need". The Joint SHMA 2013 sets out the basis for establishing the District's objectively assessed affordable housing need. It identifies a need for 268 new affordable homes each year between 2013 and 2031. However this figure of 268 has been calculated based on an assumed period of 18 years over which the backlog of affordable housing need should be met.

Following national guidance to reduce the affoirdable housing reducing the backlog to 5 years, the affordable housing requirement increases from 35 to 127 affordable dwellings per annum. The overall affordable housing need therefore increases from 268 to 360 affordable dwelling per annum.

the zero migration scenario used in the 2013 SHMA is likely to have underestimated the need for affordable housing. In addition the 2012
SHMA identified a need for 698 affordable dwellings per annum in the District. This is a significantly higher level of need, identified only the year before the Joint SHMA.
As such we would recommend that the overall housing target as set out in policy DS6 is stated as a minimum which could be exceeded.

In the light of an average performance of just 14.4% affordable housing delivery over this period the realism of achieving 40% must be seriously questioned. This emphasises that if sufficient numbers of affordable dwellings are to be delivered then correspondingly sufficient numbers of market dwellings must be delivered too.
Local Plan provides for 12,860 new homes between 2011 and 2029, which equates to approximately 714 dwellings per annum. This provision figure is over 100 dwellings less than what the Joint SHMA states is the objectively assessed housing target for the District based on an annual housing need of 720 homes over the 20 year period 2011 to 2031.

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