Object

Representation ID: 65516

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

Legally compliant? No

Sound? No

Duty to co-operate? No

There is no explanation as to how the figure from the SHMA has been translated from an objectively assessed need ('Policy Off' figure) for Warwick to an overall housing requirement ('Policy On' figure).

A two stage process should be carried out: 1) use of SHMA toi identify OAN. 2) take account of other considerations to arrive at a final housing figure (e.g DTC, SHLAA). This can then give a sound figure for the Plan.

The Plan has only looked at stage one and is therefore a "policy off" figure and is unsound.

The plan proposes a high level of windfall housing (19.3% or 138 dpa). Whilst a degree of windfalls are allowed, this should only be if there is compelling evidence.

The 2014 report on 5 year supply has not been published and the 2013 report makes no allowance for non-implementation.

There is therefore not enogh evidence to demonstrate how this approach can be achieved, and the reliance on windfall sites in this way risks a serious undersupply of housing.