Object

Representation ID: 65695

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy sets out requirement for 12,860 homes over Plan period 2011-2029, equating to 720 dwellings per annum.
Proposed housing requirements drawn from 2014 Coventry and Warwickshire Joint SHMA. The Joint SHMA covers local authority areas of Rugby, Coventry, Warwick, North Warwickshire, Nuneaton and Bedworth and Stratford-on-Avon and identifies a mid-point of need of 3,750 dpa based on 2011 and 2008 headship rates as representing a reasonable level of provision on which to base the housing needs of the HMA. Preparation of the Joint SHMA comes after the withdrawal of Coventry's Core Strategy in 2012, particularly in light of lack of consistent/joint approach to meeting housing needs of the area and failure to discharge the authority's Duty to Cooperate.
Reviewing the housing requirements in the Local Plan and the findings of the joint SHMA, submit that proposed WDLP - Publication Draft Consultation housing requirements set out in Policy DS6 are too low to meet housing needs of the district and are not based on robust evidence. Whilst welcoming the SHMA, we submit that the assessment of the housing needs it provides for the HMA and the district underestimates level of housing required to support future demographic needs and economic potential. Whilst SHMA recognises the need to address market signals, query whether these have been properly factored into future assessment of housing needs, whilst noting proposed housing needs for HMA will be insufficient to meet affordable housing for the area as a whole. Strongly submit that the Council has underestimated future level of housing that must be provided.
Aware of independent objective assessment of housing needs for Coventry and Warwickshire HMA. Incorporating critique of Joint SHMA, the Coventry and Warwickshire Sub-Regional Housing Study finds that to meet the full objectively assessed needs of the HMA and Warwick District, an overall housing requirement of at least 5,100 dpa, based on an economic-led modelling scenario linked to economic forecasts used in the Coventry and Warwickshire LEP Strategic Economic Plan. Consultants find this level of housing growth would enable demographic needs to be met, forecasted ecomic growth to be accommodated, sufficient affordable housing to be supplied and make a significant contribution towards addressing adverse market signals in the area. Translated into requirements for individual authorities in the HMA, this would require a housing requirement of 18,000 dwellings to be provided through the Warwick LP, equating to 900 dpa.
To be found sound at Examination the Warwick District LP must be based on effective joint working on cross boundary strategic issues. In this regard the LP and Coventry and Warwickshire SHMA discuss and recognise the issue of cross-boundary housing needs within the HMA and unmet requirements arising from neighbouring authority areas. Policy DS20 specifically describes the work that has taken place between the Council and other authorities within the Coventry and Warwickshire HMA to agree a process for addressing unmet needs from one or more of the HMA authorities should they arise. Outside of the HMA, the LP also identifies that there may be an issue of unmet housing needs arising from the Greater Birmingham area.
Whilst welcoming the Council's willingness to work with its neighbouring authorities to address unmet housing needs, submit that the actions proposed by the LP and the Coventry and Warwickshire Joint Committee are not sufficient. There is a long-standing and existing acknowledgement that Coventry will be unable to meet the housing needs in its own administrative area, with a report to the Coventry and Warwickshire Joint Committee on 20th March 2014 clearly stating that "there is a significant risk that Coventry City Council will not be able to accommodate 23,600 dwellings (1,180 dpa) within the City boundary". The submission draft of Birmingham City Council's LDP also identifies an initial shortfall of 29,000 dwellings against its full objectively assessed needs. There is therefore a clear requirement for effective working to be undertaken to address these needs now, and for a positive response through the LP to meet them.
In light of the need to provide for a higher housing requirement in the district, submit that Policy DS6 is not positively prepared as it fails to propose a sufficient level of housing to meet Warwick's needs and those of it surrounding neighbours. LP not justified as it is not supported by robust assessment of full objectively assessed needs for the district, and is not effective as it fails to adequately address cross-boundary housing issues. In a number of instances Council's approach is not consistent with the requirements of the Framework.To be considered sound, submit that proposed housing requirements set out in the LP should be increased, at least being consistent with the assessment of the district's housing needs prepared by consultants. To address unmet housing needs already acknowledged to exist in relation to Coventry and Birmingham there is need for action to address these unmet needs now, rather than deferring this to future work or a review of the Local Plan.
In light of our concerns over the adequacy of the Council's proposed housing requirement, reserve the right to undertake an independent objective assessment of the authority's housing needs, consistent with the requirements of the Framework and the PPG on Housing and Economic Development Needs Assessments, and submit this to the Local Plan Examination.