Object

Representation ID: 66193

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

RPS is of the opinion that the Housing Trajectory is unsound in respect of windfall allowances. The allowance is clearly overestimated and unrealistic. It makes allowance for student accommodation which is unsound.

The NPPG states that student accommodation can be included in the housing requirement "based upon the accommodation it releases from the housing market. Notwithstanding, local authorities should take steps to avoid double-counting". The authority has clearly not understood the nature of the guidance.

More fundamentally the authority can only include student accommodation "based upon the accommodation it releases from the housing market". To release a dwelling unit form the housing market it requires the dwelling unit to be firstly occupied by Students, that will then move back to the new student accommodation and thus release the dwelling unit. No evidence is provided that this is the case. In fact, the converse is true in that university accommodation is typically for overseas and first year students, which will not exist in the housing market already. Therefore no release of dwelling units occurs. In fact, the university (para 10.78 of the SHMA) is seeking to expand its use of private rented properties in Warwick, Coventry and Leamington, not reduce it.