Object

Representation ID: 66307

Received: 03/07/2014

Respondent: Patricia Hollis

Legally compliant? No

Sound? No

Duty to co-operate? Yes

The overall forecast of housing need of 12900 is considered to be exaggerated. The ONS estimates have been revised downwards and suggest only 8,100 houses are needed to meet natural increase and inward migration to Warwick District. The SHMA suggests that occupancy rates of houses will fall significantly from 2.2. Such a decrease is unrealistic and the plan is therefore seeking to justify the provision of more houses than will actually be needed to house the target population.
There is already more than a five year supply of land ready for development. As ONS estimates have dropped less houses will be needed to meet the requirement for 5 years supply. Campaign groups have claimed that there is already a five year supply; the revised ONS estimates would appear to reinforce this position.
Population projections underpin the plan and are fundamental to it being properly justified/sound. The GL Hearn projections used in the SHMA for Coventry and Warwickshire are used as the basis for the Plan but are now discredited by the may ONS population figures issued in May 2014.
The recent ONS figures are much lower than those used in the SHMA 15,313 rather 21,472, a fall of 6,159 persons or a 28.7% reduction. This is very significant in that it changes the numbers of dwellings that will be necessary; the amount of infrastructure needed to support the housing / population and reduces the amount of Greenfield needed to be taken for new allocations.
The reduction in population and required housing will also improve the 5 year housing supply position.
It is considered that the SHMA underestimates the future housing occupancy rate in the district (see statistics in full submission). This alongside the potential for minor density adjustments can also have an impact on the amount of housing required in Warwick District and could lower the numbers significantly.
Research undertaken by local campaign groups (supported by respected University of Warwick economists), shows conclusively that maintaining a housing target of 12900 by 2028 cannot be justified on the basis of the latest figures ( see power point slides in full submission).
A decision to continue to work to the Council's current housing target can only be based on the Leadership of Warwick District Council being determined to " go for growth" in the face of the communities wish for a plan that would do no more than meet the needs of natural growth with a modest allowance for inward migration.
To conclude / summarise
*Warwick's population projection is now 28.7% less than the figures used to formulate the consultation draft local plan. The Plan is therefore unsound based on incorrect/ inadequate data.
*All the other authorities in the Housing Market area are also showing similar reductions in their population projections, including Coventry.
*The method by which population is converted into the numbers of dwellings required needs better determination by calculation, using the known housing type and size to be included in the plan.
*The lower housing target will require the list of sites to be included in the plan to be reduced. In sustainability terms this will imply brownfield sites being put first and only including Greenfield where essential.
*To delay a revision of the 5 year housing supply calculation / requirement in light of the new evidence of a much lower need for housing would be neglectful.
*Dependent matters such as infrastructure needs and costs will then need to be matched to the new lower target.