Object

Representation ID: 66465

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Alongside dwellings already completed and comitted 393 dwellings are expected to come forward from small urban sites and 269 homes from the consolidation of existing employment areas. Significant proportion of future housing needs are proposed to be met through sites allocated through the LP, whilst a windfall allowance of 2,485 dwellings for Plan period is also identified.
Submit that there is need to identify further housing sites in Warwick, over and above those already identified through LP, consistent with need to meet a higher housing requirement to meet the authority's full objectively assessed needs. If Council cannot demonstrate sufficient supply of deliverable/developable housing sites to meet authority's housing needs over the Plan period, the LP cannot be considered effective.
Council cannot currently demonstrate five year housing land supply. As shown in the Council's most recent Five Year Housing Land Supply Assessment report published in July 2013, the Council could only demonstrate a 2.8 year supply against previous emerging LP target of 683 dpa. Whilst LP Housing Trajectory paper shows that more commitments have since come forward, based on making up the delivery that has already occurred since the start of the LP period over the next five years and factoring in a 20% buffer for persistent under-delivery,question whether Council will not be able to demonstrate a five-year supply against its proposed requirement going forward. If sites proposed to be allocated through the LP are taken into consideration, this is still likely to be the case.
Council's strategy heavily reliant on delivery of three large SUEs on Land West of Europa Way, Land South of Harbury Lane and East of Kenilworth. Collectively these are anticipated to deliver 3,395 dwellings, representing 54% of the sites to be allocated through the LP. Whilst supporting general principle of SUEs and their sustainability benefits, submit that sites can often be slow coming forward, delivering housing at slower rate than anticipated and failing to deliver level of home envisaged. Council should ensure that it has allowed for sufficient contingency in LP housing supply, providing flexibility for sites that do not come forward as planned.
Whilst recognising ability for local authorities to make allowance for windfall sites in their housing land supply, we remind the Council that it must ensure that its windfall assumptions are appropriately justified and based on a robust understanding of how windfall sites are likely to continue to come forward, alongside other identified commitments and housing allocations.
Conclusions on Soundness
Submit that in its current form the LP is not effective, as it fails to identify sufficient deliverable/developable housing sites that can come forward over the Plan period to meet the authority's full objectively assessed needs. Council cannot currently demonstrate five-year housing land supply. Whilst recognising that further commitments have come forward since publication of latest Five Year Housing Land Supply Assessment report and envisaged supply of housing provided through the LP, submit that this is likely to continue to be the case. Whilst recognising that the LP already provides an element of flexibility in its proposed housing supply, submit that this will not be sufficient to meet the authority's housing needs.
To be found sound at Examination submit that there is need to identify further deliverable/developable sites, in particular that can come forward in the short term in sustainable locations. Remind Council that if it is not able to demonstrate a five year housing land supply at the time of the LPs adoption, its policies for the supply of housing will be out-of-date as soon as they are intended to come into effect.