Object

Representation ID: 66546

Received: 27/06/2014

Respondent: Taylor Wimpey

Agent: Barton Willmore

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Localism Act and paragraphs 17, 157 and 178 of NPPF require neighbouring authorities to work in a joint manner and co-operate in order to address planning issues which cross administrative boundaries or on matters that are larger than local issues.
Council is working closely with other authorities from within the sub-region (Coventry, North Warwickshire, Nuneaton & Bedworth and Rugby) that have been involved directly in the production of the joint-SHMA. Furthermore, Solihull MBC, Birmingham City Council, Stratford-on-Avon District Council and Warwickshire County Council have been engaged as consultees in this process.
As is set out in paragraph 3.20 of the Coventry Sub-Regional Housing Study (Appendix 2), although North Warwickshire and Stratford-on-Avon demonstrate strong linkages to the Birmingham HMA, they are also share economic and political ties with Coventry and Warwickshire. As such it is not unreasonable to assess housing need for the sub region as a coherent HMA.
In terms of the duty-to-cooperate, fundamentally our concern relates to the point set out by the Council in paragraph 1.22 of the Publication Draft Local Plan:
"Each of the authorities within the sub region is at a different stage in preparing their local plan or core strategy. The capacity of the other districts to deliver their housing requirement in full is therefore not known. In this context, the potential remains that one or more of these authorities will not be able to meet their housing requirement within their boundaries."
However, the NPPF states the following in relation to the duty to cooperate:
"179. ... Joint working should enable local planning authorities to work together to meet development requirements which cannot wholly be met within their own areas - for instance, because of a lack of physical capacity or because to do so would cause significant harm to the principles and policies of this Framework...
181. Local planning authorities will be expected to demonstrate evidence of having effectively cooperated to plan for issues with cross-boundary impacts when their Local Plans are submitted for examination..."
Therefore, in our view it is clear that the duty to cooperate requires local planning authorities to meet - and therefore understand through joint working - the housing needs of authorities within the wider Housing Market Area who are unable to accommodate their own needs.
In essence what the Council are attempting to achieve is an agreement to cooperate at an undefined date in the future, when in reality there is no mechanism available to developers or neighbouring authorities to force Warwick District to review the Local Plan - particularly given the substantial areas of Green Belt which will to a large extent protect the District from appeals based on a housing land shortfall.
Given this position it is wholly appropriate that the Council continue to engage fully with the other HMA authorities until such time as the housing needs of each area - and the ability of those areas to accommodate their own needs - is understood.
If the Council chooses to proceed with the New Local Plan without this information, and with the same housing target, then one option to plan positively and give some confidence to developers and the Planning Inspectorate that the Council will assist neighbouring authorities if required, is to safeguard sustainable areas of land such as the land east of Radford Semele as shown at Appendix 1 to meet housing needs from across the HMA, should it be required.
This would add an amount of additional flexibility to the New Local Plan and ensure that the Council progress a Plan that is able to respond to changing circumstances over the plan period, as encouraged in paragraphs 21 and 50 of the NPPF.
The site would need to be clearly shown on the Key Diagram and the following draft policy wording is proposed for inclusion:
If it is demonstrated that either:
* there is a shortfall in the supply of housing sites against housing delivery targets for a consecutive two year period; or
* should a Council within the Coventry HMA demonstrate that it is not feasible for them to accommodate their own housing need.
The Council will work with the developers to release and phase the delivery of land east of Radford Semele, currently identified on the Key Diagram, to help meet the identified shortfall/housing need