Object

Representation ID: 66578

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Net in-migration fell from a figure of over 2,000 per annum in the years immediately following the millennium to 400 in 2008-9 and net out-migration of 700 in 2009-10. In view of this dramatic change it is not acceptable, as the 2012 SHMAA did, to take the 460 average and simply project it forward over the plan period. There is a real possibility that there will be net out-migration from rather than in-migration to the district over the plan period. The past rate of growth of population and in-migration is unsustainable. the District Council should be planning for a very much lower level of growth in which housing and employment are balanced against environmental objectives.

The SHMAs cannot claim to have been an objective assessment of housing need. The work was commissioned by local authorities and the steering committees were dominated by development interests who have a vested interest in talking up the housing needs figures. Wider interests such as residents' groups and environmental bodies were excluded from the process. WDC have assumed population growth of 17% between 2011 and 2029. This rate of growth would be above that for almost all the SHMA Projection Scenarios, despite the plan period being two years shorter than that of the SHMA. No justification is provided in the Plan for the choice of this figure. Employment forecasts are subject to great uncertainty and cannot be reliably used.

The proposal for 12860 houses is not justified in the text. The Plan is therefore unsound in its provision for housing.

The Plan does jot take account of the latest ONS population projections, which shows a much lower rate of population growth than assumed in the JSHMA. This could suggest a reduction in the housing requirement of about 3700 homes. Further average household has recently stablilised, but the plan assumes continued reductions.

Taking all these factors into account, we consider that the Plan is unsound because its housing provision is based on out-of-date information and on an over-optimistic, inflated view of both employment and population growth prospects.