Object

Representation ID: 66603

Received: 04/06/2014

Respondent: The Trustees of the F S Johnson 78NEL Settlement

Agent: Tyler-Parkes Partnership

Legally compliant? No

Sound? No

Duty to co-operate? No

Since the Revised Development Strategy the number of dwellings proposed on brownfield land has increased by 950. Despite this presumably being taken from the SHLAA the capacity of small urban sites as suitable for residential development has also risen from 300 to 393 in the Publication Draft. There is concern that the SHLAA sites are not necessarily deliverable given that they do not have planning permission. Also concern that many of the proposed allocated sites have not been subject to earlier consultation which is not in the spirit of a front loaded plan, particularly as representations at this stage must be confined to soundness and legal compliance. Do not dispute that the number of dwellings allocated to within the Growth villages may need to be decreased since the January 14 consultation. However strongly objects to distribution of these allocations between the settlements, the lack of safeguarded sites for longer term development and the site selection in Kingswood.It would be appropriate and in accordance with national planning policy that the largest proportion of development be directed towards the larger, most sustainable settlements. Kingswood (Lapworth) settlement was classified in the 'Draft Settlement Hierarchy Report' as one of five largest villages referred to as Primary Service Villages and only 4 points short of the most sustainable village but has been allocated the least amount of housing. Given the sustainability of Kingswood it is unsound that it is allocated fewer dwellings when there are suitable sustainble options available, such as land at Station Lane. The scale of development and growth should broadly reflect the sustainability of the statement. Objects to the division of housing between the growth villages because it does not fully accord with the NPPF's requirement to direct development towards the most sustainable settlements. The evidence produced in respect of Kingswood in so far as it relates to their site is unsound. It would be unreasonable to rely on this as justification for deviating from the sustainability hierachy. Outstanding housing need is an exceptional circumstance to justify review of a green belt boundary at Kingswood and the authority should safeguard land to meet longer term development requirements including: the Joint Strategic Housing Market Assessment, cross boundary requirement under duty to cooperate.
It is unclear whether the required 5 - 20% buffer has been allowed when calculating the 5 year housing supply. Given the importance of an evidenced deliverable 5 year housing land supply to any Local Plan, it is unsound for the Council not to have calculated and provided as part of the background evidence, updated information on the five year housing land supply.Warwick District had a significant annual housing shortfall in delivery, following cessation of the housing moratorium at the end of 2009. This we believe is a 'persistent' annual under delivery when measured against the annual housing requirement. Once a 'persistent under delivery' has been proven, which we contend it has, the 5 year housing land requirement would rise by a 20% buffer rather than a 5% buffer. Recent advice by the Inspector at the Independent Examination of the Staffordshire Moorlands Core Strategy indicated it is reasonable to suggest that 'persistent' means at least two accounting years before the current one and 'under delivery' would be where fewer than the projected annual housing unit requirement are completed. The Plan is unsound because it fails to address this and there is a shortfall in the deliverable housing land supply.

There is a strong case that the Plan is not sound because it fails to: provide sound, factually correct evidence on which to base decisions; satisfy the requirements of the Framework in plan making; provide guidance and certainty over the long term; identify sufficient developable, deliverable land which has been subject to public scrutiny and consultation to meet the housing requirement over the plan period; include a 20% buffer in the 5 year housing land supply; ensure all land included in the housing land supply calculation is deliverable; offer developers housing land allocation choices to ensure a rolling 5 year housing land supply is maintained; alter Green Belt boundaries to meet the latest identified growth requirement, including to meet any cross-boundary housing land shortfall under the Duty to Cooperate; ensure that Green Belt boundaries are capable of enduring beyond the plan period through the identification of 'safeguarded land'; identify a quantum of housing land allocations appropriate to the scale and sustainability of settlements; and remove our client's land, and other similarly 'deliverable' sites, from the Green Belt and allocate them for residential development.