Object

Representation ID: 66791

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

A key function of the plan is to meet in full the need for housing over the plan period. Policy DS6 does not, in our view, achieve this. It is considered that the requirement figure of 12,860 dwellings 2011 to 2029 is not positively prepared and is unsound. There is concern that the migration assumptions that have fed into the SHMA are not reflective of representative or normal migration patterns which instead have been influenced by the artificial policy constraint arising from the housing moratorium in place in Warwick District between 2005 and February 2009 . There was a period of recession once the moratorium was lifted which also has the effect of constraining supply and influencing migration trends.
There is also concern about the household formation rates used in the SHMA which use a blended approach utilising both 2008 and 2011 headship rates. It is considered that the use of 2011 headship rates to 2021 then 2008 headship rates for the following 10 years is far too pessimistic. The SHMA supports growth in labour supply of around 12% for the baseline assessment which falls short of the Experian forecast of 14.3%. It makes reference to unmet need which has not been added to the projections despite planning practice guidance stating it should be. Using the Chelmer model an alternative assessment has been undertaken for Warwick District which concludes the starting point for determining the actual housing requirement for Warwick is a figure of 15,084 dwellings over the plan period 2011 to 2029 based on the most up to date demographic information. To fulfil economic potential and to provide for projected employment growth within the plan period a higher requirement of circa 18,043 should be considered. In light of this it is considered that the delivery of 715 homes per annum would not deliver the full objectively assessed need for housing in the District. It would not assist in delivering economic growth, wouldn't address the serious imbalance in supply and demand and would not deliver the affordable housing needed. In the past the District has delivered rates of 900 + which suggests a rate of 1000 per annum could be achieved.