RDS2: The housing requirement of 12,300 homes will be met from the following categories of sites

Object

Representation ID: 59865

Received: 26/07/2013

Respondent: Mr & Mrs Trevor & Anne Wills

The projection as to the amount of housng required the area has been exaggerated and that nowehere near this quantity of housing necessary.

Object

Representation ID: 60037

Received: 29/07/2013

Respondent: Cllr Elizabeth Higgins

Objection is made to the need for this number of new homes. There are nearly 2,000 empty houses and offices can be converted to dwellings without permission. Waterloo Housing Association is building on the former Warwick Fire Station site; there are plans for the conversion of the former WCC offices on Northgate Street and the re-building of Park View Nursing Home.
There is insufficient land to accommodate all this development.
There would be an unacceptable impact on local heritage assets.

Object

Representation ID: 60054

Received: 29/07/2013

Respondent: Christopher Cox

The WDC Empty Homes Strategy should be taken into account in the identification of new homes. WDC has developed 250 homes back into use under this strategy and more are identified. In 2012 there were 1,350 empty homes in Warwick District. More work should be done to bring these homes back into use rather than propose large scale new developments.
Warwick DC should liaise with Stratford DC about the proposed development at Gaydon/ Lighthorne which is close to, and would impact upon, Warwick/ Leamington

Object

Representation ID: 60177

Received: 28/07/2013

Respondent: Crest Strategic Projects

Agent: d2planning

Objects to supply of housing sites identified in Table 1.

The recent appeal decision on land south of St Fremund Way, Whitnash Leamington Spa identified that the Council could only demonstrate a 2.6 year supply of housing land (May
2013).

Table 1 does not make any provision for a 5% or 20% buffer as required by paragraph 47 of NPPF.

Given the Leamington Spa appeal decision it would appear that the Council has consistently underperformed in its housing delivery and accordingly there should be a 20%
buffer applied.

There is no reference within this policy or the supporting text to the Council consistently underperforming in meeting its housing needs. Furthermore, paragraph 47 of NPPF states that identified sites should be deliverable.

It is unclear how the Council has arrived at its 300 small urban SHLAA sites as being deliverable since these sites usually exhibit complex ownership and assembly issues.

It is unclear whether this level of development can be achieved for these sites.

In addition there appears to be 'no compelling evidence' to justify the proposed level of windfall, as required by paragraph 48 of NPPF.

Recommendation
Reassess the supply of housing sites and identify more deliverable sites.

Object

Representation ID: 60181

Received: 29/07/2013

Respondent: Councillor Philip Morris

Insufficient numbers of windfall development sites are allowed for in the new local plan. Taking past trends in to account (which is one of the key indicators when predicting windfall sites), an average of 377 new homes per year came forward on windfall sites from 2001 to 2011. The new local plan only allows for 142 per year for the 18 years from 2011 to 2029.

Object

Representation ID: 60199

Received: 29/07/2013

Respondent: Gladman Developments

Policy RDS2 sets out the components of the Council's housing land supply. In particular it makes a windfall allowance of 2,800 dwellings over the Plan period.

Remind the Council of the guidance set out in P48 of the NPPF, which states that "Local planning authorities may make an allowance for windfall sites in the five-year supply if they have compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply"

Object

Representation ID: 60275

Received: 26/07/2013

Respondent: Mr Harry Johnson

Agent: Bond Dickinson LLP

A top down approach starting with the requirement and then subtracting the various known sources of supply to arrive at an allocation requirement and then to assume that all of that allocation requirement will come forward in the required period is unrealistic. This assumes that all the known sources of supply will deliver their full requirement. Past experience shows that there is always a dropout rate from windfall and small urban sites. Even commitments very seldom produce all of their capacity. Therefore there is a need to allocate beyond the bare arithmetical requirement to ensure that needs are met in the required period. The reliance on an extremely high proportion of the total allocated area, effectively in one broad location to the south of Warwick, (3195 dwellings out of 6630 or approximately 50%) also makes the Council extremely vulnerable to delayed delivery, a factor all too common on large sites. The Council requires major infrastructure investment in this area and this will take some time to provide and is quite likely to slip. Also large single sites are always subject to marketing constraints. Put simply, several smaller sites, more widely distributed, will always sell at a quicker rate than one large site in a single location. This factor can therefore result in a further delay in development coming forward from a large site at the required rate to meet needs. The Council needs to fully recognise the fact of non-take-up and slow delivery and allocate further land for development in sustainable locations. The exact extent of allocations will of course be determined by the final housing needs figure emerging from the revised SHMA.

Object

Representation ID: 63387

Received: 29/07/2013

Respondent: Sharon Sanderson

The WDC Empty Homes Strategy should be taken into account in the identification of new homes. WDC has developed 250 homes back into use under this strategy and more are identified. In 2012 there were 1,350 empty homes in Warwick District. More work should be done to bring these homes back into use rather than propose large scale new developments.
Warwick DC should liaise with Stratford DC about the proposed development at Gaydon/ Lighthorne which is close to, and would impact upon, Warwick/ Leamington