DS6 Level of Housing Growth

Object

Representation ID: 65694

Received: 30/06/2014

Respondent: Mr john fletcher

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Since Plan designed, ONS has produced new projections of growth in population shownig reduction.
Household size assumed to be lower than that now anticipated.
Number of homes required lower than in plan.

Object

Representation ID: 65695

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy sets out requirement for 12,860 homes over Plan period 2011-2029, equating to 720 dwellings per annum.
Proposed housing requirements drawn from 2014 Coventry and Warwickshire Joint SHMA. The Joint SHMA covers local authority areas of Rugby, Coventry, Warwick, North Warwickshire, Nuneaton and Bedworth and Stratford-on-Avon and identifies a mid-point of need of 3,750 dpa based on 2011 and 2008 headship rates as representing a reasonable level of provision on which to base the housing needs of the HMA. Preparation of the Joint SHMA comes after the withdrawal of Coventry's Core Strategy in 2012, particularly in light of lack of consistent/joint approach to meeting housing needs of the area and failure to discharge the authority's Duty to Cooperate.
Reviewing the housing requirements in the Local Plan and the findings of the joint SHMA, submit that proposed WDLP - Publication Draft Consultation housing requirements set out in Policy DS6 are too low to meet housing needs of the district and are not based on robust evidence. Whilst welcoming the SHMA, we submit that the assessment of the housing needs it provides for the HMA and the district underestimates level of housing required to support future demographic needs and economic potential. Whilst SHMA recognises the need to address market signals, query whether these have been properly factored into future assessment of housing needs, whilst noting proposed housing needs for HMA will be insufficient to meet affordable housing for the area as a whole. Strongly submit that the Council has underestimated future level of housing that must be provided.
Aware of independent objective assessment of housing needs for Coventry and Warwickshire HMA. Incorporating critique of Joint SHMA, the Coventry and Warwickshire Sub-Regional Housing Study finds that to meet the full objectively assessed needs of the HMA and Warwick District, an overall housing requirement of at least 5,100 dpa, based on an economic-led modelling scenario linked to economic forecasts used in the Coventry and Warwickshire LEP Strategic Economic Plan. Consultants find this level of housing growth would enable demographic needs to be met, forecasted ecomic growth to be accommodated, sufficient affordable housing to be supplied and make a significant contribution towards addressing adverse market signals in the area. Translated into requirements for individual authorities in the HMA, this would require a housing requirement of 18,000 dwellings to be provided through the Warwick LP, equating to 900 dpa.
To be found sound at Examination the Warwick District LP must be based on effective joint working on cross boundary strategic issues. In this regard the LP and Coventry and Warwickshire SHMA discuss and recognise the issue of cross-boundary housing needs within the HMA and unmet requirements arising from neighbouring authority areas. Policy DS20 specifically describes the work that has taken place between the Council and other authorities within the Coventry and Warwickshire HMA to agree a process for addressing unmet needs from one or more of the HMA authorities should they arise. Outside of the HMA, the LP also identifies that there may be an issue of unmet housing needs arising from the Greater Birmingham area.
Whilst welcoming the Council's willingness to work with its neighbouring authorities to address unmet housing needs, submit that the actions proposed by the LP and the Coventry and Warwickshire Joint Committee are not sufficient. There is a long-standing and existing acknowledgement that Coventry will be unable to meet the housing needs in its own administrative area, with a report to the Coventry and Warwickshire Joint Committee on 20th March 2014 clearly stating that "there is a significant risk that Coventry City Council will not be able to accommodate 23,600 dwellings (1,180 dpa) within the City boundary". The submission draft of Birmingham City Council's LDP also identifies an initial shortfall of 29,000 dwellings against its full objectively assessed needs. There is therefore a clear requirement for effective working to be undertaken to address these needs now, and for a positive response through the LP to meet them.
In light of the need to provide for a higher housing requirement in the district, submit that Policy DS6 is not positively prepared as it fails to propose a sufficient level of housing to meet Warwick's needs and those of it surrounding neighbours. LP not justified as it is not supported by robust assessment of full objectively assessed needs for the district, and is not effective as it fails to adequately address cross-boundary housing issues. In a number of instances Council's approach is not consistent with the requirements of the Framework.To be considered sound, submit that proposed housing requirements set out in the LP should be increased, at least being consistent with the assessment of the district's housing needs prepared by consultants. To address unmet housing needs already acknowledged to exist in relation to Coventry and Birmingham there is need for action to address these unmet needs now, rather than deferring this to future work or a review of the Local Plan.
In light of our concerns over the adequacy of the Council's proposed housing requirement, reserve the right to undertake an independent objective assessment of the authority's housing needs, consistent with the requirements of the Framework and the PPG on Housing and Economic Development Needs Assessments, and submit this to the Local Plan Examination.

Object

Representation ID: 65702

Received: 27/06/2014

Respondent: Mr and Mrs Swindells and Star Pubs and Bars Ltd

Agent: Barton Willmore

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The housing requirement proposed by the Local Plan Publication Draft is considered not to be positively prepared, as it is not based on the Objectively Assessed Housing Need, contrary to the NPPF and emerging Pollcy DS2. The SHMA suggests a minimum requirement of 660 homes per year, but identifies that these figures could suppress housing formation and therefore it considers that an appropriate level of provision, based on evidence would be around 720 new homes a year.

Object

Representation ID: 65734

Received: 27/06/2014

Respondent: Mr Michael Kinson OBE

Legally compliant? No

Sound? No

Duty to co-operate? No

The overall housing need forecast is wrong by almost a third and should be drastically reduced. The latest ONS projections support this position. The Council has not taken into consideration the impacts on Warwick of the proposed large development at Lighthorne (in Stratford District).The effect of the proposed huge expansion of the district and its impact on Warwick have been totally ignored, and it is feared that health and the heritage assets of the town will be affected by pollution and congestion caused by increased traffic. The Council's development strategy should not be going for growth but instead going for what is required!.

Object

Representation ID: 65736

Received: 26/06/2014

Respondent: Mr Dean Epton

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Initial consultation on level of growth resulted in majority of respondents favouring low growth option (about 5,500 dwgs), eventual plan proposes 12,900. Number speculative and based on poor quality evidence and data
15 year plan review could be revised upwards if necessary.
Recently published ONS population projection shows 29% reduction on previous estimate. Illustrates difficultly in prediction and need for caution in using data in planning decisions. Process of development not reversible.
Given pressure from developers to develop green field sites in hgih value areas for maximum profit and given negative impact of overdevelopment, safer to plan for lower number

Object

Representation ID: 65741

Received: 27/06/2014

Respondent: Barratt & David Wilson Homes;Bloor Homes;Catesby Group;Crest Strategic Projects;Hallam Land Management;Richborough Estates;Taylor Wimpey;William Davis

Agent: Barton Willmore

Legally compliant? No

Sound? No

Duty to co-operate? No

This representation highlights flaws in the published JSHMA and provides an alternative assessment of housing needs for the HMA.

The representation accepts that the 6 LPAs involved with the Joint SHMA provide a reasoned basis for an HMA study, not withstanding SDC's and NWBC's significant links with the Birmingham HMA.

Notwithstanding the fact that an up to date SHMA has been produced, a number of concerns about the SHMA's projection scenarios are raised: these include headship rates; migration assumptions; economic growth; market signals and affordable housing need.

These concerns mean that migration has been under-estimated, economic forecasts have not be sufficiently taken in to account. Further, market signals regarding house prices, affordability and overcrowding have worsened in recent years and suggest market dysfunction.

These factors need to be taken in to account by boosting housing numbers. A starting point for housing requirement should be the 2012 ONS projections, combined with long term migration trends. This indicates a starting point of c5000 dwellings per annum for the HMA. CE job creation forecasts indicate a requirement for approx. 5100 per annum (to better support economic development and to reduce reliance on unsustainable commuting). Taking this together this indicates an annual requirement of 5100 dwellings for the HMA between 2011 and 2031.

In respect of Warwick District, this would translate to a recommended housing target of 900 dwellings per annum or 18,000 dwellings over the period 2011-31.

By adopting a lower housing figure,local authorities run the risk of exacerbating market dysfunction in relation to market signals and affordable housing delivery, as well as stymieing the ambitious plans for economic growth and job creation which is reliant on sufficient new housing delivery if its ambitions are to come to fruition.

Object

Representation ID: 65746

Received: 27/06/2014

Respondent: Jaguar Land Rover

Agent: Gerald Eve LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Given the cross boundary impact of the existing Jaguar Land Rover operations on Warwick Districts' current housing provision and the need for housing requirements to accommodate future Jaguar Land Rover employees, the emerging Local Plan does not adequately plan for housing and services in accordance with the NPPF. Policy DS6 of the Local Plan is not consistent with National Policy, it is not sufficiently 'effective' as it is not based on effective joint working on cross-boundary strategic priorities.It is imperative that the Warwick District Council considers its housing targets in synergy with the need to protect, encourage and facilitate the ability of existing major employers, such as Jaguar Land Rover.

Object

Representation ID: 65873

Received: 27/06/2014

Respondent: Centaur Homes

Agent: McLoughlin Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Centaur Homes object to the level of housing growth put forward in the Plan. This
objection is based on the fact that whilst the objectively assessed need for the
District is broadly in the region of 13,000, the Plan has been prepared in isolation and does not take into account the need for the District to accommodate the needs of adjacent authorities, such as Coventry, as part of the Duty to Co-operate set out in the Framework.

Object

Representation ID: 65885

Received: 27/06/2014

Respondent: Mr E Barley

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The number of houses required by the Local Plan is incorrect and does not reflect the ONS population projections. The plan in its current format identifies too much development and not enough infrastructure.

Object

Representation ID: 65917

Received: 27/06/2014

Respondent: Mr. A. Burrows

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Office for National Statistics (ONS) has recently published population figures which are 29% below their previous figures used in preparation of this WDC Local Plan.
Not credible to continue with this plan based on outdated information with such a wide disparity in the data.
With pressures on land, Green Belt and infrastructure it would be much more reasonable to work to a lower housing need figure and periodically review the plan.

Object

Representation ID: 65953

Received: 27/06/2014

Respondent: Dr Diana Taulbut

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS7 provides for 12860 homes this is not in line with ONS statistics that show a population growth of 14000 over the plan period to 2029. In accordance with the ONS occupancy rates only 6008 homes are required, however Warwick District is working on a rate that predicts a population rise of 19,290. If 12860 homes are built and the occupancy rate applied by Warwick DC is applied we will endure a population rise of 29,963 (a 21.5% increase) which is unsustainable.

Object

Representation ID: 65983

Received: 27/06/2014

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy confirms that the Council is planning to provide for 12,860 new homes between 2011 and 2029. Barwood raise strong objection to this policy. In the first instance Barwood object to the Council setting a definitive target for housing growth.

Warwick may have to provide housing growth for the wider HMA and until the LPAs have fully assessed whether they are capable of delivering the required growth, Warwick cannot definitively state that they are planning for their full objectively assessed housing needs. Barwood believe that the Publication Local Plan is unsound as it plans for an artificially supressed level of housing growth in conflict with the objectively assessed housing needs of the Housing Market Area.

Object

Representation ID: 66031

Received: 30/06/2014

Respondent: The Warwick Society

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

HOUSEHOLD SIZE
The JSHMA assumes a rapid decrease in average household size which is not supported by evidence. The base data are questionable and other sources suggest a rise in average household size in Warwick District between 2001 and 2011. If tends are applied household size would fall to 2.30 in 2031. However GLH hearn have applied some senisitivities to take account supression of household formation, meaning household sizes would fall to 2.22 by 2031 - a much greater fall than past trends indicate and is an abuse of sensitivity testing. For instance factors acting in the opposite direction have been ignored such as the trend towards households which accommodate three generations.

PROJECTED POPULATION GROWTH
THE JSHMA is not based on the most up to date population projections. The latest projections show a 29% reduction in growth to the end of the plan period - 6,200 fewer people. This reduces by some 2,800 the number of new homes needed. Suggestions that this should be balanced by increases in Coventry's population growth are spurious as projected growth in Coventry is an artificial projection as a result of the universities' response to changes in their funding régime - incoming students are repeatedly added to each year's projection, but outgoing students are largely omitted. Without this Coventry's population is projected to grow in line with that of the sub-region as a whole.

The impact of this is that housing growth should be in 8100 over the plan period.

The knock on effect of the Council's proposals are that the average household size would be much smaller than projected and this is not consistent with the proposed densities of developments on greenfield sites. This inconsistency futher contributes to the unsoundness of the housing need calculation.

Object

Representation ID: 66042

Received: 27/06/2014

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy DS6 : Level of Housing Growth proposes 12,860 new homes (714 dwellings per annum)between 2011 - 2029. However the Coventry & Warwickshire Joint SHMA Final Report states in Paragraph 7.79 that an appropriate level of provision in Warwick District Council would be 720 dwellings per annum equivalent to 12,960 dwellings over the Local Plan period. Therefore the housing requirement figure in Policy DS6 is 100 dwellings below the objective assessment of housing need identified in the SHMA so the Council is not meeting its needs in full.


Further, the JSHMA does not take sufficient account of suppressed household formation during the recession years. The Council should consider undertaking further sensitivity testing which may indicate an increase in the objective assessment of housing needs above the proposed housing requirement of 12,860 new homes.

The JSHMA does not take sufficient account of the housing affordability issues within the District. An increase in the total housing figures included in the Local Plan should be considered where it could help deliver the required number of affordable homes. The Council should reconsidered its approach to affordability given the significant level of need for affordable housing in the District.

The housing requirement set out in DS6 does not take account of unmet need arising from outside the District, as required by the NPPF.

Object

Representation ID: 66054

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Council has failed to identify an objective assessment of objectively assessed need for housing. The current proposal is deficient and therefore unjustified and thus unsound.

The Council has used the 2011 Interim Population and Household Projections to inform it's housing figures, however these projections only extend until 2021, whereas the Council's SHMA seeks to extend these over the period 2011 to 2031.

It is understood that the SHMA undertook two sensitivity tests. With regard to scenario PROJ1A - 2008 Headship RPS concurs that the use of the 2008 headship rate over the entire plan period in this sensitivity test is likely to be unrealistic.

The second sensitivity test PROJ1A - Midpoint Headship seeks to apply a hybrid of the 2011 headship rate data to 2021 and then 2008 rates post this to 2031. RPS concur that this is an appropriate scenario to apply within the SHMA, however RPS objects to the manner in which this sensitivity test is applied.

Object

Representation ID: 66086

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan recognises that other authorities in the Housing Market area are at differing stages of the Plan preparation. There may be a need to take unmet need from other planning authority areas, most noticeably from Coventry and Birmingham. Indeed, the earlier versions of the Core Strategy proposed accommodating a significant proportion of housing from Coventry within Warwick District. The Council proposes to deal with this potential unmet need via a possible early review.

However Policy DS6 is considered unsound as it fails to acknowledge the need to potentially accommodate an element of unmet need from nearby districts.

Object

Representation ID: 66106

Received: 27/06/2014

Respondent: CALA Homes (mids) Ltd

Agent: Cerda Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy DS6 sets out the level of housing growth for the district and states that the Council will provide 12,860 new homes between 2011 and 2029. This housing requirement is derived from the 2013 joint Coventry and Warwickshire Strategic Housing Market Assessment. However a SHMA is a snapshot in time and may not reflect the objectively assessed housing needs later on in the plan period.

It is therefore important that the authority provide a significant buffer within their housing requirement so as to ensure a continuous supply of housing sites over the plan period.

Object

Representation ID: 66107

Received: 27/06/2014

Respondent: CALA Homes (mids) Ltd

Agent: Cerda Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

The housing requirement should be increased so as to ensure a continuous supply of housing sites over the plan period and to meet the needs of the wider West Midlands, notably neighbouring Authorities and Birmingham.

Object

Representation ID: 66114

Received: 27/06/2014

Respondent: Mr and Mrs Martin

Agent: Cerda Planning Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Although policy DS6 sets out that the council plan to provide 12,860 new homes between 2011 and 2029, which is derived from the joint Coventry and Warwickshire Strategic Housing Market Assessment , this is merely a snapshot in time and may not reflect the objectively assessed housing needs later on in the plan period. It is therefore important that the authority provide a significant buffer within their housing requirement so as to ensure a continuous supply of housing sites over the plan period.

Object

Representation ID: 66139

Received: 26/06/2014

Respondent: Burman Brothers

Agent: Nigel Gough Associates Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Whilst Warwick has set housing requirement at 12,860 dwellings 2011 - 2029 it has not identified its objectively assessed housing need. Urgent clarification is needed on this point.
The JSHMA apparently assessed housing need for each district, however, must be for an individual authority such as Warwick to assess themselves based on criteria and policies appertaining to their area. This does not appear to have happened or to be in accordance with the NPPF Guidance.
Need for rebasing plan period to 2031
Should be minimum of 2800 to 3300 new dwellings in addition to rebasing element in line with studies of market housing area and Cov and Warks Sub Region.
Additional housing requirement will require reassessment of housing numbers and locations and extend to future growth to meet the higher objectively assessed need.

Object

Representation ID: 66186

Received: 14/06/2014

Respondent: Mr C Wood

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Housing Need Forecast of 12,900 homes is exaggerated.

Forecast based on projections and assumptions, not on evidence. Fewer than 6,000 new homes would meet both natural growth and any likely reduction in household size.

The Plan period of 18 years, 2011-29, is longer than the 15 years required by the NPPF. The Office of National Statistics' itself advises against extrapolating them beyond 2021.

There is no need to provide in full now for what only may happen in the late 2020s, or never, the consequence of which is the allocation now of huge greenfield sites that may never be needed.

Object

Representation ID: 66194

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? No

Sound? Not specified

Duty to co-operate? No

The Council's proposals are woefully short on the number of homes required and fail to balance the level of housing and jobs provided within the strategy of the plan, or the core Objectives of it.

The proposals and policies in the Plan are not consistent with the approach set out in the preceding strategy. The proposals in the plan fail to provide for the objectively assessed need for housing, but more importantly fail to balance the provision of homes and jobs as advocated by the authority as being a fundamental component of the Plan's strategy and policy framework. It is therefore ineffective and unjustified.

In respect of the balance between jobs and homes.There is no assessment of the level of housing that will be needed to support or to balance the Gateway Site (sub-regional employment location).Given that this principle is a fundamental driver of the Plan as part of its Strategy and core Objectives, the plan cannot be found sound if it does not deliver on these.

Object

Representation ID: 66205

Received: 25/06/2014

Respondent: Protect Lillington Green Belt [Petition]

Number of people: 555

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS7 provides for 12860 homes this is not in line with ONS statistics that show a population growth of 14000 over the plan period to 2029. In accordance with the ONS occupancy rates only 6008 homes are required, however Warwick District is working on a rate that predicts a population rise of 19,290. If 12860 homes are built and the occupancy rate applied by Warwick DC is applied we will endure a population rise of 29,963 (a 21.5% increase) which is unsustainable.

Object

Representation ID: 66228

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy DS6 is unsound because it is not based on the most up to date evidence and the housing requirement should be increased.

The Joint SHMA indicates that the annual housing needs for the District is between 660 houses per annum to 772 houses per annum. A mid range figure has been arrived at albeit it is unclear what justification exists for this figure.

The Council has provided no reasoned justification for selecting 718 dwellings per annum, especially as its housing requirement is considerably higher than this figure i.e. up to 900 dwellings per annum.
An increase in the overall housing provision would assist in meeting the high level of affordable housing need identified in the report. G L Hearn consultants recommend the provision of 268 dwellings per annum in supporting the stronger delivery of affordable housing.

The SHMA also does not identify un-met need in other housing market areas.

It is vitally important to consider inter relationships between neighbouring authorities and HMAs when formulating housing and development policie, in particular the housing needs of Coventry identified in the joint SHMA and that of Birmingham City Council's needs.

Object

Representation ID: 66273

Received: 30/06/2014

Respondent: Matt Western

Legally compliant? No

Sound? No

Duty to co-operate? No

The latest ONS statistics predict 29% fewer residents for Warwick District throughout the life of the Plan.

Object

Representation ID: 66282

Received: 26/06/2014

Respondent: Mr H E Johnson

Agent: Bond Dickinson

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Welcome increase in housing numbers from the Revised Development Strategy however objects to the level of housing growth identified in the plan for the following reasons: The Council appears to have taken the figures from the 2011 CLG Interim Housing Projections and inserted them into the Local Plan without aligning these figures with other aspirations of the Plan. The objectively assessed need is therefore not provided for and it does not accord with the NPPF. The result of this will be an under delivery of homes against the identified need. The NPPF requires an additional buffer of at least 5% of housing need to ensure choice and competition in the market. Bearing in mind the historic under delivery in the area and the potential requirement to meet identified need in other local authority areas it is clear the council will have to bring forward housing from later plan periods and consequently fall short later on. The Council has ignored the advice of the Joint SHMA which recommends 720 dwellings per annum. Concern that the Council has not sufficiently discharged ita duty to cooperate, it is very likely that additional housing will be needed in Warwick District to meet the needs of the HMA. Recent Gallagher Homes case reinforces this point. It is therefore considered that the proposed housing requirement should be increased and further land should be allocated . The proposed extension at Red House Farm could provide a further 150 homes and should be removed from the Green Belt and allocated for housing.

Object

Representation ID: 66313

Received: 27/06/2014

Respondent: A C Lloyd Homes Ltd

Agent: Framptons

Legally compliant? No

Sound? No

Duty to co-operate? No

The plan period should be extended to 2031 (as Stratford Upon Avon have done), because the plan will not be adopted before the end of 2015, which is less than 15 years from the anticipated year of adoption; it is likely therefore that the choice of an end date of 2029 will artificially restrian the levels of growth.

Object

Representation ID: 66319

Received: 27/06/2014

Respondent: A C Lloyd Homes Ltd and Northern Trust

Agent: Framptons

Legally compliant? No

Sound? No

Duty to co-operate? No

The plan period should be extended to 2031 (as Stratford Upon Avon have done), because the plan will not be adopted before the end of 2015, which is less than 15 years from the anticipated year of adoption; it is likely therefore that the choice of an end date of 2029 will artificially restrian the levels of growth.

Object

Representation ID: 66326

Received: 27/06/2014

Respondent: Pauline Neale

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The housing numbers needed between 2011 & 2029 have been wrongly estimated as the population is now expected to increase by 15,300 and not 21,500 in the period.

Object

Representation ID: 66339

Received: 27/06/2014

Respondent: Mr. Paul Davison

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We should be providing for the needs of existing families rather than newcomers. The proposed developments will excerbate traffic problems and will put pressure on infrastructure.