Preferred Options

Object

Representation ID: 49210

Received: 24/07/2012

Respondent: Hallam Land Management & William Davies Ltd

Agent: Marrons

Whilst plan sets out an impression of likely improvements to highway infrastructure works necessary and anticipated provision of new education facilities, relative to each proposed housing allocation, gives no impression as to costs and how these might be covered by either CIL
contributions and/or obligations relative to each development site.
CIL payments are additional to Section 106 Obligations. CIL will be integral to delivery of plans proposals.Section 106 Obligations and CIL could prove
to be onerous.
Number of sites could prove to be unviable. Necessary for plan to allocate "more than enough" land to meet estimated needs to overcome this.

Object

Representation ID: 49211

Received: 24/07/2012

Respondent: Hallam Land Management & William Davies Ltd

Agent: Marrons

Objective is to ensure new buildings resilient to climate change.
Matters embraced by national building regulations. Policy should therefore emphasise that matter and should also acknowledge national
policy "targets", set out in paragraph 95 of NPPF.
Any policy included in plan that seeks to introduce more local
and more onerous standards will impact on development costs and will therefore have
consequences site viability.

Object

Representation ID: 49212

Received: 24/07/2012

Respondent: Hallam Land Management & William Davies Ltd

Agent: Marrons

Preferred option is to concentrate most development in or on edge of existing urban areas, described as most sustainable. Agree mostly with approach and broad strategy.
Consider that strategic expansion of Warwick/Leamington Spa, to south of two towns offers advantages over approaches to distribution of growth.
a. Such scales of growth provide better framework for the implementation of garden suburbs principles.
b. Levels of development proposed will secure viable provision of off-site infrastructure works necessary to proper planning of proposed schemes.
c. The proposals are of scale that would provide for viable on site local facilities/services.
d. Growth here avoids use of Green Belt:a key strategic
component of urban structure in northern parts of sub-region.
e. Information in SHLAA supports release of these sites.
"known" supply at 2011. includes existing commitments, small urban SHLAA sites and Windfalls. Number of small "windfall sites" will be developed for housing. Some of these identified in SHLAA.
Windfalls
On the basis of the advice in paragraph 7.20, assumed that windfall component of forward supply is:
a. Small Urban SHLAA sites 290
b. Other Windfall Housing sites 2,300
c. Total 2,590
In total windfall sites provide 24% of dwellings. New land required, is 27% (i.e. 10,800 less 1,224 commitments = 9,576. 2,590 ÷ 9,576 x 100).
Consider that above figures indicate "over reliance" on sites which have not been identified as available. Nor does evidence set out evidence to support that level of provision can be secured from previously developed
sites. Table 3 of SHLAA records completions on windfall sites 2001/2 to 2010/11. No breakdown between brownfield and greenfield sites or those which involved use of
urban garden sites. Does not therefore provide appropriate basis to suggest 2,590 new homes will come forward.
SHLAA identified sites capable of providing 13,385 dwellings (2014 - 2029) (Table
Four).
Plan requires 9,576 dwellings will need to come forward from requirement to be met from new sites. A figure of about 960 dwellings from unidentified windfall sites on
previously developed land would be appropriate.
Provision for new housing in District will have to rely substantially on allocation of land as urban extension sites. Paragraph 52 of the NPPF advises that supply of new homes can sometimes be best achieved through planning for larger scale development in form of extensions to existing towns. May then be appropriate to follow principles of Garden Cities.
This approach has clearly been followed by WDC. In so far as development proposals to south of Warwick/Leamington Spa are concerned and expressed previously,support this strategy.
ITotal of identified sites represents 20% or 1,374 dwellings more than "balance to be allocated" set out in Table 7.1. Flexibility allows,
inter-alia, for some sites to be removed, depending on response to consultation and any further evidence.
In the event of "additional allocations" not being required, it must fall to "Green Belt" sites to be removed from plan.
However, WDC will be aware that at recent Core Strategy Examinations, Inspectors have expressed concerns about the apparent lack of "flexibility" in the forward supply of
development land some flexibility be maintained. As the
Council have assessed this to be in the order of 20%, we would support this approach.
Proposed allocations
Clients' land forms part of south of Gallows Hill/West of Europa Way site. Defined in SHLAA; site reference W10. Development of this site is supported either as a part of proposed wider strategic urban extension or as a discrete development parcel, representing first phase site.
Council will be aware that Hallam Land Management and William Davis have undertaken background studies of the land in which they have an interest (site W10).Confirm that site is capable of delivering about 250 dwellings in first phase of plan period. Note that capacity of site will be influenced by application of Garden Suburbs principles. Anticipate that densities will be lower than those evident at Heathcote.

Object

Representation ID: 49213

Received: 24/07/2012

Respondent: Hallam Land Management & William Davies Ltd

Agent: Marrons

Strategic Housing Market Assessment
"accepts" that a more realistic proportion might be 30%. Affordable Housing Sites would be able to demonstrate some viability were Affordable Housing to be set within 25% - 50% range.
Policy should include within wording an ability to enable
appropriate negotiation between LA and developer as to scale/nature of provision, so as not to "threaten" financial viability of site.
All sites should be capable of being viably developed. Accordingly, policy for provision of affordable housing must be seen in context of other obligations/cash burdens that fall to developers.

Object

Representation ID: 49214

Received: 24/07/2012

Respondent: Hallam Land Management & William Davies Ltd

Agent: Marrons

The Relationship between Housing and Employment Growth
i.Summary of the projections used to inform Policy PO1 is set out at Figures
2.21 and 2.22 of the Strategic Housing Market Assessment (March 2012)
(SHMA). Three of the thirteen (13) projections set out in the SHMA are
summarised in Table 5.1 of the Plan. Each of these are at the upper end of the
range that can be identified from the thirteen projections, which extend from
191 dwellings per annum (PROJ6) to 800 dwellings per annum (PRJOJ13).
ii. The three projections "considered to be worthy of further consideration" and
as referred to in Table 5.1 are as follows:
Projection 1. (PROJ1 of Fig 2.21/22.) Trend based and assuming continued
in migration of 400 persons per annum. The resulting housing requirement is
596 dwellings per annum or 11,921 dwellings 2011 - 2031.
Projection 2. (PROJ7 of Fig 2.21/22.) Projected employment growth of
11,860 jobs. Within this projection migration levels are adjusted so that the
growth in the labour supply matches the growth in the demand for labour
(jobs). The resulting housing requirement is 716 dwellings per annum or
14,310 dwellings 2011 - 2031. The demand for new housing could be
adjusted downwards by increasing levels of in-commuting.
Projection 3. (PROJ8 of Fig 2.21/22.) Projected labour force growth derived
from a population growth of 17,070 persons. Taking account of existing
commuting dynamics, this results in a growth in jobs of 7,895 jobs. The
resulting housing requirement is 569 dwellings per annum or 11,376 dwellings
2011 - 2031.
iii. Projection 3 is not considered appropriate, because the increase in jobs
(11,860 see Projection 2) is not matched by an increase in homes. Projections
1 and 2 were considered the more appropriate basis for estimating growth in
the District.
iv. Policy PO1, however, is based on the provision of 600 homes per annum. To
balance homes and jobs would require 716 homes per annum. In order to
support the forecast of 11,860 jobs there will need to be an increase in incommuting
to the District from adjoining areas to provide the necessary labour
force.
v. If the housing policy remains at 600 dwellings per annum, then the economic
growth of the District will require the provision of some additional homes
(about 116 dwellings per annum, i.e. 716 - 600 = 116), in those Districts,
which presently show commuter flows into Warwick.
b. Evidence of the Co-operation with Neighbouring Authorities
(i) If the broad strategic objectives of the plan are to "facilitate the growth and
development of the local economy" (see para 2.5), maintain high levels of
employment and to balance housing growth with employment growth, then the
plan should make provision for the development of 716 dwellings per annum
or 12,888 dwellings over the plan period 2011 - 2029. Development at this
scale would not be reliant on adjoining authorities acting as "hosts" to growing
numbers of in-commuters to the District over the plan period so that the
growth I employment opportunities can be realised.
(ii) In the alternative, should the Local Plan be progressed on the basis of
providing 600 new homes per annum or 10,800 dwellings over the plan period,
then some of the housing to "match the growth in employment", will be
provided outside the District. However, that assumption must be supported by
evidence to indicate that the local authorities who "host" the anticipated
growth in the number of in-commuters to Warwick are content to provide land
for the necessary number of new homes. For the plan to be sound and in
conformity with the advice in the NPPF at paragraphs 178 - 181 it cannot be
appropriate to rely on the intention set out in paragraph 5.12 of the plan, which
states that:
"The Council will, however, be consulting neighbouring
authorities on its proposals."
For the plans proposals to move forward on the basis of completing 600
dwellings per annum it must demonstrate how and where some 116 homes per
annum (716 - 600) are to be constructed. It will be wholly inappropriate to
progress the plan to submission stage without evidence that this issue has been
resolved on the basis of an agreement at sub-regional level.
(iii) Notwithstanding the observation at (ii) above, Policy PO3 and Tables 7.1 and
7.2 note that the plan will provide for "allocations" totalling 8,360 dwellings;
some 1,374 dwellings or 76 dwellings per annum more than the required scale
of new housing to be provided on allocated sites (see Table 7.1). These
planned allocations together with the addition of some further suitable SHLAA
sites could, in our view, meet the higher level of provision required to achieve
the balance between housing and employment.