Revised Development Strategy

Object

Representation ID: 55453

Received: 29/07/2013

Respondent: Taylor Wimpey UK Ltd

Agent: Barton Willmore

Plan Period: The draft document refers to a 15 year plan period however the plan commencement and end dates of 2011 - 2029 are 18 years apart and the Council should clarify the plan period.

Object

Representation ID: 56815

Received: 29/07/2013

Respondent: Taylor Wimpey UK Ltd

Agent: Barton Willmore

Duty to co-operate: The Localism Act and Paragraphs 17, 157 and 178 of the National Planning Policy Framework (NPPF) require neighbouring authorities to work in a joint manner and co-operate in order to address planning issues which cross administrative boundaries or on matters that are larger than local issues. Under Paragraph 181 LA's are required to demonstrate evidence of having co-operated effectively when their local plans are submitted for examination.

Working closely with the other authorities (Coventry, Warwick, Nuneaton & Bedworth and Rugby) on SHMA but the Council will have to demonstrate co-operation within the wider context of neighbouring authorities, including Solihull and Stratford upon Avon Councils.

Following the revocation of West Midlands RSS (WMRSS), there has been a significant drop in the total level of housing provision being promoted by local authorities across the West Midlands.

Research by the HBF shows that in total all the adopted and emerging plans for the WM will only provide for 17,085 homes per year compared to the previous target of 19,795.

Currently a high-level of uncertainty in neighbouring authorities over the level of housing provision required to meet objectively assessed needs for both market and affordable housing as set out in the NPPF.

Strategic pressures do still exist. If any neighbouring authorities are not adequately meeting their own assessed housing needs then it is anticipated that these housing pressures could impinge upon Warwick DC. Request that any SHMA publication and associated amendments to the development strategy are consulted upon in full to enable a suitably robust consultation strategy and record of engagement with neighbouring authorities.

Object

Representation ID: 56816

Received: 29/07/2013

Respondent: Taylor Wimpey UK Ltd

Agent: Barton Willmore

Amount of housing: Not considered appropriate to comment fully until the results of the joint-SHMA are available.

Concerns with an over reliance on the 2011-based interim household projections, which suggest only an average need of 624 new households per annum 2011 - 2021. These results are heavily influenced by a period of sharp economic recession and the Council should not use these figures to justify a low housing requirement that fails to meet needs during a different economic period and following a time of volatility in the housing market. See Cambridge Centre for Housing & Planning Research (CCHPR) report 'Choice of Assumptions in Forecasting Housing Requirements Methodological Notes' dated March 2013.

Council should give weight to documents and statements such as 'Laying the Foundations: A Housing Strategy for England' (November 2011), the 'Get Britain Building' fund (December 2011) and 'Housing and Growth' (September 2012). All highlight the significant role that residential development can have in assisting with the economic recovery of the Country.

Warwick DC can make a valuable contribution to the economic recovery of the region and the Country as a whole.

Object

Representation ID: 56817

Received: 29/07/2013

Respondent: Taylor Wimpey UK Ltd

Agent: Barton Willmore

Housing supply: Warwick DC cannot demonstrate a five-year supply of deliverable housing. If the CS is not to be out of date on adoption it is important that the land supply requirement is achieved. If there were not reasonable certainty that this would be the case then the plan would not be sound as it would be neither effective nor consistent with national policy. Without a five year housing land supply, the Council should aim to identify and release more development land in a range of locations or formulate a deliverable strategy that will provide for housing needs across the Plan period. The local plan needs to demonstrate maximum flexibility to ensure delivery of an objectively assessed housing need in accordance with NPPF. As part of this the Council the provision of 5% or 20% buffer in its land supply must be addressed to be compliant with Paragraph 47 of the NPPF.

Object

Representation ID: 56818

Received: 29/07/2013

Respondent: Taylor Wimpey UK Ltd

Agent: Barton Willmore

In order to plan for sustainable and achievable growth within the District over the Plan period it is essential to apportion a sufficient level of growth to sustainable settlements within the District. Hampton Magna is recognised as a sustainable settlement. It is not clear from the document what evidence base has informed the specific housing requirements apportioned per settlement, however, it is considered that a higher level of growth should be planned for Hampton Magna to take account of its sustainability. The final level of housing agreed across the District may also impact on the need to provide extra residential growth in sustainable locations such as Hampton Magna.

The Council should give significant weight to the ability of Taylor Wimpey to deliver a development of this size, a factor which will provide the Council with certainty in meeting Hampton Magna's housing needs. The benefits of this should be fully considered by the Council before setting out to achieve a more dispersed strategy across several small sites which may place at risk the deliverability of the requirement over the Plan period.

Object

Representation ID: 56819

Received: 29/07/2013

Respondent: Taylor Wimpey UK Ltd

Agent: Barton Willmore

In order to plan for sustainable and achievable growth within the District over the Plan period it is essential to apportion a sufficient level of growth to sustainable settlements within the District. Barford is recognised as a sustainable settlement. It is not clear from the document what evidence base has informed the specific housing requirements apportioned per settlement, however, it is considered that a higher level of growth should be planned for Barford to take account of its sustainability. The final level of housing agreed across the District may also impact on the need to provide extra residential growth in sustainable locations such as Barford.

Land at Brembridge Close, Barford is capable of delivering approximately 12 dwellings and smaller sites of this nature should be used to complement the delivery of more significant sites such as Wellesbourne Road, Barford. Larger sites will provide the Council with significant confidence in their ability to meet local needs, however, the addition of a selection on smaller sites will add variety to the local housing offer and provide increased options for future residents.

The land to the west of Wellesbourne Road is capable of delivering approximately 60 dwellings and therefore will meet a significant portion of housing needs in Barford over the Plan period. The Council should also give significant weight to the ability of Taylor Wimpey to deliver a development of this size, a factor which will provide the Council with certainty in meeting Barford's needs. The benefits of this should be fully considered by the Council before setting out to achieve a more dispersed strategy across several small sites which may place at risk the deliverability of the requirement over the Plan period.

Object

Representation ID: 56820

Received: 29/07/2013

Respondent: Taylor Wimpey UK Ltd

Agent: Barton Willmore

Re Land North of Milverton: The demonstration of exceptional circumstances is necessary (Para. 83, NPPF) but considers the proposed housing target likely to be insufficient once finalised and that the release of additional land will be required. Council has produced additional documentation to support the Revised Growth Strategy; however, there remain significant concerns regarding the Strategy as currently defined. The ability of a housing market to deliver the required housing on sites in close proximity to one another. GVA Grimley (on behalf of Taylor Wimpey) consider that there is a relatively finite number of prospective purchasers for whom South Warwick would be an acceptable location. This will impact on the rates of delivery that can be achieved. Report will be submitted in full to the Council shortly and will provide further details. M-EC will provide a report on the updated transport evidence.

The Council cannot deliver the required level of growth without the release of Green Belt Land. A Green Belt review document produced by CSa Environmental will be submitted in support of these representations shortly. Initial assessment demonstrates that the characteristics of the land to the north of Milverton ensure that the release of the land for residential-focused development would not impact negatively on the five Green Belt tests as set out in the NPPF. It is considered that the Taylor Wimpey site to the north of Milverton provides the most appropriate site for release from the Green Belt to meet the housing needs. Consistent with the findings of the 2009 joint-Green Belt study which acknowledged that land to the north of Milverton (WL6a) was one of the best performing sites in this regard. The release of this land would also assist the Council in progressing a more deliverable strategy which would provide greater geographic choice for future residents of Warwick District.

Significant levels of growth envisaged as part of the 'Gateway' development near to the administrative boundary with Coventry and should be at the forefront of any strategy. Our Vision document, (submitted previously) set out how a well-designed development in this location could meet the wider needs of the District and provide for a strategic development based on the Garden City concept; with sustainability at the heart of the design.

Safeguarded Land
Should the SHMA evidence confirm that the housing target included in this document is robust and that additional Green Belt release is not required, we would urge strong consideration to be given to the concerns which have been expressed in respect of the distribution strategy and the reliance on the bulk of development being allocated in a single area.

Suggest the Council give due consideration to the removal of land from the Green Belt and identification as Safeguarded Land, to be brought forward in the event that the Council finds that it cannot meet its housing targets. Will add flexibility to the New Local Plan and ensure that the Council adopt a document that is able to respond to changing circumstances over the plan period. The site would need to be clearly shown on the Key Diagram and the following draft policy wording is proposed for inclusion: If it is demonstrated that there is a shortfall in the supply of housing sites against housing delivery targets for a consecutive two year period, the Council will take action to address the identified shortfall. Should this circumstance arise, the Council will work with the developers to release and phase the delivery of land north of Milverton, currently identified on the Key Diagram, to meet the identified shortfall.

Support

Representation ID: 56821

Received: 29/07/2013

Respondent: Taylor Wimpey UK Ltd

Agent: Barton Willmore

Supports the intention to focus development on the edge of existing urban areas so as to deliver the most sustainable strategy for the District.