Publication Draft

Object

Representation ID: 66050

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

RPS is of the opinion that the Housing Trajectory is unsound.

The Housing Trajectory contains substantial over estimations of housing delivery, particularly in the early period of the plan. The rate of development in the early period is insufficient from the sites identified and an over reliance is being placed on a small number of sites delivering high rates of dwellings. This is not going to be experienced as proposed and the only way to maintain high levels of delivery is from a broader range of sites.

RPS also objects to the identification of confidential sites in the Housing Trajectory amounting to 207 dwellings. It is not appropriate to identify confidential sites and withhold information on the location of such sites from a public examination of the evidence. If the Council cannot identify those sites publically, if cannot rely on them during scrutiny of the public examination as it does not permit transparency in the evidence. The 207 dwellings should be removed.

Object

Representation ID: 66052

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Council has failed to give the Green Belt a degree of permanence as required by the NPPF in that it cannot endure within the current plan period, yet alone beyond it. The Plan is unjustified and thus unsound.

The level to which the Green Belt has been amended is therefore insufficient to meet the needs of the District and Sub-Region.There is also clear evidence that Warwick District is severely under providing for housing need, land within the Green Belt offers sustainable options for addressing this.

RPS objects to the methodology applied to the land parcel C11a at Baginton, on the basis that the fourth criterion has been misapplied. PPG2 set out very clearly that this purpose was 'to preserve the setting and special
character of historic towns'. The assessment applied this purpose to Baginton Village which while it is acknowledged has a conservation area, it is not a town of special character, nor is it of special historic context.Against this misapplication of the Green Belt policy the parcel was discounted.

In conclusion the Council's own evidence therefore indicates that the authority was incorrect in its assessment of Green Belt Parcel C11a, as has been clarified by its more recent evidence that would have necessitated the further consideration of the site in the appraisal process.Taken on the whole, it is clear that the Green Belt Parcel C11 should have been appraised more
appropriately and the Council must have due regard to significant changing circumstances in reaching its conclusions now.

Object

Representation ID: 66053

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

RPS objects to the fundamental basis of this policy. It is not justified and is unsound. It is incorrectly predicated on unmet need arising from outside of the District and fails to reflect the commitment given by the authority in the Coventry and Warwickshire Local Enterprise Partnership.

A basis for objection is that the Council proposes a review mechanism to address sub-regional housing need.

Warwick is already accomodating sub-regional employment requirements within this current plan without the need for review. However there is no sign of any housing and job balanced agreement on associate levels of housing provision. The justification for this is that the Council does not know the capacity and other needs of other districts and thus a review mechanism is the only approach that it has considered.

There is a concern that no reference is made to the ability of Warwick or neighbouring authorities to accommodate the need within Warwick from the Gateway site.

RPS considers that a review mechanism is not required and that it is Warwick District Council that has a significant unmet need that needs to be addressed by adjoining authorities.

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: 66055

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

RPS objects to this policy as it is not positively prepared as it does not meet the housing needs within Growth Villages. Additional local growth is required at Baginton to support the growth status of the village.

RPS has identified a strategic site on the edge of Coventry to meet the needs of Warwick arising from the Gateway Site and that of Coventry City. However, RPS is also promoting a part of the site as a phase 1 development to deliver much needed local housing within the village and
objection is raised to the level of development currently identified to Baginton as a 'Growth Village'.

RPS supports the need for expansion at Baginton, but considers 35 dwellings unrepresentative of the level of housing need in the village.The identified housing need is considered out of date and not robust, the housing requirment is considered closer to that identififed in the Revised Developmnent Strategy of between 70 and 90 dwellings.

Object

Representation ID: 66056

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

RPS has set out objection to the strategy of the plan and the interrelationship between housing and employment, including the Duty to Cooperate, particularly in respect of the sub-regional employment allocation. However, the allocation in DS16 as it stands is soundly based, however, the implications of it and the manner in which it is accommodated in the wider strategy and sub-region is not.

Object

Representation ID: 66057

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.

RPS expect the authority's housing need to be based upon the Government's latest demographic evidence with close scrutiny of their relevance for future planning, and any adjustments made to them being fully justified.

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: 66060

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

There is a significant deficiency and the relationship between the level of housing and employment proposed in the Plan and the components of policy set out in Policy PC0.

Object

Representation ID: 66193

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

RPS is of the opinion that the Housing Trajectory is unsound in respect of windfall allowances. The allowance is clearly overestimated and unrealistic. It makes allowance for student accommodation which is unsound.

The NPPG states that student accommodation can be included in the housing requirement "based upon the accommodation it releases from the housing market. Notwithstanding, local authorities should take steps to avoid double-counting". The authority has clearly not understood the nature of the guidance.

More fundamentally the authority can only include student accommodation "based upon the accommodation it releases from the housing market". To release a dwelling unit form the housing market it requires the dwelling unit to be firstly occupied by Students, that will then move back to the new student accommodation and thus release the dwelling unit. No evidence is provided that this is the case. In fact, the converse is true in that university accommodation is typically for overseas and first year students, which will not exist in the housing market already. Therefore no release of dwelling units occurs. In fact, the university (para 10.78 of the SHMA) is seeking to expand its use of private rented properties in Warwick, Coventry and Leamington, not reduce it.

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.