Publication Draft

Object

Representation ID: 65510

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

Legally compliant? No

Sound? No

Duty to co-operate? No

Support of point c), as it ensures long term employment opportunities for all areas of the district, which will in itself enhance the long term sustainability of both main urban areas and villages throughout the plan area.

Point e) is overly restrictive, in that the base point for a determination on allocation is 'no'. NPPF paragraphs 133 and 134 require that the significance of harm that would be caused be the determining factor as to whether the 'presumption' in favour of sustainable development is applied, and to what degree public benefits of proposals should be assessed. The proposed policy conflicts with national policy, is therefore 'unsound' and should be either altered or removed.

Support principle of point g) of the policy, with the caveat of the requirement of the need to show exceptional circumstances in order to favourably consider Green Belt sites, with all other avenues first being exhausted before considering sites within the Green Belt.

Object

Representation ID: 65513

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

Legally compliant? No

Sound? No

Duty to co-operate? No

This policy should be more clearly tied into Policies DS4 and DS7, to
clearly set out what the housing needs are for Warwick District, and
how these will be explicitly be delivered within the district. At present,
this policy seems incomplete and almost unnecessary, due to other
policies more clearly being able to translate into development on the
ground whilst considering objectively assessed need.

Object

Representation ID: 65516

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

Legally compliant? No

Sound? No

Duty to co-operate? No

There is no explanation as to how the figure from the SHMA has been translated from an objectively assessed need ('Policy Off' figure) for Warwick to an overall housing requirement ('Policy On' figure).

A two stage process should be carried out: 1) use of SHMA toi identify OAN. 2) take account of other considerations to arrive at a final housing figure (e.g DTC, SHLAA). This can then give a sound figure for the Plan.

The Plan has only looked at stage one and is therefore a "policy off" figure and is unsound.

The plan proposes a high level of windfall housing (19.3% or 138 dpa). Whilst a degree of windfalls are allowed, this should only be if there is compelling evidence.

The 2014 report on 5 year supply has not been published and the 2013 report makes no allowance for non-implementation.

There is therefore not enogh evidence to demonstrate how this approach can be achieved, and the reliance on windfall sites in this way risks a serious undersupply of housing.

Object

Representation ID: 65519

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

Legally compliant? No

Sound? No

Duty to co-operate? No

Green Belt sites have been chosed before non-greenbelt sites have been exhausted. It is clear that there is a vast disproportion of distribution throughout the District's villages. Larger, more sustainable villages, with boundaries outside of Green Belt are proposed to accommodate far less housing when compared to smaller, less sustainable villages tightly constrained by Green Belt. 64% of the total requirement is expected to be achieved from villages currently within Green Belt, despite Barford and Radford Semele being capable of accommodating far higher levels of housing than proposed. As there are additional sites within these two non Green Belt villages that can accommodate housing without the need for incursions into Green Belt the approach to is unsound and does not comply with national policy.

Object

Representation ID: 65520

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

Legally compliant? No

Sound? No

Duty to co-operate? No

Green Belt sites have been chosed before non-greenbelt sites have been exhausted. It is clear that there is a vast disproportion of distribution throughout the District's villages. Larger, more sustainable villages, with boundaries outside of Green Belt are proposed to accommodate far less housing when compared to smaller, less sustainable villages tightly constrained by Green Belt. 64% of the total requirement is expected to be achieved from villages currently within Green Belt, despite Barford and Radford Semele being capable of accommodating far higher levels of housing than proposed. As there are additional sites within these two non Green Belt villages that can accommodate housing without the need for incursions into Green Belt the approach to is unsound and does not comply with national policy.

Object

Representation ID: 65523

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

Legally compliant? No

Sound? No

Duty to co-operate? No

This policy does not discharge to the Duty to Cooperate. As the 'duty' has not been discharged, the plan cannot be found to be legally compliant, and cannot be declared sound by an inspector. In this case the inspector must recommend the plan's withdrawal.

The Plan is not therefore legally compliant

Support

Representation ID: 65525

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

We agree with paragraph 4.7 of the plan, which offers detailed explanation on this policy. This correctly identifies Barford as a Growth Village within the District, therefore designating it as an area where a level of housing growth is to be expected.

Object

Representation ID: 65526

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

Legally compliant? No

Sound? No

Duty to co-operate? No

We seek clarification on this policy over whether Growth Villages, as defined in policy H1 fall under point A or point B, as the policies map does not identify rural areas explicitly.

Object

Representation ID: 65528

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

Legally compliant? No

Sound? No

Duty to co-operate? No

This policy is imprecise, due to it's over-reliance on the SHMA, a document that itself is not a part of the development plan, and is only designed to inform it.

the SHMA is informed by 2011 data. In paragraph 98 the Solihull High Court Decision, the judge mentioned that pre NPPF data must be used with 'Extreme Caution... because of the radical policy change in respect of housing provision effected by the NPPF".

Therefore, a SHMA must be fully reworked with data from April 2012 onwards, and not simply 'refreshed'. We are not convinced that the 2013 SHMA is a full and complete reworking of the process from the ground up, and is therefore fundamentally flawed.

The policy fails to recognise the the differing housing mix requirements of towns and villages and simply argues this will be negotiated on a'case by case' basis. The policy is therefore not robust enough to be considered acceptable throughout the plan area, hence failing the tests of soundness

Object

Representation ID: 65531

Received: 27/06/2014

Respondent: Sharba Homes Group

Agent: PJPlanning

Legally compliant? No

Sound? No

Duty to co-operate? No

This policy puts unecessary obsticles in the way pof housing delivery contrary to the NPPF (paras 14, 47 and 154).

The first bullet point places unnecessary weight on the opinions of the stakeholders, transforming a material consideration into a development
plan policy where development may be stifled simply because it may
be seen as unwanted or unnecessary, for reasons contrary to other
aims and ambitions of the plan.

The second bullet point undue weight on the SHMA.Because the SHMA is not being subject to consultation or examination
before informing the plan, it should not be directly referenced in policy, and instead, a 'Policy On' approach should
be taken. Again, the policy fails to make a comparison on a detailed basis throughout the district, and provides no evidential basis to explain the imprecise approach taken.

The final bullet point create serious viability issues, who will be unable to develop strategic sites in a timely,and cost effective manner. This is in conflict with both Paragraphs 14 and 47 of the NPPF and will reduce the ability for there to be clear 'choice and competition for land', instead forcing developers to hold onto land for long periods before areas can be brought forward. the policy will will make surrounding areas undesiarble during prolonged construction periods and will add the development burdens. The policyu will also hamper the delivery of 5 year supply. The plicy is unjustified and unsound