Publication Draft

Object

Representation ID: 65707

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

Whilst the Council's allocation strategy may have been to firstly review previously
developed land sites, this cannot be enforced as a delivery policy. A 'brownfield
first' approach is not consistent with the Framework, which does not advocate this
priority or inflexibility. The Spatial Strategy should not be used negatively to
prevent sustainable development. Policy DS4 has identified the broad locations
which are to deliver growth over the Plan period, and allocated specific sites
accordingly, therefore the Council should not promote a hierarchical approach to
their allocations.

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: 65984

Received: 27/06/2014

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

As new allocations have been provided to deliver the needs of the Borough, the Council cannot assume that the historic rate of windfall development will continue. In addition to this Barwood suggests that a nonimplementation allowance is included to allow for any slippage in planning permissions not being built out.

The Employment Land Review identified a number of sites which have employment suitability issues and where future redevelopment for alternative uses many be appropriate. However the identified employment sites may not come forward for residential development exclusively, which will have an impact on the number of dwellings that can be delivered on these sites.

Object

Representation ID: 65986

Received: 27/06/2014

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Notwithstanding this support, Barwood reiterate paragraph 17 of the Framework which states that Local Planning Authorities should actively manage patterns of growth and focus significant development in locations which are or can be made sustainable. Additionally, the Framework states the supply of new homes can sometimes be best achieved through planning for larger scale development, such as new settlements or extensions to existing villages, which follow principles of Garden Cities.

Land South of Mallory Road is consistent with the Council's spatial strategy. The site offers the potential to deliver highly sustainable development as a sustainable
extension to an existing village.

Object

Representation ID: 65987

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 assumption that all the urban brownfield sites, along with the small SHLAA sites, will yield 1,330 units with no allowance for non-implementation or slippage is
questionable.

To reflect the uncertainties connected to the deliverability of a number of the urban brownfield sites, Barwood recommends that a 10% reduction is applied to the number of dwellings which could be delivered on urban brownfield sites.

The identification of Bishop's Tachbrook as a 'Growth Village' is supported, as it is truly capable of accommodating growth.

It is considered however the Plan is currently unsound as it identifies some 20 villages within this category some of which will only bring forward 10 or fewer units.

Barwood strongly disagrees with the identification of only a single allocated site in Bishop's Tachbrook,when the location is capable of accommodating greater levels of growth than those currently proposed.

Land to the South of Mallory Road is a site which is better placed to accommodate residential development than the site to the south of the Primary School. Barwood strongly disagrees with the decision not to allocate this land for residential development.

Barwood consider that the approach taken by the Council in allocating housing sites within Growth Villages is not sound as it is not consistent with the Framework. The policy approach does not allow for a sufficient choice and range of dwellings.

Support

Representation ID: 65988

Received: 27/06/2014

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

The policy approach of Policy DS15 is supported by Barwood. It is important that
the masterplans for the strategic urban extensions are approved by the Council to
ensure site deliverability. However, Barwood consider that the policy lacks
clarification on the process by which the Development Brief or Masterplan will be
approved.

Object

Representation ID: 65989

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

Local Planning Authorities with Green Belts in their area should only alter the Green Belt boundary in exceptional circumstances, through the preparation or review of the Local Plan.Green Belt boundaries should have permanence in the long term and be capable of enduring beyond the Plan period.The Council has not undertaken a strategic review of the Green Belt and therefore does not have the evidence base to selectively remove sites, such as Red House Farm, from the Green Belt.

The Council has identified that it is their intention to undertake a revised evidence base for the wider Housing Market Area which, importantly, includes a review of the Green Belt. This evidence base must inform this Local Plan as changes to Warwick's Green Belt cannot be implemented through a partial review.

Object

Representation ID: 65990

Received: 27/06/2014

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

National guidance sets out a prescriptive set of requirements in relation to the Duty to Cooperate and it is confirmed that robust evidence is required to demonstrate how this has been complied with.

The Sub-Regional Approach to Delivering the Housing Requirement report identifies that further work is required to ensure the HMA has a robust subregional
evidence base to support collaborative work on a sub-regional spatial strategy.

The Council's approach to the Local Plan's housing spatial strategy is premature given the significant uncertainties which the joint HMA evidence base could deliver.

This approach lacks certainty and is dependent on a number of significant pieces of technical evidence that are not yet complete.There can be no assurance that the Council's assumptions will translate to the HMA's unmet housing requirements being provided for.

Barwood conclude that the legal compliance of the Plan has not been satisfied on the basis that the Duty to Cooperate is not a matter which can be rectified at the Examination stage.

Support

Representation ID: 65991

Received: 27/06/2014

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Barwood support this policy which sets out the Council's strategic approach to
housing, aiming to ensure the District has the right amount, quality and mix of
housing to meet future needs.

Object

Representation ID: 65992

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

Barwood object to the inflexible approach taken to bringing forward allocated sites
in the Growth Villages through Policy H10.

Barwood consider that the approach taken in clause (c) is overly restrictive. By the very fact that the Council has allocated a site for development, the site's
deliverability is reinforced. The Council should not therefore put a limit of the
number of dwellings which can be delivered per annum. This approach is
restrictive and does not follow the Framework's positive growth message.
Barwood suggest that this clause is removed from the Policy H10.