Publication Draft

Object

Representation ID: 65741

Received: 27/06/2014

Respondent: Barratt & David Wilson Homes;Bloor Homes;Catesby Group;Crest Strategic Projects;Hallam Land Management;Richborough Estates;Taylor Wimpey;William Davis

Agent: Barton Willmore

Legally compliant? No

Sound? No

Duty to co-operate? No

This representation highlights flaws in the published JSHMA and provides an alternative assessment of housing needs for the HMA.

The representation accepts that the 6 LPAs involved with the Joint SHMA provide a reasoned basis for an HMA study, not withstanding SDC's and NWBC's significant links with the Birmingham HMA.

Notwithstanding the fact that an up to date SHMA has been produced, a number of concerns about the SHMA's projection scenarios are raised: these include headship rates; migration assumptions; economic growth; market signals and affordable housing need.

These concerns mean that migration has been under-estimated, economic forecasts have not be sufficiently taken in to account. Further, market signals regarding house prices, affordability and overcrowding have worsened in recent years and suggest market dysfunction.

These factors need to be taken in to account by boosting housing numbers. A starting point for housing requirement should be the 2012 ONS projections, combined with long term migration trends. This indicates a starting point of c5000 dwellings per annum for the HMA. CE job creation forecasts indicate a requirement for approx. 5100 per annum (to better support economic development and to reduce reliance on unsustainable commuting). Taking this together this indicates an annual requirement of 5100 dwellings for the HMA between 2011 and 2031.

In respect of Warwick District, this would translate to a recommended housing target of 900 dwellings per annum or 18,000 dwellings over the period 2011-31.

By adopting a lower housing figure,local authorities run the risk of exacerbating market dysfunction in relation to market signals and affordable housing delivery, as well as stymieing the ambitious plans for economic growth and job creation which is reliant on sufficient new housing delivery if its ambitions are to come to fruition.

Object

Representation ID: 65999

Received: 27/06/2014

Respondent: Barratt & David Wilson Homes;Bloor Homes;Catesby Group;Crest Strategic Projects;Hallam Land Management;Richborough Estates;Taylor Wimpey;William Davis

Agent: Barton Willmore

Legally compliant? No

Sound? No

Duty to co-operate? No

It is unlikely that Coventry City will be able to accommodate all of its objectively assessed housing needs within its own administrative area. However, no specific allowance has been made for this within the Plan's housing target. For the reasons stated above, we consider there to be a number of deficiencies within the Joint SHMA that call into the question the accuracy of the objectively assessed need within the HMA.

We do not consider that part C of Policy DS20 constitutes a 'concrete action or outcome' as the Council are effectively deferring the identification of suitable sites to meet the needs of an adjoining authority.

Whilst we are therefore generally supportive of the sentiment that the Council are expressing in Policy DS20, we do not consider that it goes far enough.