Publication Draft

Object

Representation ID: 66042

Received: 27/06/2014

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy DS6 : Level of Housing Growth proposes 12,860 new homes (714 dwellings per annum)between 2011 - 2029. However the Coventry & Warwickshire Joint SHMA Final Report states in Paragraph 7.79 that an appropriate level of provision in Warwick District Council would be 720 dwellings per annum equivalent to 12,960 dwellings over the Local Plan period. Therefore the housing requirement figure in Policy DS6 is 100 dwellings below the objective assessment of housing need identified in the SHMA so the Council is not meeting its needs in full.


Further, the JSHMA does not take sufficient account of suppressed household formation during the recession years. The Council should consider undertaking further sensitivity testing which may indicate an increase in the objective assessment of housing needs above the proposed housing requirement of 12,860 new homes.

The JSHMA does not take sufficient account of the housing affordability issues within the District. An increase in the total housing figures included in the Local Plan should be considered where it could help deliver the required number of affordable homes. The Council should reconsidered its approach to affordability given the significant level of need for affordable housing in the District.

The housing requirement set out in DS6 does not take account of unmet need arising from outside the District, as required by the NPPF.

Object

Representation ID: 66043

Received: 27/06/2014

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The NPPG affirms that a LPA should assess its development needs working with other authorities in the relevant HMA in line with the Duty to Co-operate. Each of the authorities within the sub region is at a different stage in preparing their local plan or core strategy, therefore the capacity of the other districts to deliver their housing requirement is unknown. Policy DS20 states that existence of unmet housing need arising outside outside the District will not render the plan out of date, however the Plan will be reviewed.

There is evidence of a potential shortfall arising from a number of the neighbouring local authorities.Therefore it is not agreed that the existence of an unmet housing need outside the District will not render the Warwick Local Plan out of date.If a LPA preparing a Local Plan provides robust evidence of an unmet housing need identified in a SHMA other LPAs in the HMA will be required to consider the implications including the need to review their housing policies.

In conclusion whilst there remain uncertainties about the meeting of unmet housing need in the LPAs adjoining Warwick District Council and Birmingham it is impossible to determine if the legal requirements of the Duty to Co-operate has or has not been discharged by the Council because the evidence is not available on which to make such a judgement.

Object

Representation ID: 66044

Received: 27/06/2014

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Within this policy is a stipulation that sites allocated for 50 or more dwellings must be phased with ''no more than 50 dwellings at a time over a period of 5 years''. This is inappropriate, as the fundamental thrust of government policy is the need to boost significantly the supply of housing.

The phasing proposal within this policy means that the Council will not be meeting its objective assessment of housing needs.

Object

Representation ID: 66045

Received: 27/06/2014

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This policy includes a reference to a Supplementary Planning Document (SPD). This SPD has not been through a statutory process and therefore has a lesser status than the Local Plan. By referring to this SPD in the Local Plan policy a greater weighting of significance is implied which is inappropriate. This reference should be removed and only if necessary placed in the supporting text.

Object

Representation ID: 66046

Received: 27/06/2014

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This policy includes a reference to a Supplementary Planning Document (SPD). This SPD has not been through a statutory process and therefore has a lesser status than the Local Plan. By referring to this SPD in the Local Plan policy a greater weighting of significance is implied which is inappropriate. This reference should be removed and only if necessary placed in the supporting text.

Object

Representation ID: 66047

Received: 27/06/2014

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy CC3 Building Standards Requirements - Residential Buildings requires all new dwellings to achieve Code for Sustainable Homes Level 4 from the date of adoption of the Local Plan and Level 5 from 2016 (or any future national equivalent) unless it can be demonstrated that it is financially unviable. This policy should be reviewed by the Council in response to the Governments recent consultation on the Housing Standards Review and the announcements on planning made in the recent Queen's Speech.

Object

Representation ID: 66048

Received: 27/06/2014

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This policy proposes that a minimum of 40% affordable housing to meet local needs is provided on residential developments of 10 or more dwellings within the urban area and 5 or more dwellings within the rural areas. The form of affordable housing, its location on the site and its means of delivery will be subject to negotiation at the time of a planning application.

Policy H2 together with other policy requirements such as Policy CT5 Infrastructure Contributions to Meeting Places, Cultural Facilities and Public Art, Policy CC3 Building Standards Requirements, and DM1 Infrastructure Contributions are not justified by the viability assessments, which demonstrate that at the Baseline Market Position no development was viable at 40% affordable housing provision.

Object

Representation ID: 66049

Received: 27/06/2014

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Although this policy has a viability assessment in place to ascertain the extent the Plan's policies are likely to impact a schemes viability.

The Council in the first instance should be mindful that it is inappropriate to set unachievable policy obligations. In Paragraph 154 of the NPPF states that "local plans should be aspirational but realistic". It is unrealistic to negotiateevery site on a one by one basis because the base-line aspiration of a policy or combination of policies is set too high as this will jeopardise future housing delivery.

The Council should provide further evidence of whole plan viability assessment to justify the proposed policy requirements of the Warwick Local Plan.

Object

Representation ID: 66264

Received: 27/06/2014

Respondent: Home Builders Federation Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy DS7 sets out the means of achieving the housing requirement from past completions, existing planning permissions, windfall sites, SHLAA sites, use of employment land, canal-side regeneration and Local Plan site allocations.
Tthe Council should clarify the method for dealing with shortfalls in housing delivery illustrated by the housing trajectory against an annualised housing requirement and if a 5% or 20% buffer is applicable. The Council should also confirm that 5 years housing land supply is available on adoption of the plan.

Under Paragraph 49 of the NPPF "relevant policies for the supply of housing will not be considered up to date if the LPA cannot demonstrate a five year supply of deliverable housing sites". Therefore if the Local Plan is to be found sound and consistent with National Policy it is critical that the land supply requirement is achieved.