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Object

Publication Draft

DS2 Providing the Homes the District Needs

Representation ID: 66008

Received: 27/06/2014

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Wish to help devise a sound local plan, but the publication draft is not sound for a number of reasons. The overriding reason is that the housing requirement doesn't take account of mid 2012 population projections. This means the plan is based on outdated data. The 2012 projections show population growth 28.7% less than used for the Joint SHMA. this changes the no. of dwellings required and means less infrastructure investment is needed. This in turn changes the selection of housing sites and allows brownfield sites to be committed before green field sites. This in turn enables a realistic achievable plan to be prepared.

PPG: 2a-003 "Assessing development needs should be proportionate and does not require local councils to consider purely hypothetical future scenarios, only future scenarios that could be reasonably expected to occur." Ensuring there is a supply of sites is necessary with affordable housing. but the Plan also needs to comply with Para 157 of the NPPF. It is also important to keep a balance between jobs and homes.

DTC is also important the JSHMA achieves this, but this needs to be re-examined to address the ONs projections, taking a particular problem with Coventry in to account. The JSHMA indicated a need for 67,536 homes over 18 years across the HMA. The revised projections (based on 2012 ONS) indicate a need for 68,152. However this masks an issue with Coventry's requirement whereby international migration makes up a significant element of the projected increase in Coventry's population. However international students inflow has increased since 2005, but corresponding outflow has not to the same extent (as students are generally resident for 3 years). This indicates that the increase in inflow may be due to international students on courses that are not yet completed. This temporary anomaly is projected forward in the population projections. It does not make sense to provide housing for this population as they won't be there.

If adjustments are made to reflect this, then a worst case scenario for Coventry would be an inflow of 40,000 (instead of 74,000) which is still lower than the JSHMA figure. This in turn would lead to a reduction in the HMA's housing requirement from 68,152 to 51,327.

with this level of housing Warwick District could justify a lower level of housing at the same time as fulfilling the DTC.

Attachments:

Object

Publication Draft

DS6 Level of Housing Growth

Representation ID: 66775

Received: 27/06/2014

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Wish to help devise a sound local plan, but the publication draft is not sound for a number of reasons. The overriding reason is that the housing requirement doesn't take account of mid 2012 population projections. This means the plan is based on outdated data. The 2012 projections show population growth 28.7% less than used for the Joint SHMA. this changes the no. of dwellings required and means less infrastructure investment is needed. This in turn changes the selection of housing sites and allows brownfield sites to be committed before green field sites. This in turn enables a realistic achievable plan to be prepared.

PPG: 2a-003 "Assessing development needs should be proportionate and does not require local councils to consider purely hypothetical future scenarios, only future scenarios that could be reasonably expected to occur." Ensuring there is a supply of sites is necessary with affordable housing. but the Plan also needs to comply with Para 157 of the NPPF. It is also important to keep a balance between jobs and homes.

DTC is also important the JSHMA achieves this, but this needs to be re-examined to address the ONs projections, taking a particular problem with Coventry in to account. The JSHMA indicated a need for 67,536 homes over 18 years across the HMA. The revised projections (based on 2012 ONS) indicate a need for 68,152. However this masks an issue with Coventry's requirement whereby international migration makes up a significant element of the projected increase in Coventry's population. However international students inflow has increased since 2005, but corresponding outflow has not to the same extent (as students are generally resident for 3 years). This indicates that the increase in inflow may be due to international students on courses that are not yet completed. This temporary anomaly is projected forward in the population projections. It does not make sense to provide housing for this population as they won't be there.

If adjustments are made to reflect this, then a worst case scenario for Coventry would be an inflow of 40,000 (instead of 74,000) which is still lower than the JSHMA figure. This in turn would lead to a reduction in the HMA's housing requirement from 68,152 to 51,327.

with this level of housing Warwick District could justify a lower level of housing at the same time as fulfilling the DTC.

The publication draft provides for too many homes and must be revised to reflect the latest projections. Further the JSHMA used an abstract and subjective concept of headship rates. This is critical because small changes in the average household size can alter homes required significantly. It also bases its average household size on the total population. This gives an incorrect result. ONS calculate the population estimates and projections on the total population less those living in communal establishments adding these back into the total population at the end of any calculation. This gives a true average household size which is different to the SHMA household size and varies the relationship between areas as each has a different communal proportion. If the population growth is going to be less, then the household size to use needs to be addressed. different options produce different outcomes. for instance the 2011 census rate would require 6715 homes for an increase of 15,313 people. However the likelihood is that household size will rise rather than fall.

Two other factors will also affect future measures of household size. Over time as affordable homes are reallocated to existing occupants, vacant spaces will become occupied. For owner occupiers, as people find house prices unaffordable, rather than move they tend to stay where they are but extend their properties to accommodate extra children etc. So a calculated outcome can be used to provide the capacity in a lower but acceptable number of homes.

As well as being better in terms of providing the right tenure mix, it is also better from a sustainability point of view as it takes less land, avoids loss of agricultural land, is better from a CO2 emissions reduction viewpoint both from energy used in homes and travel from fossil fuel vehicles, reduces costs and makes all homes more affordable and spreads the homes required around the district, reducing the amount of infrastructure needed by the additional population.

Attachments:

Object

Publication Draft

DS4 Spatial Strategy

Representation ID: 66778

Received: 27/06/2014

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

DS7 shows how the housing requirement will be met. The requirement needs to be revised to comply with the reduction in the population growth now known.

The completion between 2011 and 2013 are not consistent with the figure published in June 2013.

DS7 makes no provision to account for 687 over-supply form previous years (see PPG 3-036), nor does it account for 450 completions during 13/14. It does not include completions since 1/4/14 nor does it include an up to date assessment of site under construction. Finally it does not take account of vacant dwellings.

DS7 includes a balance to be provided on allocated sites. NE5 conflicts with DS11 where the Local Plan includes a significant number of sites as a first call for the housing required, before brownfield and urban regeneration sites have been fully examined.

The housing trajectory is unexplained and shows annual targets that are unlikely to be met. For a trajectory to be achieved, it should be site related so that as sites are approved they can be included in the trajectory correctly and confidently. 2014/15 is supposed to deliver over 1,000 homes but as yet none of the large sites have commenced.

DS4 is not be observed in other policies indicating inconsistencies. In the first instance, allocations will be directed to previously developed land within urban areas - if this is the case why have 5 major sites been approved in advance of previously developed land within the urban areas? greenfield sites will not need to be identified for housing because the revised population projection shows that the number of homes have either already been built, permission granted, allocated without involving greenfield or green belt for up to 10,100 homes, more than is now known to be required.

Attachments:

Object

Publication Draft

NE5 Protection of Natural Resources

Representation ID: 66779

Received: 27/06/2014

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

This policy waters down NPPF para 112 as it does not take in to account the economic and other benefits of agricultural land nor does it require it to be demonstrated that it is necessary and seek to use poorer quality land in preference to it. Para 5.198 alters the sense of the NPPF with a less stringent condition requiring any lower grade land to be excused if it has adverse sustainability impacts such as ...... sustainable patterns of development. This could mean anything to a developer. It may well explain why NE5 conflicts with DS11 where the Local Plan includes a significant number of sites as a first call for the housing required, before brownfield and urban regeneration sites have been fully examined.

Attachments:

Object

Publication Draft

DS10 Broad Location of Allocated Sites for Housing

Representation ID: 66781

Received: 27/06/2014

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

This does not take account of previous years oversupply; completions to date; sites under construction; vacant dwellings already returned; permissions not started; further permission between April and December 2013; offices to residences approved; windfall sites for the plan period; small urban sites on SHLAA sites and consolidation of existing employment areas and canal side development. This means that if the housing numbers identified as needed by a revised approach on population numbers and the conversion method to number of dwellings then no further applications need to be granted to meet the plan as there is already a surplus provision.

If the maximum figure for the reduced population projection figure of 9,217 is considered to be necessary, then to this list can be added allocated urban brownfield sites definites only; 2 greenfield sites in urban locations; 4 sites accepted in villages and 6 sites granted since January 2014 can be added giving 9,601 dwelling sites.

The reduced population projection and the related reduction in the number of houses required now means that the use of any further greenfield sites cannot be demonstrated to be necessary and those should be removed from DS11.

Grove Farm at 200 dwellings, future vacant dwellings return and a list of 543 C2 homes for the elderly can also be counted in the supply. With these it would not be necessary to keep the sensitive urban brownfield and sensitive greenfield in DS11.

Attachments:

Object

Publication Draft

DS11 Allocated Housing Sites

Representation ID: 66782

Received: 27/06/2014

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

This does not take account of previous years oversupply; completions to date; sites under construction; vacant dwellings already returned; permissions not started; further permission between April and December 2013; offices to residences approved; windfall sites for the plan period; small urban sites on SHLAA sites and consolidation of existing employment areas and canal side development. This means that if the housing numbers identified as needed by a revised approach on population numbers and the conversion method to number of dwellings then no further applications need to be granted to meet the plan as there is already a surplus provision.

If the maximum figure for the reduced population projection figure of 9,217 is considered to be necessary, then to this list can be added allocated urban brownfield sites definites only; 2 greenfield sites in urban locations; 4 sites accepted in villages and 6 sites granted since January 2014 can be added giving 9,601 dwelling sites.

The reduced population projection and the related reduction in the number of houses required now means that the use of any further greenfield sites cannot be demonstrated to be necessary and those should be removed from DS11.

Grove Farm at 200 dwellings, future vacant dwellings return and a list of 543 C2 homes for the elderly can also be counted in the supply. With these it would not be necessary to keep the sensitive urban brownfield and sensitive greenfield in DS11.

Attachments:

Object

Publication Draft

DS7 Meeting the Housing Requirement

Representation ID: 66783

Received: 27/06/2014

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

DS7 shows how the housing requirement will be met. The requirement needs to be revised to comply with the reduction in the population growth now known.

The completion between 2011 and 2013 are not consistent with the figure published in June 2013.

DS7 makes no provision to account for 687 over-supply form previous years (see PPG 3-036), nor does it account for 450 completions during 13/14. It does not include completions since 1/4/14 nor does it include an up to date assessment of site under construction. Finally it does not take account of vacant dwellings.

DS7 includes a balance to be provided on allocated sites. NE5 conflicts with DS11 where the Local Plan includes a significant number of sites as a first call for the housing required, before brownfield and urban regeneration sites have been fully examined.

The housing trajectory is unexplained and shows annual targets that are unlikely to be met. For a trajectory to be achieved, it should be site related so that as sites are approved they can be included in the trajectory correctly and confidently. 2014/15 is supposed to deliver over 1,000 homes but as yet none of the large sites have commenced.

DS4 is not be observed in other policies indicating inconsistencies. In the first instance, allocations will be directed to previously developed land within urban areas - if this is the case why have 5 major sites been approved in advance of previously developed land within the urban areas? greenfield sites will not need to be identified for housing because the revised population projection shows that the number of homes have either already been built, permission granted, allocated without involving greenfield or green belt for up to 10,100 homes, more than is now known to be required.

Attachments:

Object

Publication Draft

DS13 Allocation of Land for a Country Park

Representation ID: 66784

Received: 27/06/2014

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

DS13 allocates grade 2 and 3a agricultural for the development of a country park as part of the offsetting of the housing development proposed south of Harbury Lane.

Now that the 2012 population projections show that land south of Harbury Lane is not necessary for housing development, this area of land should also remain as agricultural land. This is particularly important as it an essential part of the Tachbrook Valley and can be seen from long distances across the valley.


We doubt that the £1.5m needed to set up a Country Park, , will be available nor can we see the expensive continual maintenance being affordable from reducing Council budgets. Hence we cannot see the Country Park will materialise.

Attachments:

Object

Publication Draft

DM1 Infrastructure Contributions

Representation ID: 66785

Received: 27/06/2014

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is an important part of the local plan that the necessary infrastructure required is provided.

The financial contributions will not deliver the level of funding required for infrastructure, meaning the necessary infrastructure is not provided or that it has to come from other source which the current inhabitants will have to meet the cost of. There is no plan in place to deliver infrastructure.

If the housing needed is spread around the district, then some of the existing infrastructure can take up the spare capacity and in some ways that can be a good thing. But large amounts of new housing are concentrated in one place then large amounts of new infrastructure cannot be avoided.

Independent assessment indicates that the costs of the infrastructure required will be between £30m to £50m more than the income that will be received. Further this additional infrastructure will require sites upon which to place the facilities and these had not been selected nor has any land acquisition cost been included.

We find compared with an expenditure of in the region of £230m income that will be recovered to pay for those costs will be about £190m, leaving £50m unfinanced.
If the reduced population now known is taken into the plan then much of the infrastructure listed will cease to be required, because the sites are already known and are well distributed around the district.

Attachments:

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