Publication Draft

Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 1.
1. In responding to this consultation, the Parish Council emphasises that its sole interest is to help devise a Local Plan that is positively prepared, justified, effective and consistent with national policy, complying with the National Planning Policy Framework and the Planning Practice Guidelines published in March 2014.
2 It is our belief however that draft Local Plan is not sound in a number of aspects.
But over-riding all the matters is the fact that because the plan is based on the joint SHMA, it was only able to use the mid-2011 ONS Population Projections when it was prepared.
On the 29th May 2014, the ONS published the mid-2012 population projections. As we indicated to you at the Planning Forum before the publication draft was approved by the District Council on April 23rd, the new projections show a very significant reduction in population projection for the plan period up to 2029.
3. National planning policy places Local Plans at the heart of the planning system, so it is essential that they are in place and kept up to date. PPG12-001, NPPF157 * 2.
To start a new Local Plan based on outdated data cannot be seen as a sound plan and an Inspector will have to conclude that procedural requirements have not been met and question whether the Plan is sound.
For Warwick District, the joint SHMA uses for Proj 1A a population growth of 23,858 over 20 years, this being 21,472 over 18 years. The mid-2012 ONS projection for 2029 is 153,049, which is a population growth of 15,313 from mid 2011. This is 28.7% less than the Joint SHMA.
This is a very significant change since, amongst other things, it
* Changes the number of dwellings to meet local need
* The lower population will need commensurately less infrastructure support, optimising the use of capacity in existing infrastructure
* Changes the emphasis on the selection of sites for new housing
* Allows brownfield and regeneration sites to be committed before greenfield sites meeting NPPF112 and PPG8-026 and this also places less pressure on Green Belt.
* Can provide a deliverable plan rather than a plan that is too ambitious and unrealistic in the period of the plan
The new projections indicate that 8,343 persons are due to natural change; movement between Warwick District and the rest of the UK account for 5,971 net inflow and International migration shows a net inflow of 999 persons over the plan period.
Further detail is given in Appendix 1 pages 1 to 7.
Until the population targets are revised to the latest projections, the plan cannot be considered ready for submission to Inspection.
Explanation paragraph 2.7 in relation to DS2 commences by saying "The Council's ambitions align with national policy in recognising that housing needs are met for all. "
The parish council agrees that housing needs identified in the district based on up to date population projections should be met, but that the ambitions of the district must also be realistic. Planning practice Guidance on the definition of need, advises that
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 that there is a supply of sites for new housing is clearly necessary with affordable housing and housing that can be afforded being an important part of the plan.

But it is also important to comply with NPPF 157 Crucially, Local Plans should:
* plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework;
* identify land where development would be inappropriate, for instance because of its environmental or historic significance; and
* contain a clear strategy for enhancing the natural, built and historic environment, and supporting Nature Improvement Areas where they have been identified.

The projected population increase of 15,313 people will clearly require employment opportunities but it is also important to balance the jobs/homes ratio so that the current ratio, generally regarded as good, is maintained.

4.1 The plan has to be prepared in accordance with the Duty to Cooperate with Neighbouring authorities. This has been accomplished through a joint SHMA. The mid-2012 ONS Population projection has had a similar result for the Warwickshire Districts. There is however a possible problem with the Coventry result.

4.2 This table summarises the revised population growth and the number of dwellings resulting from the same dwelling density as the Joint SHMA. The joint SHMA identified a need for 67,536 homes. The revised projections now identify 68,152 homes.


Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 74,796 36,168 +70.4%
TOTAL HMA 123,882 67,536 129,751 68,152 +4.7%

4.3 Coventry's 2011 ONS population was 316,915 and is projected by 2029 to be 391,711. This is an increase of 74,796 over the plan period. This is made up from
* The net effect of natural change which accounts for 50,734 people by 2029.
* The net effect of people moving in and out of Coventry from other parts of the UK is a net outflow of 50,592 over the plan period.
* The net effect of international migration is an inflow of 74,654 over the plan period.
However, analysis of the numbers of people in single age groups for each year from 2002 to 2029 identifies two problems with this projection.
The first is that the 2 universities currently have about 13,500 international students. Most Coventry students and many Warwick University students live in Coventry. Looking at the 17 to 20, 21 to 24, 25 to 29 and 30 to 34 age groups it was found that there was in increase in these cohort numbers of International inflow from 2005 but not a corresponding outflow. Between 2002 and 2004 the net inflow was between 3400 and 3700. From 2005 inflow increased in significant steps to 7700 by 2011. In younger and older age groups the numbers remained fairly constant for the whole period. This reflected a time when universities sought to increase international students.
There was not a corresponding change in international outflow until 2009 to 2011 but the volume of the outflow was less that the volume of the inflow 3 years earlier. This indicates that the increase in inflow may be due to international students on courses that are not yet completed.
The problem for the population projection is that the higher inflow is reflected in the population projections because it takes the 6 year average from 2007 to 2012 with the higher numbers, but a related outflow at the completion of courses has not yet begun except at a lower level. It would be expected that as courses and related academic activities for each student came to an end then the outflow would approach the previous level of inflow. Hence the projection for outflow on the same 6 year average is based on a low level. This represents a temporary student bulge that in the course of time should rectify as student turn over numbers give equating inflows and outflows.
The 2002 to 2004 net inflow was between 1000 and 2000 per year, but by 2011 and 12, this had become over 5,000 per year.
In the meantime this gives an overall increase of 74,654 due to international migration over the 18 year plan period. It does not make sense to plan to build homes for a population that is theoretical and will not be there.
If the student bulge is factored out by relating student age groups to the younger and older age groups to estimate the possible non-student element, this indicates that the total number of 74,654 will fall to between 25,000 and 40,000 depending the averaging method used. Without any other detail data this is the closest estimate that can be given. Take the worst case of 40,000 inflow due to migration, then this is still lower than the migration inflow in the Joint SHMA of 43,884.
Hence, Coventry would still have a reduced requirement over the JointSHMA of almost 9%, which would indicate that Coventry is unlikely to seek to ask neighbouring authorities to meet its housing need.
The table below shows the result.
Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 40,000 19,344 -8.85%
TOTAL HMA 123,882 67,536 94,954 51,327 +4.7%

4.4 Further detail is given in Appendix 1 pages 12 to 16.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 2.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS6
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure the Inspector is fully aware of the implications of the method by which the 2012 population projections are converted to the number of dwellings required in the plan and that a fully justified housing need is objectively assessed.
___________________________________________________________________________


DS6 states that the District will provide 12,860 homes over the plan period. This has to relate to the population projection that the up to date assessment of population growth determines.

This number needs to be revised to comply with the reduction in population growth now known.

To convert population to homes, the JointSHMA used an abstract concept of Headship rates, based on information contained in the 2011-based CLG household projections about the relationship between the total population in an age group and the number of household reference persons (HRPs) in that age group. But this is only true at the time the data is taken. HRP's can be any age and are mobile. It can only be a subjective and not an objective assessment.

It is critical because small changes in the average household size can alter homes required significantly. The JointSHMA bases its chosen headship rate on an arbitrary split between 2008 and 2011 headship rates.

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 less communal residents is added to the Joint SHMA plan,, the 2029 population becomes 156,150 plus communal. The combined dwellings total 71,603 and the resultant household size is 2.181.This is a very low figure compared with the 2011 census.

Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 21,472 = 156,150
dwellings 58,679 + 12,924 = 71,603
Persons/household 2.295 = 2.181

If the population growth is going to be less, then the household size to use needs to be addressed.

The following options could be considered -

a) If the population of 15,313 is substituted in to the table above so that the household size in 2029 remains as 2.181, then 10,100 would be needed.

b) Proportionately, the revised population growth would require 9,217 homes producing an average household size of 2.209.

c) Using census data for 2001, the average household size excluding communal was 2.32. But the 2011 size was 2.295. If the size dropped at the same rate in the next 18 years it would become 2.245. If this is used for the revised population projection, the calculation becomes
Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 15,313 = 149,991
dwellings 58,679 + 8,118 = 66,797
Persons/household 2.295 = 2.245


d) However, there is no evidence that says that any drop in household size will be at the same rate. The closer that the size gets to 1, the slower will be the reducing rate of change. If the 2011 census rate of 2.295 prevails then 6,715 homes would provide for 15,313 people.

e) Because the built home is normally constant, the size and tenure of a house, on average over time, is a better indicator of household size than the variable HRP. Given that we know from the 2011 census the number of people in the number of house of each tenure type, we have an up to date household size for each dwelling type, for example, the average household size for a detached house or bungalow was 2.585.

Further details are given in Appendix 1 pages 8 to 11 where a calculation for a typical development takes the 2011 census data for each dwelling type adds on the densities arising from Affordable homes that will be allocated to match families to the number of bedrooms they need and the market housing developers have selected the type they want to include in their development. From Page 10 in the appendix, in the example given, the average household size calculates at 2.325. So the likelihood is that the household size will rise rather than fall. If it should rise to 2.325 over the whole of the 2029 population, then only 5,785 homes will be required.

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. This is what the NPPF6 means by "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system. 7. There are three dimensions to sustainable development: economic, social and Environmental all of which should be achieved simultaneously."
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 3.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS4, DS7, DS10, DS11, NE5
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that in the selection of sites for development, compliance with all NPPF matters from provision of housing and infrastructure to protecting Green Belt, conserving the natural and historic environment is achieved.
___________________________________________________________________________


DS7 identifies 13,014 sites for a plan of 12860 homes. This has to relate to the population projection that the up to date assessment of population growth determines, so that this number needs to be revised to comply with the reduction in population growth now known.

DS7 lists sites completed between 2011 and 2013 as 406. This conflicts with a previously published number of 447 in the June 2013 % year housing land supply document.

It makes no provision for the following
1. As PPG3-036 no allowance has been made to deduct oversupply of 687 made in years previous to the start date of Apr 2011 when completions of 5,947 compared with the target was 5,260.
2. Completions of 450 in the 2013/14 financial year, listed in the rough update April 2014 is not shown.
3. No allowance is made for completions since 1st April 2014.
4. An up to date assessment of sites under construction is not included.
5. No allowance has been included for vacant dwellings returned to use since1/4/11 to date, as reported to DCLG and upon which new homes bonus has been received by the District.
6. No allowance for vacant dwellings being returned to use through the remainder of the plan period has been included.


Explanation 2.22 states that the balance of housing outside of DS7 is to be provided on allocated brownfield and greenfield sites across the District. Reference is made to DS4.



Policy NE5 Protection of Natural Resources para d) includes reference to NPPF112 concerning best & most versatile agricultural land. It is a somewhat watered down version of NPPF112 that requires LPA's to take into account the economic and other benefits of the b&mv ag land. Even where significant development of b&mv ag land is identified, it has to be demonstrated that it is necessary and seek to use poorer quality land in preference to it. Explanation clause 5.198 expands NE5d) satisfactorily until it gets to the last few lines where it alters the sense of NPPF112 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 last phrase 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.


Explanation 2.23 states that the housing strategy shows a timeline for the delivery of housing across the plan period. 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 Spatial Strategy contains statements that are not being observed.

a) 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 any (except for affordable homes on Queensway) previously developed land within the urban areas? Regeneration and enhancement sites remain to be identified in principle let alone activation. The strategy is right, but its needs to be fully implemented.

b) 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.

DS10 and DS11 sets out a list of allocated housing sites.

Taking these lists and the current programme position, the sites have been listed in appendix 2. This appendix shows that 8,482 sites have been identified as -

1. 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 up to 8482 dwellings for this set of supply categories , then no further applications need to be granted to meet the plan as there is already a surplus provision. This applies to options c), 8,118 d), 6,615 & e) 5,785 in Representation 2 from Bishop's Tachbrook Parish Council.

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.


2. This applies to the following sites (See also APPENDIX 2)

Land west of Europa Way
East of Whitnash/south of Sydenham
Campion hills
East of Kenilworth (Thickthorn)
Both Kenilworth School sites.
All villages except Bishops Tachbrook, Barford and Radford Semele
Land south of Harbury Lane, including the former sewage works which is wrongly classified under Urban Brownfield sites. In any event this is a valuable green part of the Tachbrook Valley with a significant range of ecological biodiversity implications, a series of deep tanks across the site that would make any development difficult and a slope across the site which at the proximity of the Tach Brook turns into a steep slope. It is well planted and supports a number of mammals. Otters are known in the brook.
The photo below shows the former sewage works. This is not urban brownfield.


3. The list also shows
* Grove Farm at 200 dwellings which is currently subject to appeal after refusal,
* future vacant dwellings return and
* a list of 543 C2 homes for the elderly, all of which can be counted towards the housing supply in accordance with PPG3-037.
037 How should local planning authorities deal with housing for older people?
Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.
With these it would no longer be necessary to keep the sensitive urban brownfield and sensitive greenfield shown at the end of appendix 2 in DS11.

So the 3 Kenilworth sites, land west of Europa Way and East of Whitnash/ south of Sydenham do not need to be included.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 4.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS13
5. Do you consider the Local Plan is :
5.1 Legally Compliant? Don't know
5.2 Complies with the Duty to Co-operate? No
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that best and most versatile agricultural land is protected sufficiently to conserve and enhance the Natural Environment
___________________________________________________________________________

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.

As part of the duty to cooperate, the District Council should work with the Parish Council, as we prepare our Neighbourhood Plan and in accordance with Policy NP2 stating that the Council will support communities preparing Neighbourhood Plans.

The developing Neighbourhood plan seeks to retain the agricultural economy of the land between Harbury Lane and the Tach Brook but at the same time open the area up in a limited way with a brookstray walk and habitat improvement for wildlife possibly through an extended Defra/ Natural England Stewardship scheme and a Local Greenspace designation over those stewardship areas. This could achieve the objectives in Explanation paras 2.57 but not commit to the expensive country park concept.

We doubt that the £1.5m needed to set up a Country Park, which will require car parks and facilities for the public, becoming urbanised and less friendly to wildlife, 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.




Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact.
Representation 5.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DM1
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that the Local Plan has been prepared to a realistic level that can be supported by adequate income from developments CIL and other government payments such as new homes bonus to ensure that the additional infrastructure necessary to accommodate the increased population of 15,313 people
___________________________________________________________________________

It is an important part of the local plan that the necessary infrastructure required to support the additional population has been fully identified , addressed in the plan as to where and how it will be delivered and that the costs have been assessed and a financial plan for their delivery determined.

An independent assessment of the plan for 12860 homes has been carried out by professionals concerned that this aspect is not properly covered, since the result of an inadequate financial plan would mean 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.

DM1 says it will happen but there does not appear to be a plan in place to ensure that it does. If this is the case, then the inspector, who will have to ensure that such a plan is in place, will find that it doesn't and the plan will be found unsound.

However the amount of infrastructure necessary will depend on the population to be planned for, the housing numbers necessary to meet that need and the location of housing.

Across the district currently, much of the infrastructure is fairly fully stretched. Major items such Education, Hospitals and road networks are heavily utilised. But there are parts where there is some spare capacity that new developments can utilise.

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.

For the 12,860 homes plan, our independent assessment indicates that the costs of the infrastructure required will be between £30m to £50m more than the income that will be received from section 106, CIL(when it applies), new homes bonus and other sundry incomes. This is on the assumption that the infrastructure costs are capital costs and that the revenue running costs will be met from income generated from Council tax and similar receipts.

In our assessment we have included the costs of road traffic schemes due to high concentrations of new traffic in underprovided areas, Health and hospitals, Education, sports facilities, recreational facilities , cultural and community , police and emergency services as well as parking provision for the additional users of the towns. All 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.

It will be appreciated that doing this exercise from outside the authority, much of the detail necessary is not available and it is dependent on published information from the District Councils website as to the amounts of payments so far agreed with developers on the early schemes.

Although the plan is for 12860 homes, many of these will not be paying contributions because they have been approved in advance of the programme, are affordable homes so will not be liable for payments and are part of small schemes for which 106 payments are not sought.

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. Some elements are population number dependent but lower numbers mean a smaller impact on them.

Depending on the housing number decided the assessment will to be reworked. Until thenthe plan does not have a sound infrastructure cost strategy.

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.
Paragraph: 037 Reference ID: 3-037-20140306

Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 1.
1. In responding to this consultation, the Parish Council emphasises that its sole interest is to help devise a Local Plan that is positively prepared, justified, effective and consistent with national policy, complying with the National Planning Policy Framework and the Planning Practice Guidelines published in March 2014.
2 It is our belief however that draft Local Plan is not sound in a number of aspects.
But over-riding all the matters is the fact that because the plan is based on the joint SHMA, it was only able to use the mid-2011 ONS Population Projections when it was prepared.
On the 29th May 2014, the ONS published the mid-2012 population projections. As we indicated to you at the Planning Forum before the publication draft was approved by the District Council on April 23rd, the new projections show a very significant reduction in population projection for the plan period up to 2029.
3. National planning policy places Local Plans at the heart of the planning system, so it is essential that they are in place and kept up to date. PPG12-001, NPPF157 * 2.
To start a new Local Plan based on outdated data cannot be seen as a sound plan and an Inspector will have to conclude that procedural requirements have not been met and question whether the Plan is sound.
For Warwick District, the joint SHMA uses for Proj 1A a population growth of 23,858 over 20 years, this being 21,472 over 18 years. The mid-2012 ONS projection for 2029 is 153,049, which is a population growth of 15,313 from mid 2011. This is 28.7% less than the Joint SHMA.
This is a very significant change since, amongst other things, it
* Changes the number of dwellings to meet local need
* The lower population will need commensurately less infrastructure support, optimising the use of capacity in existing infrastructure
* Changes the emphasis on the selection of sites for new housing
* Allows brownfield and regeneration sites to be committed before greenfield sites meeting NPPF112 and PPG8-026 and this also places less pressure on Green Belt.
* Can provide a deliverable plan rather than a plan that is too ambitious and unrealistic in the period of the plan
The new projections indicate that 8,343 persons are due to natural change; movement between Warwick District and the rest of the UK account for 5,971 net inflow and International migration shows a net inflow of 999 persons over the plan period.
Further detail is given in Appendix 1 pages 1 to 7.
Until the population targets are revised to the latest projections, the plan cannot be considered ready for submission to Inspection.
Explanation paragraph 2.7 in relation to DS2 commences by saying "The Council's ambitions align with national policy in recognising that housing needs are met for all. "
The parish council agrees that housing needs identified in the district based on up to date population projections should be met, but that the ambitions of the district must also be realistic. Planning practice Guidance on the definition of need, advises that
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 that there is a supply of sites for new housing is clearly necessary with affordable housing and housing that can be afforded being an important part of the plan.

But it is also important to comply with NPPF 157 Crucially, Local Plans should:
* plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework;
* identify land where development would be inappropriate, for instance because of its environmental or historic significance; and
* contain a clear strategy for enhancing the natural, built and historic environment, and supporting Nature Improvement Areas where they have been identified.

The projected population increase of 15,313 people will clearly require employment opportunities but it is also important to balance the jobs/homes ratio so that the current ratio, generally regarded as good, is maintained.

4.1 The plan has to be prepared in accordance with the Duty to Cooperate with Neighbouring authorities. This has been accomplished through a joint SHMA. The mid-2012 ONS Population projection has had a similar result for the Warwickshire Districts. There is however a possible problem with the Coventry result.

4.2 This table summarises the revised population growth and the number of dwellings resulting from the same dwelling density as the Joint SHMA. The joint SHMA identified a need for 67,536 homes. The revised projections now identify 68,152 homes.


Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 74,796 36,168 +70.4%
TOTAL HMA 123,882 67,536 129,751 68,152 +4.7%

4.3 Coventry's 2011 ONS population was 316,915 and is projected by 2029 to be 391,711. This is an increase of 74,796 over the plan period. This is made up from
* The net effect of natural change which accounts for 50,734 people by 2029.
* The net effect of people moving in and out of Coventry from other parts of the UK is a net outflow of 50,592 over the plan period.
* The net effect of international migration is an inflow of 74,654 over the plan period.
However, analysis of the numbers of people in single age groups for each year from 2002 to 2029 identifies two problems with this projection.
The first is that the 2 universities currently have about 13,500 international students. Most Coventry students and many Warwick University students live in Coventry. Looking at the 17 to 20, 21 to 24, 25 to 29 and 30 to 34 age groups it was found that there was in increase in these cohort numbers of International inflow from 2005 but not a corresponding outflow. Between 2002 and 2004 the net inflow was between 3400 and 3700. From 2005 inflow increased in significant steps to 7700 by 2011. In younger and older age groups the numbers remained fairly constant for the whole period. This reflected a time when universities sought to increase international students.
There was not a corresponding change in international outflow until 2009 to 2011 but the volume of the outflow was less that the volume of the inflow 3 years earlier. This indicates that the increase in inflow may be due to international students on courses that are not yet completed.
The problem for the population projection is that the higher inflow is reflected in the population projections because it takes the 6 year average from 2007 to 2012 with the higher numbers, but a related outflow at the completion of courses has not yet begun except at a lower level. It would be expected that as courses and related academic activities for each student came to an end then the outflow would approach the previous level of inflow. Hence the projection for outflow on the same 6 year average is based on a low level. This represents a temporary student bulge that in the course of time should rectify as student turn over numbers give equating inflows and outflows.
The 2002 to 2004 net inflow was between 1000 and 2000 per year, but by 2011 and 12, this had become over 5,000 per year.
In the meantime this gives an overall increase of 74,654 due to international migration over the 18 year plan period. It does not make sense to plan to build homes for a population that is theoretical and will not be there.
If the student bulge is factored out by relating student age groups to the younger and older age groups to estimate the possible non-student element, this indicates that the total number of 74,654 will fall to between 25,000 and 40,000 depending the averaging method used. Without any other detail data this is the closest estimate that can be given. Take the worst case of 40,000 inflow due to migration, then this is still lower than the migration inflow in the Joint SHMA of 43,884.
Hence, Coventry would still have a reduced requirement over the JointSHMA of almost 9%, which would indicate that Coventry is unlikely to seek to ask neighbouring authorities to meet its housing need.
The table below shows the result.
Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 40,000 19,344 -8.85%
TOTAL HMA 123,882 67,536 94,954 51,327 +4.7%

4.4 Further detail is given in Appendix 1 pages 12 to 16.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 2.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS6
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure the Inspector is fully aware of the implications of the method by which the 2012 population projections are converted to the number of dwellings required in the plan and that a fully justified housing need is objectively assessed.
___________________________________________________________________________


DS6 states that the District will provide 12,860 homes over the plan period. This has to relate to the population projection that the up to date assessment of population growth determines.

This number needs to be revised to comply with the reduction in population growth now known.

To convert population to homes, the JointSHMA used an abstract concept of Headship rates, based on information contained in the 2011-based CLG household projections about the relationship between the total population in an age group and the number of household reference persons (HRPs) in that age group. But this is only true at the time the data is taken. HRP's can be any age and are mobile. It can only be a subjective and not an objective assessment.

It is critical because small changes in the average household size can alter homes required significantly. The JointSHMA bases its chosen headship rate on an arbitrary split between 2008 and 2011 headship rates.

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 less communal residents is added to the Joint SHMA plan,, the 2029 population becomes 156,150 plus communal. The combined dwellings total 71,603 and the resultant household size is 2.181.This is a very low figure compared with the 2011 census.

Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 21,472 = 156,150
dwellings 58,679 + 12,924 = 71,603
Persons/household 2.295 = 2.181

If the population growth is going to be less, then the household size to use needs to be addressed.

The following options could be considered -

a) If the population of 15,313 is substituted in to the table above so that the household size in 2029 remains as 2.181, then 10,100 would be needed.

b) Proportionately, the revised population growth would require 9,217 homes producing an average household size of 2.209.

c) Using census data for 2001, the average household size excluding communal was 2.32. But the 2011 size was 2.295. If the size dropped at the same rate in the next 18 years it would become 2.245. If this is used for the revised population projection, the calculation becomes
Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 15,313 = 149,991
dwellings 58,679 + 8,118 = 66,797
Persons/household 2.295 = 2.245


d) However, there is no evidence that says that any drop in household size will be at the same rate. The closer that the size gets to 1, the slower will be the reducing rate of change. If the 2011 census rate of 2.295 prevails then 6,715 homes would provide for 15,313 people.

e) Because the built home is normally constant, the size and tenure of a house, on average over time, is a better indicator of household size than the variable HRP. Given that we know from the 2011 census the number of people in the number of house of each tenure type, we have an up to date household size for each dwelling type, for example, the average household size for a detached house or bungalow was 2.585.

Further details are given in Appendix 1 pages 8 to 11 where a calculation for a typical development takes the 2011 census data for each dwelling type adds on the densities arising from Affordable homes that will be allocated to match families to the number of bedrooms they need and the market housing developers have selected the type they want to include in their development. From Page 10 in the appendix, in the example given, the average household size calculates at 2.325. So the likelihood is that the household size will rise rather than fall. If it should rise to 2.325 over the whole of the 2029 population, then only 5,785 homes will be required.

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. This is what the NPPF6 means by "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system. 7. There are three dimensions to sustainable development: economic, social and Environmental all of which should be achieved simultaneously."
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 3.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS4, DS7, DS10, DS11, NE5
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that in the selection of sites for development, compliance with all NPPF matters from provision of housing and infrastructure to protecting Green Belt, conserving the natural and historic environment is achieved.
___________________________________________________________________________


DS7 identifies 13,014 sites for a plan of 12860 homes. This has to relate to the population projection that the up to date assessment of population growth determines, so that this number needs to be revised to comply with the reduction in population growth now known.

DS7 lists sites completed between 2011 and 2013 as 406. This conflicts with a previously published number of 447 in the June 2013 % year housing land supply document.

It makes no provision for the following
1. As PPG3-036 no allowance has been made to deduct oversupply of 687 made in years previous to the start date of Apr 2011 when completions of 5,947 compared with the target was 5,260.
2. Completions of 450 in the 2013/14 financial year, listed in the rough update April 2014 is not shown.
3. No allowance is made for completions since 1st April 2014.
4. An up to date assessment of sites under construction is not included.
5. No allowance has been included for vacant dwellings returned to use since1/4/11 to date, as reported to DCLG and upon which new homes bonus has been received by the District.
6. No allowance for vacant dwellings being returned to use through the remainder of the plan period has been included.


Explanation 2.22 states that the balance of housing outside of DS7 is to be provided on allocated brownfield and greenfield sites across the District. Reference is made to DS4.



Policy NE5 Protection of Natural Resources para d) includes reference to NPPF112 concerning best & most versatile agricultural land. It is a somewhat watered down version of NPPF112 that requires LPA's to take into account the economic and other benefits of the b&mv ag land. Even where significant development of b&mv ag land is identified, it has to be demonstrated that it is necessary and seek to use poorer quality land in preference to it. Explanation clause 5.198 expands NE5d) satisfactorily until it gets to the last few lines where it alters the sense of NPPF112 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 last phrase 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.


Explanation 2.23 states that the housing strategy shows a timeline for the delivery of housing across the plan period. 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 Spatial Strategy contains statements that are not being observed.

a) 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 any (except for affordable homes on Queensway) previously developed land within the urban areas? Regeneration and enhancement sites remain to be identified in principle let alone activation. The strategy is right, but its needs to be fully implemented.

b) 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.

DS10 and DS11 sets out a list of allocated housing sites.

Taking these lists and the current programme position, the sites have been listed in appendix 2. This appendix shows that 8,482 sites have been identified as -

1. 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 up to 8482 dwellings for this set of supply categories , then no further applications need to be granted to meet the plan as there is already a surplus provision. This applies to options c), 8,118 d), 6,615 & e) 5,785 in Representation 2 from Bishop's Tachbrook Parish Council.

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.


2. This applies to the following sites (See also APPENDIX 2)

Land west of Europa Way
East of Whitnash/south of Sydenham
Campion hills
East of Kenilworth (Thickthorn)
Both Kenilworth School sites.
All villages except Bishops Tachbrook, Barford and Radford Semele
Land south of Harbury Lane, including the former sewage works which is wrongly classified under Urban Brownfield sites. In any event this is a valuable green part of the Tachbrook Valley with a significant range of ecological biodiversity implications, a series of deep tanks across the site that would make any development difficult and a slope across the site which at the proximity of the Tach Brook turns into a steep slope. It is well planted and supports a number of mammals. Otters are known in the brook.
The photo below shows the former sewage works. This is not urban brownfield.


3. The list also shows
* Grove Farm at 200 dwellings which is currently subject to appeal after refusal,
* future vacant dwellings return and
* a list of 543 C2 homes for the elderly, all of which can be counted towards the housing supply in accordance with PPG3-037.
037 How should local planning authorities deal with housing for older people?
Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.
With these it would no longer be necessary to keep the sensitive urban brownfield and sensitive greenfield shown at the end of appendix 2 in DS11.

So the 3 Kenilworth sites, land west of Europa Way and East of Whitnash/ south of Sydenham do not need to be included.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 4.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS13
5. Do you consider the Local Plan is :
5.1 Legally Compliant? Don't know
5.2 Complies with the Duty to Co-operate? No
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that best and most versatile agricultural land is protected sufficiently to conserve and enhance the Natural Environment
___________________________________________________________________________

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.

As part of the duty to cooperate, the District Council should work with the Parish Council, as we prepare our Neighbourhood Plan and in accordance with Policy NP2 stating that the Council will support communities preparing Neighbourhood Plans.

The developing Neighbourhood plan seeks to retain the agricultural economy of the land between Harbury Lane and the Tach Brook but at the same time open the area up in a limited way with a brookstray walk and habitat improvement for wildlife possibly through an extended Defra/ Natural England Stewardship scheme and a Local Greenspace designation over those stewardship areas. This could achieve the objectives in Explanation paras 2.57 but not commit to the expensive country park concept.

We doubt that the £1.5m needed to set up a Country Park, which will require car parks and facilities for the public, becoming urbanised and less friendly to wildlife, 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.




Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact.
Representation 5.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DM1
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that the Local Plan has been prepared to a realistic level that can be supported by adequate income from developments CIL and other government payments such as new homes bonus to ensure that the additional infrastructure necessary to accommodate the increased population of 15,313 people
___________________________________________________________________________

It is an important part of the local plan that the necessary infrastructure required to support the additional population has been fully identified , addressed in the plan as to where and how it will be delivered and that the costs have been assessed and a financial plan for their delivery determined.

An independent assessment of the plan for 12860 homes has been carried out by professionals concerned that this aspect is not properly covered, since the result of an inadequate financial plan would mean 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.

DM1 says it will happen but there does not appear to be a plan in place to ensure that it does. If this is the case, then the inspector, who will have to ensure that such a plan is in place, will find that it doesn't and the plan will be found unsound.

However the amount of infrastructure necessary will depend on the population to be planned for, the housing numbers necessary to meet that need and the location of housing.

Across the district currently, much of the infrastructure is fairly fully stretched. Major items such Education, Hospitals and road networks are heavily utilised. But there are parts where there is some spare capacity that new developments can utilise.

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.

For the 12,860 homes plan, our independent assessment indicates that the costs of the infrastructure required will be between £30m to £50m more than the income that will be received from section 106, CIL(when it applies), new homes bonus and other sundry incomes. This is on the assumption that the infrastructure costs are capital costs and that the revenue running costs will be met from income generated from Council tax and similar receipts.

In our assessment we have included the costs of road traffic schemes due to high concentrations of new traffic in underprovided areas, Health and hospitals, Education, sports facilities, recreational facilities , cultural and community , police and emergency services as well as parking provision for the additional users of the towns. All 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.

It will be appreciated that doing this exercise from outside the authority, much of the detail necessary is not available and it is dependent on published information from the District Councils website as to the amounts of payments so far agreed with developers on the early schemes.

Although the plan is for 12860 homes, many of these will not be paying contributions because they have been approved in advance of the programme, are affordable homes so will not be liable for payments and are part of small schemes for which 106 payments are not sought.

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. Some elements are population number dependent but lower numbers mean a smaller impact on them.

Depending on the housing number decided the assessment will to be reworked. Until thenthe plan does not have a sound infrastructure cost strategy.

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.
Paragraph: 037 Reference ID: 3-037-20140306

Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 1.
1. In responding to this consultation, the Parish Council emphasises that its sole interest is to help devise a Local Plan that is positively prepared, justified, effective and consistent with national policy, complying with the National Planning Policy Framework and the Planning Practice Guidelines published in March 2014.
2 It is our belief however that draft Local Plan is not sound in a number of aspects.
But over-riding all the matters is the fact that because the plan is based on the joint SHMA, it was only able to use the mid-2011 ONS Population Projections when it was prepared.
On the 29th May 2014, the ONS published the mid-2012 population projections. As we indicated to you at the Planning Forum before the publication draft was approved by the District Council on April 23rd, the new projections show a very significant reduction in population projection for the plan period up to 2029.
3. National planning policy places Local Plans at the heart of the planning system, so it is essential that they are in place and kept up to date. PPG12-001, NPPF157 * 2.
To start a new Local Plan based on outdated data cannot be seen as a sound plan and an Inspector will have to conclude that procedural requirements have not been met and question whether the Plan is sound.
For Warwick District, the joint SHMA uses for Proj 1A a population growth of 23,858 over 20 years, this being 21,472 over 18 years. The mid-2012 ONS projection for 2029 is 153,049, which is a population growth of 15,313 from mid 2011. This is 28.7% less than the Joint SHMA.
This is a very significant change since, amongst other things, it
* Changes the number of dwellings to meet local need
* The lower population will need commensurately less infrastructure support, optimising the use of capacity in existing infrastructure
* Changes the emphasis on the selection of sites for new housing
* Allows brownfield and regeneration sites to be committed before greenfield sites meeting NPPF112 and PPG8-026 and this also places less pressure on Green Belt.
* Can provide a deliverable plan rather than a plan that is too ambitious and unrealistic in the period of the plan
The new projections indicate that 8,343 persons are due to natural change; movement between Warwick District and the rest of the UK account for 5,971 net inflow and International migration shows a net inflow of 999 persons over the plan period.
Further detail is given in Appendix 1 pages 1 to 7.
Until the population targets are revised to the latest projections, the plan cannot be considered ready for submission to Inspection.
Explanation paragraph 2.7 in relation to DS2 commences by saying "The Council's ambitions align with national policy in recognising that housing needs are met for all. "
The parish council agrees that housing needs identified in the district based on up to date population projections should be met, but that the ambitions of the district must also be realistic. Planning practice Guidance on the definition of need, advises that
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 that there is a supply of sites for new housing is clearly necessary with affordable housing and housing that can be afforded being an important part of the plan.

But it is also important to comply with NPPF 157 Crucially, Local Plans should:
* plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework;
* identify land where development would be inappropriate, for instance because of its environmental or historic significance; and
* contain a clear strategy for enhancing the natural, built and historic environment, and supporting Nature Improvement Areas where they have been identified.

The projected population increase of 15,313 people will clearly require employment opportunities but it is also important to balance the jobs/homes ratio so that the current ratio, generally regarded as good, is maintained.

4.1 The plan has to be prepared in accordance with the Duty to Cooperate with Neighbouring authorities. This has been accomplished through a joint SHMA. The mid-2012 ONS Population projection has had a similar result for the Warwickshire Districts. There is however a possible problem with the Coventry result.

4.2 This table summarises the revised population growth and the number of dwellings resulting from the same dwelling density as the Joint SHMA. The joint SHMA identified a need for 67,536 homes. The revised projections now identify 68,152 homes.


Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 74,796 36,168 +70.4%
TOTAL HMA 123,882 67,536 129,751 68,152 +4.7%

4.3 Coventry's 2011 ONS population was 316,915 and is projected by 2029 to be 391,711. This is an increase of 74,796 over the plan period. This is made up from
* The net effect of natural change which accounts for 50,734 people by 2029.
* The net effect of people moving in and out of Coventry from other parts of the UK is a net outflow of 50,592 over the plan period.
* The net effect of international migration is an inflow of 74,654 over the plan period.
However, analysis of the numbers of people in single age groups for each year from 2002 to 2029 identifies two problems with this projection.
The first is that the 2 universities currently have about 13,500 international students. Most Coventry students and many Warwick University students live in Coventry. Looking at the 17 to 20, 21 to 24, 25 to 29 and 30 to 34 age groups it was found that there was in increase in these cohort numbers of International inflow from 2005 but not a corresponding outflow. Between 2002 and 2004 the net inflow was between 3400 and 3700. From 2005 inflow increased in significant steps to 7700 by 2011. In younger and older age groups the numbers remained fairly constant for the whole period. This reflected a time when universities sought to increase international students.
There was not a corresponding change in international outflow until 2009 to 2011 but the volume of the outflow was less that the volume of the inflow 3 years earlier. This indicates that the increase in inflow may be due to international students on courses that are not yet completed.
The problem for the population projection is that the higher inflow is reflected in the population projections because it takes the 6 year average from 2007 to 2012 with the higher numbers, but a related outflow at the completion of courses has not yet begun except at a lower level. It would be expected that as courses and related academic activities for each student came to an end then the outflow would approach the previous level of inflow. Hence the projection for outflow on the same 6 year average is based on a low level. This represents a temporary student bulge that in the course of time should rectify as student turn over numbers give equating inflows and outflows.
The 2002 to 2004 net inflow was between 1000 and 2000 per year, but by 2011 and 12, this had become over 5,000 per year.
In the meantime this gives an overall increase of 74,654 due to international migration over the 18 year plan period. It does not make sense to plan to build homes for a population that is theoretical and will not be there.
If the student bulge is factored out by relating student age groups to the younger and older age groups to estimate the possible non-student element, this indicates that the total number of 74,654 will fall to between 25,000 and 40,000 depending the averaging method used. Without any other detail data this is the closest estimate that can be given. Take the worst case of 40,000 inflow due to migration, then this is still lower than the migration inflow in the Joint SHMA of 43,884.
Hence, Coventry would still have a reduced requirement over the JointSHMA of almost 9%, which would indicate that Coventry is unlikely to seek to ask neighbouring authorities to meet its housing need.
The table below shows the result.
Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 40,000 19,344 -8.85%
TOTAL HMA 123,882 67,536 94,954 51,327 +4.7%

4.4 Further detail is given in Appendix 1 pages 12 to 16.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 2.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS6
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure the Inspector is fully aware of the implications of the method by which the 2012 population projections are converted to the number of dwellings required in the plan and that a fully justified housing need is objectively assessed.
___________________________________________________________________________


DS6 states that the District will provide 12,860 homes over the plan period. This has to relate to the population projection that the up to date assessment of population growth determines.

This number needs to be revised to comply with the reduction in population growth now known.

To convert population to homes, the JointSHMA used an abstract concept of Headship rates, based on information contained in the 2011-based CLG household projections about the relationship between the total population in an age group and the number of household reference persons (HRPs) in that age group. But this is only true at the time the data is taken. HRP's can be any age and are mobile. It can only be a subjective and not an objective assessment.

It is critical because small changes in the average household size can alter homes required significantly. The JointSHMA bases its chosen headship rate on an arbitrary split between 2008 and 2011 headship rates.

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 less communal residents is added to the Joint SHMA plan,, the 2029 population becomes 156,150 plus communal. The combined dwellings total 71,603 and the resultant household size is 2.181.This is a very low figure compared with the 2011 census.

Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 21,472 = 156,150
dwellings 58,679 + 12,924 = 71,603
Persons/household 2.295 = 2.181

If the population growth is going to be less, then the household size to use needs to be addressed.

The following options could be considered -

a) If the population of 15,313 is substituted in to the table above so that the household size in 2029 remains as 2.181, then 10,100 would be needed.

b) Proportionately, the revised population growth would require 9,217 homes producing an average household size of 2.209.

c) Using census data for 2001, the average household size excluding communal was 2.32. But the 2011 size was 2.295. If the size dropped at the same rate in the next 18 years it would become 2.245. If this is used for the revised population projection, the calculation becomes
Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 15,313 = 149,991
dwellings 58,679 + 8,118 = 66,797
Persons/household 2.295 = 2.245


d) However, there is no evidence that says that any drop in household size will be at the same rate. The closer that the size gets to 1, the slower will be the reducing rate of change. If the 2011 census rate of 2.295 prevails then 6,715 homes would provide for 15,313 people.

e) Because the built home is normally constant, the size and tenure of a house, on average over time, is a better indicator of household size than the variable HRP. Given that we know from the 2011 census the number of people in the number of house of each tenure type, we have an up to date household size for each dwelling type, for example, the average household size for a detached house or bungalow was 2.585.

Further details are given in Appendix 1 pages 8 to 11 where a calculation for a typical development takes the 2011 census data for each dwelling type adds on the densities arising from Affordable homes that will be allocated to match families to the number of bedrooms they need and the market housing developers have selected the type they want to include in their development. From Page 10 in the appendix, in the example given, the average household size calculates at 2.325. So the likelihood is that the household size will rise rather than fall. If it should rise to 2.325 over the whole of the 2029 population, then only 5,785 homes will be required.

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. This is what the NPPF6 means by "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system. 7. There are three dimensions to sustainable development: economic, social and Environmental all of which should be achieved simultaneously."
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 3.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS4, DS7, DS10, DS11, NE5
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that in the selection of sites for development, compliance with all NPPF matters from provision of housing and infrastructure to protecting Green Belt, conserving the natural and historic environment is achieved.
___________________________________________________________________________


DS7 identifies 13,014 sites for a plan of 12860 homes. This has to relate to the population projection that the up to date assessment of population growth determines, so that this number needs to be revised to comply with the reduction in population growth now known.

DS7 lists sites completed between 2011 and 2013 as 406. This conflicts with a previously published number of 447 in the June 2013 % year housing land supply document.

It makes no provision for the following
1. As PPG3-036 no allowance has been made to deduct oversupply of 687 made in years previous to the start date of Apr 2011 when completions of 5,947 compared with the target was 5,260.
2. Completions of 450 in the 2013/14 financial year, listed in the rough update April 2014 is not shown.
3. No allowance is made for completions since 1st April 2014.
4. An up to date assessment of sites under construction is not included.
5. No allowance has been included for vacant dwellings returned to use since1/4/11 to date, as reported to DCLG and upon which new homes bonus has been received by the District.
6. No allowance for vacant dwellings being returned to use through the remainder of the plan period has been included.


Explanation 2.22 states that the balance of housing outside of DS7 is to be provided on allocated brownfield and greenfield sites across the District. Reference is made to DS4.



Policy NE5 Protection of Natural Resources para d) includes reference to NPPF112 concerning best & most versatile agricultural land. It is a somewhat watered down version of NPPF112 that requires LPA's to take into account the economic and other benefits of the b&mv ag land. Even where significant development of b&mv ag land is identified, it has to be demonstrated that it is necessary and seek to use poorer quality land in preference to it. Explanation clause 5.198 expands NE5d) satisfactorily until it gets to the last few lines where it alters the sense of NPPF112 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 last phrase 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.


Explanation 2.23 states that the housing strategy shows a timeline for the delivery of housing across the plan period. 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 Spatial Strategy contains statements that are not being observed.

a) 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 any (except for affordable homes on Queensway) previously developed land within the urban areas? Regeneration and enhancement sites remain to be identified in principle let alone activation. The strategy is right, but its needs to be fully implemented.

b) 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.

DS10 and DS11 sets out a list of allocated housing sites.

Taking these lists and the current programme position, the sites have been listed in appendix 2. This appendix shows that 8,482 sites have been identified as -

1. 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 up to 8482 dwellings for this set of supply categories , then no further applications need to be granted to meet the plan as there is already a surplus provision. This applies to options c), 8,118 d), 6,615 & e) 5,785 in Representation 2 from Bishop's Tachbrook Parish Council.

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.


2. This applies to the following sites (See also APPENDIX 2)

Land west of Europa Way
East of Whitnash/south of Sydenham
Campion hills
East of Kenilworth (Thickthorn)
Both Kenilworth School sites.
All villages except Bishops Tachbrook, Barford and Radford Semele
Land south of Harbury Lane, including the former sewage works which is wrongly classified under Urban Brownfield sites. In any event this is a valuable green part of the Tachbrook Valley with a significant range of ecological biodiversity implications, a series of deep tanks across the site that would make any development difficult and a slope across the site which at the proximity of the Tach Brook turns into a steep slope. It is well planted and supports a number of mammals. Otters are known in the brook.
The photo below shows the former sewage works. This is not urban brownfield.


3. The list also shows
* Grove Farm at 200 dwellings which is currently subject to appeal after refusal,
* future vacant dwellings return and
* a list of 543 C2 homes for the elderly, all of which can be counted towards the housing supply in accordance with PPG3-037.
037 How should local planning authorities deal with housing for older people?
Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.
With these it would no longer be necessary to keep the sensitive urban brownfield and sensitive greenfield shown at the end of appendix 2 in DS11.

So the 3 Kenilworth sites, land west of Europa Way and East of Whitnash/ south of Sydenham do not need to be included.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 4.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS13
5. Do you consider the Local Plan is :
5.1 Legally Compliant? Don't know
5.2 Complies with the Duty to Co-operate? No
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that best and most versatile agricultural land is protected sufficiently to conserve and enhance the Natural Environment
___________________________________________________________________________

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.

As part of the duty to cooperate, the District Council should work with the Parish Council, as we prepare our Neighbourhood Plan and in accordance with Policy NP2 stating that the Council will support communities preparing Neighbourhood Plans.

The developing Neighbourhood plan seeks to retain the agricultural economy of the land between Harbury Lane and the Tach Brook but at the same time open the area up in a limited way with a brookstray walk and habitat improvement for wildlife possibly through an extended Defra/ Natural England Stewardship scheme and a Local Greenspace designation over those stewardship areas. This could achieve the objectives in Explanation paras 2.57 but not commit to the expensive country park concept.

We doubt that the £1.5m needed to set up a Country Park, which will require car parks and facilities for the public, becoming urbanised and less friendly to wildlife, 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.




Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact.
Representation 5.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DM1
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that the Local Plan has been prepared to a realistic level that can be supported by adequate income from developments CIL and other government payments such as new homes bonus to ensure that the additional infrastructure necessary to accommodate the increased population of 15,313 people
___________________________________________________________________________

It is an important part of the local plan that the necessary infrastructure required to support the additional population has been fully identified , addressed in the plan as to where and how it will be delivered and that the costs have been assessed and a financial plan for their delivery determined.

An independent assessment of the plan for 12860 homes has been carried out by professionals concerned that this aspect is not properly covered, since the result of an inadequate financial plan would mean 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.

DM1 says it will happen but there does not appear to be a plan in place to ensure that it does. If this is the case, then the inspector, who will have to ensure that such a plan is in place, will find that it doesn't and the plan will be found unsound.

However the amount of infrastructure necessary will depend on the population to be planned for, the housing numbers necessary to meet that need and the location of housing.

Across the district currently, much of the infrastructure is fairly fully stretched. Major items such Education, Hospitals and road networks are heavily utilised. But there are parts where there is some spare capacity that new developments can utilise.

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.

For the 12,860 homes plan, our independent assessment indicates that the costs of the infrastructure required will be between £30m to £50m more than the income that will be received from section 106, CIL(when it applies), new homes bonus and other sundry incomes. This is on the assumption that the infrastructure costs are capital costs and that the revenue running costs will be met from income generated from Council tax and similar receipts.

In our assessment we have included the costs of road traffic schemes due to high concentrations of new traffic in underprovided areas, Health and hospitals, Education, sports facilities, recreational facilities , cultural and community , police and emergency services as well as parking provision for the additional users of the towns. All 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.

It will be appreciated that doing this exercise from outside the authority, much of the detail necessary is not available and it is dependent on published information from the District Councils website as to the amounts of payments so far agreed with developers on the early schemes.

Although the plan is for 12860 homes, many of these will not be paying contributions because they have been approved in advance of the programme, are affordable homes so will not be liable for payments and are part of small schemes for which 106 payments are not sought.

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. Some elements are population number dependent but lower numbers mean a smaller impact on them.

Depending on the housing number decided the assessment will to be reworked. Until thenthe plan does not have a sound infrastructure cost strategy.

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.
Paragraph: 037 Reference ID: 3-037-20140306

Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 1.
1. In responding to this consultation, the Parish Council emphasises that its sole interest is to help devise a Local Plan that is positively prepared, justified, effective and consistent with national policy, complying with the National Planning Policy Framework and the Planning Practice Guidelines published in March 2014.
2 It is our belief however that draft Local Plan is not sound in a number of aspects.
But over-riding all the matters is the fact that because the plan is based on the joint SHMA, it was only able to use the mid-2011 ONS Population Projections when it was prepared.
On the 29th May 2014, the ONS published the mid-2012 population projections. As we indicated to you at the Planning Forum before the publication draft was approved by the District Council on April 23rd, the new projections show a very significant reduction in population projection for the plan period up to 2029.
3. National planning policy places Local Plans at the heart of the planning system, so it is essential that they are in place and kept up to date. PPG12-001, NPPF157 * 2.
To start a new Local Plan based on outdated data cannot be seen as a sound plan and an Inspector will have to conclude that procedural requirements have not been met and question whether the Plan is sound.
For Warwick District, the joint SHMA uses for Proj 1A a population growth of 23,858 over 20 years, this being 21,472 over 18 years. The mid-2012 ONS projection for 2029 is 153,049, which is a population growth of 15,313 from mid 2011. This is 28.7% less than the Joint SHMA.
This is a very significant change since, amongst other things, it
* Changes the number of dwellings to meet local need
* The lower population will need commensurately less infrastructure support, optimising the use of capacity in existing infrastructure
* Changes the emphasis on the selection of sites for new housing
* Allows brownfield and regeneration sites to be committed before greenfield sites meeting NPPF112 and PPG8-026 and this also places less pressure on Green Belt.
* Can provide a deliverable plan rather than a plan that is too ambitious and unrealistic in the period of the plan
The new projections indicate that 8,343 persons are due to natural change; movement between Warwick District and the rest of the UK account for 5,971 net inflow and International migration shows a net inflow of 999 persons over the plan period.
Further detail is given in Appendix 1 pages 1 to 7.
Until the population targets are revised to the latest projections, the plan cannot be considered ready for submission to Inspection.
Explanation paragraph 2.7 in relation to DS2 commences by saying "The Council's ambitions align with national policy in recognising that housing needs are met for all. "
The parish council agrees that housing needs identified in the district based on up to date population projections should be met, but that the ambitions of the district must also be realistic. Planning practice Guidance on the definition of need, advises that
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 that there is a supply of sites for new housing is clearly necessary with affordable housing and housing that can be afforded being an important part of the plan.

But it is also important to comply with NPPF 157 Crucially, Local Plans should:
* plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework;
* identify land where development would be inappropriate, for instance because of its environmental or historic significance; and
* contain a clear strategy for enhancing the natural, built and historic environment, and supporting Nature Improvement Areas where they have been identified.

The projected population increase of 15,313 people will clearly require employment opportunities but it is also important to balance the jobs/homes ratio so that the current ratio, generally regarded as good, is maintained.

4.1 The plan has to be prepared in accordance with the Duty to Cooperate with Neighbouring authorities. This has been accomplished through a joint SHMA. The mid-2012 ONS Population projection has had a similar result for the Warwickshire Districts. There is however a possible problem with the Coventry result.

4.2 This table summarises the revised population growth and the number of dwellings resulting from the same dwelling density as the Joint SHMA. The joint SHMA identified a need for 67,536 homes. The revised projections now identify 68,152 homes.


Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 74,796 36,168 +70.4%
TOTAL HMA 123,882 67,536 129,751 68,152 +4.7%

4.3 Coventry's 2011 ONS population was 316,915 and is projected by 2029 to be 391,711. This is an increase of 74,796 over the plan period. This is made up from
* The net effect of natural change which accounts for 50,734 people by 2029.
* The net effect of people moving in and out of Coventry from other parts of the UK is a net outflow of 50,592 over the plan period.
* The net effect of international migration is an inflow of 74,654 over the plan period.
However, analysis of the numbers of people in single age groups for each year from 2002 to 2029 identifies two problems with this projection.
The first is that the 2 universities currently have about 13,500 international students. Most Coventry students and many Warwick University students live in Coventry. Looking at the 17 to 20, 21 to 24, 25 to 29 and 30 to 34 age groups it was found that there was in increase in these cohort numbers of International inflow from 2005 but not a corresponding outflow. Between 2002 and 2004 the net inflow was between 3400 and 3700. From 2005 inflow increased in significant steps to 7700 by 2011. In younger and older age groups the numbers remained fairly constant for the whole period. This reflected a time when universities sought to increase international students.
There was not a corresponding change in international outflow until 2009 to 2011 but the volume of the outflow was less that the volume of the inflow 3 years earlier. This indicates that the increase in inflow may be due to international students on courses that are not yet completed.
The problem for the population projection is that the higher inflow is reflected in the population projections because it takes the 6 year average from 2007 to 2012 with the higher numbers, but a related outflow at the completion of courses has not yet begun except at a lower level. It would be expected that as courses and related academic activities for each student came to an end then the outflow would approach the previous level of inflow. Hence the projection for outflow on the same 6 year average is based on a low level. This represents a temporary student bulge that in the course of time should rectify as student turn over numbers give equating inflows and outflows.
The 2002 to 2004 net inflow was between 1000 and 2000 per year, but by 2011 and 12, this had become over 5,000 per year.
In the meantime this gives an overall increase of 74,654 due to international migration over the 18 year plan period. It does not make sense to plan to build homes for a population that is theoretical and will not be there.
If the student bulge is factored out by relating student age groups to the younger and older age groups to estimate the possible non-student element, this indicates that the total number of 74,654 will fall to between 25,000 and 40,000 depending the averaging method used. Without any other detail data this is the closest estimate that can be given. Take the worst case of 40,000 inflow due to migration, then this is still lower than the migration inflow in the Joint SHMA of 43,884.
Hence, Coventry would still have a reduced requirement over the JointSHMA of almost 9%, which would indicate that Coventry is unlikely to seek to ask neighbouring authorities to meet its housing need.
The table below shows the result.
Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 40,000 19,344 -8.85%
TOTAL HMA 123,882 67,536 94,954 51,327 +4.7%

4.4 Further detail is given in Appendix 1 pages 12 to 16.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 2.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS6
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure the Inspector is fully aware of the implications of the method by which the 2012 population projections are converted to the number of dwellings required in the plan and that a fully justified housing need is objectively assessed.
___________________________________________________________________________


DS6 states that the District will provide 12,860 homes over the plan period. This has to relate to the population projection that the up to date assessment of population growth determines.

This number needs to be revised to comply with the reduction in population growth now known.

To convert population to homes, the JointSHMA used an abstract concept of Headship rates, based on information contained in the 2011-based CLG household projections about the relationship between the total population in an age group and the number of household reference persons (HRPs) in that age group. But this is only true at the time the data is taken. HRP's can be any age and are mobile. It can only be a subjective and not an objective assessment.

It is critical because small changes in the average household size can alter homes required significantly. The JointSHMA bases its chosen headship rate on an arbitrary split between 2008 and 2011 headship rates.

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 less communal residents is added to the Joint SHMA plan,, the 2029 population becomes 156,150 plus communal. The combined dwellings total 71,603 and the resultant household size is 2.181.This is a very low figure compared with the 2011 census.

Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 21,472 = 156,150
dwellings 58,679 + 12,924 = 71,603
Persons/household 2.295 = 2.181

If the population growth is going to be less, then the household size to use needs to be addressed.

The following options could be considered -

a) If the population of 15,313 is substituted in to the table above so that the household size in 2029 remains as 2.181, then 10,100 would be needed.

b) Proportionately, the revised population growth would require 9,217 homes producing an average household size of 2.209.

c) Using census data for 2001, the average household size excluding communal was 2.32. But the 2011 size was 2.295. If the size dropped at the same rate in the next 18 years it would become 2.245. If this is used for the revised population projection, the calculation becomes
Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 15,313 = 149,991
dwellings 58,679 + 8,118 = 66,797
Persons/household 2.295 = 2.245


d) However, there is no evidence that says that any drop in household size will be at the same rate. The closer that the size gets to 1, the slower will be the reducing rate of change. If the 2011 census rate of 2.295 prevails then 6,715 homes would provide for 15,313 people.

e) Because the built home is normally constant, the size and tenure of a house, on average over time, is a better indicator of household size than the variable HRP. Given that we know from the 2011 census the number of people in the number of house of each tenure type, we have an up to date household size for each dwelling type, for example, the average household size for a detached house or bungalow was 2.585.

Further details are given in Appendix 1 pages 8 to 11 where a calculation for a typical development takes the 2011 census data for each dwelling type adds on the densities arising from Affordable homes that will be allocated to match families to the number of bedrooms they need and the market housing developers have selected the type they want to include in their development. From Page 10 in the appendix, in the example given, the average household size calculates at 2.325. So the likelihood is that the household size will rise rather than fall. If it should rise to 2.325 over the whole of the 2029 population, then only 5,785 homes will be required.

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. This is what the NPPF6 means by "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system. 7. There are three dimensions to sustainable development: economic, social and Environmental all of which should be achieved simultaneously."
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 3.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS4, DS7, DS10, DS11, NE5
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that in the selection of sites for development, compliance with all NPPF matters from provision of housing and infrastructure to protecting Green Belt, conserving the natural and historic environment is achieved.
___________________________________________________________________________


DS7 identifies 13,014 sites for a plan of 12860 homes. This has to relate to the population projection that the up to date assessment of population growth determines, so that this number needs to be revised to comply with the reduction in population growth now known.

DS7 lists sites completed between 2011 and 2013 as 406. This conflicts with a previously published number of 447 in the June 2013 % year housing land supply document.

It makes no provision for the following
1. As PPG3-036 no allowance has been made to deduct oversupply of 687 made in years previous to the start date of Apr 2011 when completions of 5,947 compared with the target was 5,260.
2. Completions of 450 in the 2013/14 financial year, listed in the rough update April 2014 is not shown.
3. No allowance is made for completions since 1st April 2014.
4. An up to date assessment of sites under construction is not included.
5. No allowance has been included for vacant dwellings returned to use since1/4/11 to date, as reported to DCLG and upon which new homes bonus has been received by the District.
6. No allowance for vacant dwellings being returned to use through the remainder of the plan period has been included.


Explanation 2.22 states that the balance of housing outside of DS7 is to be provided on allocated brownfield and greenfield sites across the District. Reference is made to DS4.



Policy NE5 Protection of Natural Resources para d) includes reference to NPPF112 concerning best & most versatile agricultural land. It is a somewhat watered down version of NPPF112 that requires LPA's to take into account the economic and other benefits of the b&mv ag land. Even where significant development of b&mv ag land is identified, it has to be demonstrated that it is necessary and seek to use poorer quality land in preference to it. Explanation clause 5.198 expands NE5d) satisfactorily until it gets to the last few lines where it alters the sense of NPPF112 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 last phrase 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.


Explanation 2.23 states that the housing strategy shows a timeline for the delivery of housing across the plan period. 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 Spatial Strategy contains statements that are not being observed.

a) 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 any (except for affordable homes on Queensway) previously developed land within the urban areas? Regeneration and enhancement sites remain to be identified in principle let alone activation. The strategy is right, but its needs to be fully implemented.

b) 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.

DS10 and DS11 sets out a list of allocated housing sites.

Taking these lists and the current programme position, the sites have been listed in appendix 2. This appendix shows that 8,482 sites have been identified as -

1. 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 up to 8482 dwellings for this set of supply categories , then no further applications need to be granted to meet the plan as there is already a surplus provision. This applies to options c), 8,118 d), 6,615 & e) 5,785 in Representation 2 from Bishop's Tachbrook Parish Council.

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.


2. This applies to the following sites (See also APPENDIX 2)

Land west of Europa Way
East of Whitnash/south of Sydenham
Campion hills
East of Kenilworth (Thickthorn)
Both Kenilworth School sites.
All villages except Bishops Tachbrook, Barford and Radford Semele
Land south of Harbury Lane, including the former sewage works which is wrongly classified under Urban Brownfield sites. In any event this is a valuable green part of the Tachbrook Valley with a significant range of ecological biodiversity implications, a series of deep tanks across the site that would make any development difficult and a slope across the site which at the proximity of the Tach Brook turns into a steep slope. It is well planted and supports a number of mammals. Otters are known in the brook.
The photo below shows the former sewage works. This is not urban brownfield.


3. The list also shows
* Grove Farm at 200 dwellings which is currently subject to appeal after refusal,
* future vacant dwellings return and
* a list of 543 C2 homes for the elderly, all of which can be counted towards the housing supply in accordance with PPG3-037.
037 How should local planning authorities deal with housing for older people?
Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.
With these it would no longer be necessary to keep the sensitive urban brownfield and sensitive greenfield shown at the end of appendix 2 in DS11.

So the 3 Kenilworth sites, land west of Europa Way and East of Whitnash/ south of Sydenham do not need to be included.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 4.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS13
5. Do you consider the Local Plan is :
5.1 Legally Compliant? Don't know
5.2 Complies with the Duty to Co-operate? No
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that best and most versatile agricultural land is protected sufficiently to conserve and enhance the Natural Environment
___________________________________________________________________________

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.

As part of the duty to cooperate, the District Council should work with the Parish Council, as we prepare our Neighbourhood Plan and in accordance with Policy NP2 stating that the Council will support communities preparing Neighbourhood Plans.

The developing Neighbourhood plan seeks to retain the agricultural economy of the land between Harbury Lane and the Tach Brook but at the same time open the area up in a limited way with a brookstray walk and habitat improvement for wildlife possibly through an extended Defra/ Natural England Stewardship scheme and a Local Greenspace designation over those stewardship areas. This could achieve the objectives in Explanation paras 2.57 but not commit to the expensive country park concept.

We doubt that the £1.5m needed to set up a Country Park, which will require car parks and facilities for the public, becoming urbanised and less friendly to wildlife, 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.




Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact.
Representation 5.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DM1
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that the Local Plan has been prepared to a realistic level that can be supported by adequate income from developments CIL and other government payments such as new homes bonus to ensure that the additional infrastructure necessary to accommodate the increased population of 15,313 people
___________________________________________________________________________

It is an important part of the local plan that the necessary infrastructure required to support the additional population has been fully identified , addressed in the plan as to where and how it will be delivered and that the costs have been assessed and a financial plan for their delivery determined.

An independent assessment of the plan for 12860 homes has been carried out by professionals concerned that this aspect is not properly covered, since the result of an inadequate financial plan would mean 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.

DM1 says it will happen but there does not appear to be a plan in place to ensure that it does. If this is the case, then the inspector, who will have to ensure that such a plan is in place, will find that it doesn't and the plan will be found unsound.

However the amount of infrastructure necessary will depend on the population to be planned for, the housing numbers necessary to meet that need and the location of housing.

Across the district currently, much of the infrastructure is fairly fully stretched. Major items such Education, Hospitals and road networks are heavily utilised. But there are parts where there is some spare capacity that new developments can utilise.

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.

For the 12,860 homes plan, our independent assessment indicates that the costs of the infrastructure required will be between £30m to £50m more than the income that will be received from section 106, CIL(when it applies), new homes bonus and other sundry incomes. This is on the assumption that the infrastructure costs are capital costs and that the revenue running costs will be met from income generated from Council tax and similar receipts.

In our assessment we have included the costs of road traffic schemes due to high concentrations of new traffic in underprovided areas, Health and hospitals, Education, sports facilities, recreational facilities , cultural and community , police and emergency services as well as parking provision for the additional users of the towns. All 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.

It will be appreciated that doing this exercise from outside the authority, much of the detail necessary is not available and it is dependent on published information from the District Councils website as to the amounts of payments so far agreed with developers on the early schemes.

Although the plan is for 12860 homes, many of these will not be paying contributions because they have been approved in advance of the programme, are affordable homes so will not be liable for payments and are part of small schemes for which 106 payments are not sought.

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. Some elements are population number dependent but lower numbers mean a smaller impact on them.

Depending on the housing number decided the assessment will to be reworked. Until thenthe plan does not have a sound infrastructure cost strategy.

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.
Paragraph: 037 Reference ID: 3-037-20140306

Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 1.
1. In responding to this consultation, the Parish Council emphasises that its sole interest is to help devise a Local Plan that is positively prepared, justified, effective and consistent with national policy, complying with the National Planning Policy Framework and the Planning Practice Guidelines published in March 2014.
2 It is our belief however that draft Local Plan is not sound in a number of aspects.
But over-riding all the matters is the fact that because the plan is based on the joint SHMA, it was only able to use the mid-2011 ONS Population Projections when it was prepared.
On the 29th May 2014, the ONS published the mid-2012 population projections. As we indicated to you at the Planning Forum before the publication draft was approved by the District Council on April 23rd, the new projections show a very significant reduction in population projection for the plan period up to 2029.
3. National planning policy places Local Plans at the heart of the planning system, so it is essential that they are in place and kept up to date. PPG12-001, NPPF157 * 2.
To start a new Local Plan based on outdated data cannot be seen as a sound plan and an Inspector will have to conclude that procedural requirements have not been met and question whether the Plan is sound.
For Warwick District, the joint SHMA uses for Proj 1A a population growth of 23,858 over 20 years, this being 21,472 over 18 years. The mid-2012 ONS projection for 2029 is 153,049, which is a population growth of 15,313 from mid 2011. This is 28.7% less than the Joint SHMA.
This is a very significant change since, amongst other things, it
* Changes the number of dwellings to meet local need
* The lower population will need commensurately less infrastructure support, optimising the use of capacity in existing infrastructure
* Changes the emphasis on the selection of sites for new housing
* Allows brownfield and regeneration sites to be committed before greenfield sites meeting NPPF112 and PPG8-026 and this also places less pressure on Green Belt.
* Can provide a deliverable plan rather than a plan that is too ambitious and unrealistic in the period of the plan
The new projections indicate that 8,343 persons are due to natural change; movement between Warwick District and the rest of the UK account for 5,971 net inflow and International migration shows a net inflow of 999 persons over the plan period.
Further detail is given in Appendix 1 pages 1 to 7.
Until the population targets are revised to the latest projections, the plan cannot be considered ready for submission to Inspection.
Explanation paragraph 2.7 in relation to DS2 commences by saying "The Council's ambitions align with national policy in recognising that housing needs are met for all. "
The parish council agrees that housing needs identified in the district based on up to date population projections should be met, but that the ambitions of the district must also be realistic. Planning practice Guidance on the definition of need, advises that
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 that there is a supply of sites for new housing is clearly necessary with affordable housing and housing that can be afforded being an important part of the plan.

But it is also important to comply with NPPF 157 Crucially, Local Plans should:
* plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework;
* identify land where development would be inappropriate, for instance because of its environmental or historic significance; and
* contain a clear strategy for enhancing the natural, built and historic environment, and supporting Nature Improvement Areas where they have been identified.

The projected population increase of 15,313 people will clearly require employment opportunities but it is also important to balance the jobs/homes ratio so that the current ratio, generally regarded as good, is maintained.

4.1 The plan has to be prepared in accordance with the Duty to Cooperate with Neighbouring authorities. This has been accomplished through a joint SHMA. The mid-2012 ONS Population projection has had a similar result for the Warwickshire Districts. There is however a possible problem with the Coventry result.

4.2 This table summarises the revised population growth and the number of dwellings resulting from the same dwelling density as the Joint SHMA. The joint SHMA identified a need for 67,536 homes. The revised projections now identify 68,152 homes.


Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 74,796 36,168 +70.4%
TOTAL HMA 123,882 67,536 129,751 68,152 +4.7%

4.3 Coventry's 2011 ONS population was 316,915 and is projected by 2029 to be 391,711. This is an increase of 74,796 over the plan period. This is made up from
* The net effect of natural change which accounts for 50,734 people by 2029.
* The net effect of people moving in and out of Coventry from other parts of the UK is a net outflow of 50,592 over the plan period.
* The net effect of international migration is an inflow of 74,654 over the plan period.
However, analysis of the numbers of people in single age groups for each year from 2002 to 2029 identifies two problems with this projection.
The first is that the 2 universities currently have about 13,500 international students. Most Coventry students and many Warwick University students live in Coventry. Looking at the 17 to 20, 21 to 24, 25 to 29 and 30 to 34 age groups it was found that there was in increase in these cohort numbers of International inflow from 2005 but not a corresponding outflow. Between 2002 and 2004 the net inflow was between 3400 and 3700. From 2005 inflow increased in significant steps to 7700 by 2011. In younger and older age groups the numbers remained fairly constant for the whole period. This reflected a time when universities sought to increase international students.
There was not a corresponding change in international outflow until 2009 to 2011 but the volume of the outflow was less that the volume of the inflow 3 years earlier. This indicates that the increase in inflow may be due to international students on courses that are not yet completed.
The problem for the population projection is that the higher inflow is reflected in the population projections because it takes the 6 year average from 2007 to 2012 with the higher numbers, but a related outflow at the completion of courses has not yet begun except at a lower level. It would be expected that as courses and related academic activities for each student came to an end then the outflow would approach the previous level of inflow. Hence the projection for outflow on the same 6 year average is based on a low level. This represents a temporary student bulge that in the course of time should rectify as student turn over numbers give equating inflows and outflows.
The 2002 to 2004 net inflow was between 1000 and 2000 per year, but by 2011 and 12, this had become over 5,000 per year.
In the meantime this gives an overall increase of 74,654 due to international migration over the 18 year plan period. It does not make sense to plan to build homes for a population that is theoretical and will not be there.
If the student bulge is factored out by relating student age groups to the younger and older age groups to estimate the possible non-student element, this indicates that the total number of 74,654 will fall to between 25,000 and 40,000 depending the averaging method used. Without any other detail data this is the closest estimate that can be given. Take the worst case of 40,000 inflow due to migration, then this is still lower than the migration inflow in the Joint SHMA of 43,884.
Hence, Coventry would still have a reduced requirement over the JointSHMA of almost 9%, which would indicate that Coventry is unlikely to seek to ask neighbouring authorities to meet its housing need.
The table below shows the result.
Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 40,000 19,344 -8.85%
TOTAL HMA 123,882 67,536 94,954 51,327 +4.7%

4.4 Further detail is given in Appendix 1 pages 12 to 16.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 2.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS6
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure the Inspector is fully aware of the implications of the method by which the 2012 population projections are converted to the number of dwellings required in the plan and that a fully justified housing need is objectively assessed.
___________________________________________________________________________


DS6 states that the District will provide 12,860 homes over the plan period. This has to relate to the population projection that the up to date assessment of population growth determines.

This number needs to be revised to comply with the reduction in population growth now known.

To convert population to homes, the JointSHMA used an abstract concept of Headship rates, based on information contained in the 2011-based CLG household projections about the relationship between the total population in an age group and the number of household reference persons (HRPs) in that age group. But this is only true at the time the data is taken. HRP's can be any age and are mobile. It can only be a subjective and not an objective assessment.

It is critical because small changes in the average household size can alter homes required significantly. The JointSHMA bases its chosen headship rate on an arbitrary split between 2008 and 2011 headship rates.

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 less communal residents is added to the Joint SHMA plan,, the 2029 population becomes 156,150 plus communal. The combined dwellings total 71,603 and the resultant household size is 2.181.This is a very low figure compared with the 2011 census.

Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 21,472 = 156,150
dwellings 58,679 + 12,924 = 71,603
Persons/household 2.295 = 2.181

If the population growth is going to be less, then the household size to use needs to be addressed.

The following options could be considered -

a) If the population of 15,313 is substituted in to the table above so that the household size in 2029 remains as 2.181, then 10,100 would be needed.

b) Proportionately, the revised population growth would require 9,217 homes producing an average household size of 2.209.

c) Using census data for 2001, the average household size excluding communal was 2.32. But the 2011 size was 2.295. If the size dropped at the same rate in the next 18 years it would become 2.245. If this is used for the revised population projection, the calculation becomes
Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 15,313 = 149,991
dwellings 58,679 + 8,118 = 66,797
Persons/household 2.295 = 2.245


d) However, there is no evidence that says that any drop in household size will be at the same rate. The closer that the size gets to 1, the slower will be the reducing rate of change. If the 2011 census rate of 2.295 prevails then 6,715 homes would provide for 15,313 people.

e) Because the built home is normally constant, the size and tenure of a house, on average over time, is a better indicator of household size than the variable HRP. Given that we know from the 2011 census the number of people in the number of house of each tenure type, we have an up to date household size for each dwelling type, for example, the average household size for a detached house or bungalow was 2.585.

Further details are given in Appendix 1 pages 8 to 11 where a calculation for a typical development takes the 2011 census data for each dwelling type adds on the densities arising from Affordable homes that will be allocated to match families to the number of bedrooms they need and the market housing developers have selected the type they want to include in their development. From Page 10 in the appendix, in the example given, the average household size calculates at 2.325. So the likelihood is that the household size will rise rather than fall. If it should rise to 2.325 over the whole of the 2029 population, then only 5,785 homes will be required.

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. This is what the NPPF6 means by "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system. 7. There are three dimensions to sustainable development: economic, social and Environmental all of which should be achieved simultaneously."
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 3.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS4, DS7, DS10, DS11, NE5
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that in the selection of sites for development, compliance with all NPPF matters from provision of housing and infrastructure to protecting Green Belt, conserving the natural and historic environment is achieved.
___________________________________________________________________________


DS7 identifies 13,014 sites for a plan of 12860 homes. This has to relate to the population projection that the up to date assessment of population growth determines, so that this number needs to be revised to comply with the reduction in population growth now known.

DS7 lists sites completed between 2011 and 2013 as 406. This conflicts with a previously published number of 447 in the June 2013 % year housing land supply document.

It makes no provision for the following
1. As PPG3-036 no allowance has been made to deduct oversupply of 687 made in years previous to the start date of Apr 2011 when completions of 5,947 compared with the target was 5,260.
2. Completions of 450 in the 2013/14 financial year, listed in the rough update April 2014 is not shown.
3. No allowance is made for completions since 1st April 2014.
4. An up to date assessment of sites under construction is not included.
5. No allowance has been included for vacant dwellings returned to use since1/4/11 to date, as reported to DCLG and upon which new homes bonus has been received by the District.
6. No allowance for vacant dwellings being returned to use through the remainder of the plan period has been included.


Explanation 2.22 states that the balance of housing outside of DS7 is to be provided on allocated brownfield and greenfield sites across the District. Reference is made to DS4.



Policy NE5 Protection of Natural Resources para d) includes reference to NPPF112 concerning best & most versatile agricultural land. It is a somewhat watered down version of NPPF112 that requires LPA's to take into account the economic and other benefits of the b&mv ag land. Even where significant development of b&mv ag land is identified, it has to be demonstrated that it is necessary and seek to use poorer quality land in preference to it. Explanation clause 5.198 expands NE5d) satisfactorily until it gets to the last few lines where it alters the sense of NPPF112 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 last phrase 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.


Explanation 2.23 states that the housing strategy shows a timeline for the delivery of housing across the plan period. 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 Spatial Strategy contains statements that are not being observed.

a) 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 any (except for affordable homes on Queensway) previously developed land within the urban areas? Regeneration and enhancement sites remain to be identified in principle let alone activation. The strategy is right, but its needs to be fully implemented.

b) 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.

DS10 and DS11 sets out a list of allocated housing sites.

Taking these lists and the current programme position, the sites have been listed in appendix 2. This appendix shows that 8,482 sites have been identified as -

1. 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 up to 8482 dwellings for this set of supply categories , then no further applications need to be granted to meet the plan as there is already a surplus provision. This applies to options c), 8,118 d), 6,615 & e) 5,785 in Representation 2 from Bishop's Tachbrook Parish Council.

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.


2. This applies to the following sites (See also APPENDIX 2)

Land west of Europa Way
East of Whitnash/south of Sydenham
Campion hills
East of Kenilworth (Thickthorn)
Both Kenilworth School sites.
All villages except Bishops Tachbrook, Barford and Radford Semele
Land south of Harbury Lane, including the former sewage works which is wrongly classified under Urban Brownfield sites. In any event this is a valuable green part of the Tachbrook Valley with a significant range of ecological biodiversity implications, a series of deep tanks across the site that would make any development difficult and a slope across the site which at the proximity of the Tach Brook turns into a steep slope. It is well planted and supports a number of mammals. Otters are known in the brook.
The photo below shows the former sewage works. This is not urban brownfield.


3. The list also shows
* Grove Farm at 200 dwellings which is currently subject to appeal after refusal,
* future vacant dwellings return and
* a list of 543 C2 homes for the elderly, all of which can be counted towards the housing supply in accordance with PPG3-037.
037 How should local planning authorities deal with housing for older people?
Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.
With these it would no longer be necessary to keep the sensitive urban brownfield and sensitive greenfield shown at the end of appendix 2 in DS11.

So the 3 Kenilworth sites, land west of Europa Way and East of Whitnash/ south of Sydenham do not need to be included.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 4.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS13
5. Do you consider the Local Plan is :
5.1 Legally Compliant? Don't know
5.2 Complies with the Duty to Co-operate? No
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that best and most versatile agricultural land is protected sufficiently to conserve and enhance the Natural Environment
___________________________________________________________________________

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.

As part of the duty to cooperate, the District Council should work with the Parish Council, as we prepare our Neighbourhood Plan and in accordance with Policy NP2 stating that the Council will support communities preparing Neighbourhood Plans.

The developing Neighbourhood plan seeks to retain the agricultural economy of the land between Harbury Lane and the Tach Brook but at the same time open the area up in a limited way with a brookstray walk and habitat improvement for wildlife possibly through an extended Defra/ Natural England Stewardship scheme and a Local Greenspace designation over those stewardship areas. This could achieve the objectives in Explanation paras 2.57 but not commit to the expensive country park concept.

We doubt that the £1.5m needed to set up a Country Park, which will require car parks and facilities for the public, becoming urbanised and less friendly to wildlife, 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.




Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact.
Representation 5.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DM1
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that the Local Plan has been prepared to a realistic level that can be supported by adequate income from developments CIL and other government payments such as new homes bonus to ensure that the additional infrastructure necessary to accommodate the increased population of 15,313 people
___________________________________________________________________________

It is an important part of the local plan that the necessary infrastructure required to support the additional population has been fully identified , addressed in the plan as to where and how it will be delivered and that the costs have been assessed and a financial plan for their delivery determined.

An independent assessment of the plan for 12860 homes has been carried out by professionals concerned that this aspect is not properly covered, since the result of an inadequate financial plan would mean 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.

DM1 says it will happen but there does not appear to be a plan in place to ensure that it does. If this is the case, then the inspector, who will have to ensure that such a plan is in place, will find that it doesn't and the plan will be found unsound.

However the amount of infrastructure necessary will depend on the population to be planned for, the housing numbers necessary to meet that need and the location of housing.

Across the district currently, much of the infrastructure is fairly fully stretched. Major items such Education, Hospitals and road networks are heavily utilised. But there are parts where there is some spare capacity that new developments can utilise.

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.

For the 12,860 homes plan, our independent assessment indicates that the costs of the infrastructure required will be between £30m to £50m more than the income that will be received from section 106, CIL(when it applies), new homes bonus and other sundry incomes. This is on the assumption that the infrastructure costs are capital costs and that the revenue running costs will be met from income generated from Council tax and similar receipts.

In our assessment we have included the costs of road traffic schemes due to high concentrations of new traffic in underprovided areas, Health and hospitals, Education, sports facilities, recreational facilities , cultural and community , police and emergency services as well as parking provision for the additional users of the towns. All 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.

It will be appreciated that doing this exercise from outside the authority, much of the detail necessary is not available and it is dependent on published information from the District Councils website as to the amounts of payments so far agreed with developers on the early schemes.

Although the plan is for 12860 homes, many of these will not be paying contributions because they have been approved in advance of the programme, are affordable homes so will not be liable for payments and are part of small schemes for which 106 payments are not sought.

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. Some elements are population number dependent but lower numbers mean a smaller impact on them.

Depending on the housing number decided the assessment will to be reworked. Until thenthe plan does not have a sound infrastructure cost strategy.

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.
Paragraph: 037 Reference ID: 3-037-20140306

Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 1.
1. In responding to this consultation, the Parish Council emphasises that its sole interest is to help devise a Local Plan that is positively prepared, justified, effective and consistent with national policy, complying with the National Planning Policy Framework and the Planning Practice Guidelines published in March 2014.
2 It is our belief however that draft Local Plan is not sound in a number of aspects.
But over-riding all the matters is the fact that because the plan is based on the joint SHMA, it was only able to use the mid-2011 ONS Population Projections when it was prepared.
On the 29th May 2014, the ONS published the mid-2012 population projections. As we indicated to you at the Planning Forum before the publication draft was approved by the District Council on April 23rd, the new projections show a very significant reduction in population projection for the plan period up to 2029.
3. National planning policy places Local Plans at the heart of the planning system, so it is essential that they are in place and kept up to date. PPG12-001, NPPF157 * 2.
To start a new Local Plan based on outdated data cannot be seen as a sound plan and an Inspector will have to conclude that procedural requirements have not been met and question whether the Plan is sound.
For Warwick District, the joint SHMA uses for Proj 1A a population growth of 23,858 over 20 years, this being 21,472 over 18 years. The mid-2012 ONS projection for 2029 is 153,049, which is a population growth of 15,313 from mid 2011. This is 28.7% less than the Joint SHMA.
This is a very significant change since, amongst other things, it
* Changes the number of dwellings to meet local need
* The lower population will need commensurately less infrastructure support, optimising the use of capacity in existing infrastructure
* Changes the emphasis on the selection of sites for new housing
* Allows brownfield and regeneration sites to be committed before greenfield sites meeting NPPF112 and PPG8-026 and this also places less pressure on Green Belt.
* Can provide a deliverable plan rather than a plan that is too ambitious and unrealistic in the period of the plan
The new projections indicate that 8,343 persons are due to natural change; movement between Warwick District and the rest of the UK account for 5,971 net inflow and International migration shows a net inflow of 999 persons over the plan period.
Further detail is given in Appendix 1 pages 1 to 7.
Until the population targets are revised to the latest projections, the plan cannot be considered ready for submission to Inspection.
Explanation paragraph 2.7 in relation to DS2 commences by saying "The Council's ambitions align with national policy in recognising that housing needs are met for all. "
The parish council agrees that housing needs identified in the district based on up to date population projections should be met, but that the ambitions of the district must also be realistic. Planning practice Guidance on the definition of need, advises that
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 that there is a supply of sites for new housing is clearly necessary with affordable housing and housing that can be afforded being an important part of the plan.

But it is also important to comply with NPPF 157 Crucially, Local Plans should:
* plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework;
* identify land where development would be inappropriate, for instance because of its environmental or historic significance; and
* contain a clear strategy for enhancing the natural, built and historic environment, and supporting Nature Improvement Areas where they have been identified.

The projected population increase of 15,313 people will clearly require employment opportunities but it is also important to balance the jobs/homes ratio so that the current ratio, generally regarded as good, is maintained.

4.1 The plan has to be prepared in accordance with the Duty to Cooperate with Neighbouring authorities. This has been accomplished through a joint SHMA. The mid-2012 ONS Population projection has had a similar result for the Warwickshire Districts. There is however a possible problem with the Coventry result.

4.2 This table summarises the revised population growth and the number of dwellings resulting from the same dwelling density as the Joint SHMA. The joint SHMA identified a need for 67,536 homes. The revised projections now identify 68,152 homes.


Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 74,796 36,168 +70.4%
TOTAL HMA 123,882 67,536 129,751 68,152 +4.7%

4.3 Coventry's 2011 ONS population was 316,915 and is projected by 2029 to be 391,711. This is an increase of 74,796 over the plan period. This is made up from
* The net effect of natural change which accounts for 50,734 people by 2029.
* The net effect of people moving in and out of Coventry from other parts of the UK is a net outflow of 50,592 over the plan period.
* The net effect of international migration is an inflow of 74,654 over the plan period.
However, analysis of the numbers of people in single age groups for each year from 2002 to 2029 identifies two problems with this projection.
The first is that the 2 universities currently have about 13,500 international students. Most Coventry students and many Warwick University students live in Coventry. Looking at the 17 to 20, 21 to 24, 25 to 29 and 30 to 34 age groups it was found that there was in increase in these cohort numbers of International inflow from 2005 but not a corresponding outflow. Between 2002 and 2004 the net inflow was between 3400 and 3700. From 2005 inflow increased in significant steps to 7700 by 2011. In younger and older age groups the numbers remained fairly constant for the whole period. This reflected a time when universities sought to increase international students.
There was not a corresponding change in international outflow until 2009 to 2011 but the volume of the outflow was less that the volume of the inflow 3 years earlier. This indicates that the increase in inflow may be due to international students on courses that are not yet completed.
The problem for the population projection is that the higher inflow is reflected in the population projections because it takes the 6 year average from 2007 to 2012 with the higher numbers, but a related outflow at the completion of courses has not yet begun except at a lower level. It would be expected that as courses and related academic activities for each student came to an end then the outflow would approach the previous level of inflow. Hence the projection for outflow on the same 6 year average is based on a low level. This represents a temporary student bulge that in the course of time should rectify as student turn over numbers give equating inflows and outflows.
The 2002 to 2004 net inflow was between 1000 and 2000 per year, but by 2011 and 12, this had become over 5,000 per year.
In the meantime this gives an overall increase of 74,654 due to international migration over the 18 year plan period. It does not make sense to plan to build homes for a population that is theoretical and will not be there.
If the student bulge is factored out by relating student age groups to the younger and older age groups to estimate the possible non-student element, this indicates that the total number of 74,654 will fall to between 25,000 and 40,000 depending the averaging method used. Without any other detail data this is the closest estimate that can be given. Take the worst case of 40,000 inflow due to migration, then this is still lower than the migration inflow in the Joint SHMA of 43,884.
Hence, Coventry would still have a reduced requirement over the JointSHMA of almost 9%, which would indicate that Coventry is unlikely to seek to ask neighbouring authorities to meet its housing need.
The table below shows the result.
Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 40,000 19,344 -8.85%
TOTAL HMA 123,882 67,536 94,954 51,327 +4.7%

4.4 Further detail is given in Appendix 1 pages 12 to 16.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 2.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS6
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure the Inspector is fully aware of the implications of the method by which the 2012 population projections are converted to the number of dwellings required in the plan and that a fully justified housing need is objectively assessed.
___________________________________________________________________________


DS6 states that the District will provide 12,860 homes over the plan period. This has to relate to the population projection that the up to date assessment of population growth determines.

This number needs to be revised to comply with the reduction in population growth now known.

To convert population to homes, the JointSHMA used an abstract concept of Headship rates, based on information contained in the 2011-based CLG household projections about the relationship between the total population in an age group and the number of household reference persons (HRPs) in that age group. But this is only true at the time the data is taken. HRP's can be any age and are mobile. It can only be a subjective and not an objective assessment.

It is critical because small changes in the average household size can alter homes required significantly. The JointSHMA bases its chosen headship rate on an arbitrary split between 2008 and 2011 headship rates.

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 less communal residents is added to the Joint SHMA plan,, the 2029 population becomes 156,150 plus communal. The combined dwellings total 71,603 and the resultant household size is 2.181.This is a very low figure compared with the 2011 census.

Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 21,472 = 156,150
dwellings 58,679 + 12,924 = 71,603
Persons/household 2.295 = 2.181

If the population growth is going to be less, then the household size to use needs to be addressed.

The following options could be considered -

a) If the population of 15,313 is substituted in to the table above so that the household size in 2029 remains as 2.181, then 10,100 would be needed.

b) Proportionately, the revised population growth would require 9,217 homes producing an average household size of 2.209.

c) Using census data for 2001, the average household size excluding communal was 2.32. But the 2011 size was 2.295. If the size dropped at the same rate in the next 18 years it would become 2.245. If this is used for the revised population projection, the calculation becomes
Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 15,313 = 149,991
dwellings 58,679 + 8,118 = 66,797
Persons/household 2.295 = 2.245


d) However, there is no evidence that says that any drop in household size will be at the same rate. The closer that the size gets to 1, the slower will be the reducing rate of change. If the 2011 census rate of 2.295 prevails then 6,715 homes would provide for 15,313 people.

e) Because the built home is normally constant, the size and tenure of a house, on average over time, is a better indicator of household size than the variable HRP. Given that we know from the 2011 census the number of people in the number of house of each tenure type, we have an up to date household size for each dwelling type, for example, the average household size for a detached house or bungalow was 2.585.

Further details are given in Appendix 1 pages 8 to 11 where a calculation for a typical development takes the 2011 census data for each dwelling type adds on the densities arising from Affordable homes that will be allocated to match families to the number of bedrooms they need and the market housing developers have selected the type they want to include in their development. From Page 10 in the appendix, in the example given, the average household size calculates at 2.325. So the likelihood is that the household size will rise rather than fall. If it should rise to 2.325 over the whole of the 2029 population, then only 5,785 homes will be required.

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. This is what the NPPF6 means by "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system. 7. There are three dimensions to sustainable development: economic, social and Environmental all of which should be achieved simultaneously."
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 3.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS4, DS7, DS10, DS11, NE5
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that in the selection of sites for development, compliance with all NPPF matters from provision of housing and infrastructure to protecting Green Belt, conserving the natural and historic environment is achieved.
___________________________________________________________________________


DS7 identifies 13,014 sites for a plan of 12860 homes. This has to relate to the population projection that the up to date assessment of population growth determines, so that this number needs to be revised to comply with the reduction in population growth now known.

DS7 lists sites completed between 2011 and 2013 as 406. This conflicts with a previously published number of 447 in the June 2013 % year housing land supply document.

It makes no provision for the following
1. As PPG3-036 no allowance has been made to deduct oversupply of 687 made in years previous to the start date of Apr 2011 when completions of 5,947 compared with the target was 5,260.
2. Completions of 450 in the 2013/14 financial year, listed in the rough update April 2014 is not shown.
3. No allowance is made for completions since 1st April 2014.
4. An up to date assessment of sites under construction is not included.
5. No allowance has been included for vacant dwellings returned to use since1/4/11 to date, as reported to DCLG and upon which new homes bonus has been received by the District.
6. No allowance for vacant dwellings being returned to use through the remainder of the plan period has been included.


Explanation 2.22 states that the balance of housing outside of DS7 is to be provided on allocated brownfield and greenfield sites across the District. Reference is made to DS4.



Policy NE5 Protection of Natural Resources para d) includes reference to NPPF112 concerning best & most versatile agricultural land. It is a somewhat watered down version of NPPF112 that requires LPA's to take into account the economic and other benefits of the b&mv ag land. Even where significant development of b&mv ag land is identified, it has to be demonstrated that it is necessary and seek to use poorer quality land in preference to it. Explanation clause 5.198 expands NE5d) satisfactorily until it gets to the last few lines where it alters the sense of NPPF112 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 last phrase 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.


Explanation 2.23 states that the housing strategy shows a timeline for the delivery of housing across the plan period. 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 Spatial Strategy contains statements that are not being observed.

a) 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 any (except for affordable homes on Queensway) previously developed land within the urban areas? Regeneration and enhancement sites remain to be identified in principle let alone activation. The strategy is right, but its needs to be fully implemented.

b) 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.

DS10 and DS11 sets out a list of allocated housing sites.

Taking these lists and the current programme position, the sites have been listed in appendix 2. This appendix shows that 8,482 sites have been identified as -

1. 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 up to 8482 dwellings for this set of supply categories , then no further applications need to be granted to meet the plan as there is already a surplus provision. This applies to options c), 8,118 d), 6,615 & e) 5,785 in Representation 2 from Bishop's Tachbrook Parish Council.

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.


2. This applies to the following sites (See also APPENDIX 2)

Land west of Europa Way
East of Whitnash/south of Sydenham
Campion hills
East of Kenilworth (Thickthorn)
Both Kenilworth School sites.
All villages except Bishops Tachbrook, Barford and Radford Semele
Land south of Harbury Lane, including the former sewage works which is wrongly classified under Urban Brownfield sites. In any event this is a valuable green part of the Tachbrook Valley with a significant range of ecological biodiversity implications, a series of deep tanks across the site that would make any development difficult and a slope across the site which at the proximity of the Tach Brook turns into a steep slope. It is well planted and supports a number of mammals. Otters are known in the brook.
The photo below shows the former sewage works. This is not urban brownfield.


3. The list also shows
* Grove Farm at 200 dwellings which is currently subject to appeal after refusal,
* future vacant dwellings return and
* a list of 543 C2 homes for the elderly, all of which can be counted towards the housing supply in accordance with PPG3-037.
037 How should local planning authorities deal with housing for older people?
Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.
With these it would no longer be necessary to keep the sensitive urban brownfield and sensitive greenfield shown at the end of appendix 2 in DS11.

So the 3 Kenilworth sites, land west of Europa Way and East of Whitnash/ south of Sydenham do not need to be included.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 4.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS13
5. Do you consider the Local Plan is :
5.1 Legally Compliant? Don't know
5.2 Complies with the Duty to Co-operate? No
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that best and most versatile agricultural land is protected sufficiently to conserve and enhance the Natural Environment
___________________________________________________________________________

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.

As part of the duty to cooperate, the District Council should work with the Parish Council, as we prepare our Neighbourhood Plan and in accordance with Policy NP2 stating that the Council will support communities preparing Neighbourhood Plans.

The developing Neighbourhood plan seeks to retain the agricultural economy of the land between Harbury Lane and the Tach Brook but at the same time open the area up in a limited way with a brookstray walk and habitat improvement for wildlife possibly through an extended Defra/ Natural England Stewardship scheme and a Local Greenspace designation over those stewardship areas. This could achieve the objectives in Explanation paras 2.57 but not commit to the expensive country park concept.

We doubt that the £1.5m needed to set up a Country Park, which will require car parks and facilities for the public, becoming urbanised and less friendly to wildlife, 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.




Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact.
Representation 5.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DM1
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that the Local Plan has been prepared to a realistic level that can be supported by adequate income from developments CIL and other government payments such as new homes bonus to ensure that the additional infrastructure necessary to accommodate the increased population of 15,313 people
___________________________________________________________________________

It is an important part of the local plan that the necessary infrastructure required to support the additional population has been fully identified , addressed in the plan as to where and how it will be delivered and that the costs have been assessed and a financial plan for their delivery determined.

An independent assessment of the plan for 12860 homes has been carried out by professionals concerned that this aspect is not properly covered, since the result of an inadequate financial plan would mean 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.

DM1 says it will happen but there does not appear to be a plan in place to ensure that it does. If this is the case, then the inspector, who will have to ensure that such a plan is in place, will find that it doesn't and the plan will be found unsound.

However the amount of infrastructure necessary will depend on the population to be planned for, the housing numbers necessary to meet that need and the location of housing.

Across the district currently, much of the infrastructure is fairly fully stretched. Major items such Education, Hospitals and road networks are heavily utilised. But there are parts where there is some spare capacity that new developments can utilise.

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.

For the 12,860 homes plan, our independent assessment indicates that the costs of the infrastructure required will be between £30m to £50m more than the income that will be received from section 106, CIL(when it applies), new homes bonus and other sundry incomes. This is on the assumption that the infrastructure costs are capital costs and that the revenue running costs will be met from income generated from Council tax and similar receipts.

In our assessment we have included the costs of road traffic schemes due to high concentrations of new traffic in underprovided areas, Health and hospitals, Education, sports facilities, recreational facilities , cultural and community , police and emergency services as well as parking provision for the additional users of the towns. All 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.

It will be appreciated that doing this exercise from outside the authority, much of the detail necessary is not available and it is dependent on published information from the District Councils website as to the amounts of payments so far agreed with developers on the early schemes.

Although the plan is for 12860 homes, many of these will not be paying contributions because they have been approved in advance of the programme, are affordable homes so will not be liable for payments and are part of small schemes for which 106 payments are not sought.

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. Some elements are population number dependent but lower numbers mean a smaller impact on them.

Depending on the housing number decided the assessment will to be reworked. Until thenthe plan does not have a sound infrastructure cost strategy.

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.
Paragraph: 037 Reference ID: 3-037-20140306

Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 1.
1. In responding to this consultation, the Parish Council emphasises that its sole interest is to help devise a Local Plan that is positively prepared, justified, effective and consistent with national policy, complying with the National Planning Policy Framework and the Planning Practice Guidelines published in March 2014.
2 It is our belief however that draft Local Plan is not sound in a number of aspects.
But over-riding all the matters is the fact that because the plan is based on the joint SHMA, it was only able to use the mid-2011 ONS Population Projections when it was prepared.
On the 29th May 2014, the ONS published the mid-2012 population projections. As we indicated to you at the Planning Forum before the publication draft was approved by the District Council on April 23rd, the new projections show a very significant reduction in population projection for the plan period up to 2029.
3. National planning policy places Local Plans at the heart of the planning system, so it is essential that they are in place and kept up to date. PPG12-001, NPPF157 * 2.
To start a new Local Plan based on outdated data cannot be seen as a sound plan and an Inspector will have to conclude that procedural requirements have not been met and question whether the Plan is sound.
For Warwick District, the joint SHMA uses for Proj 1A a population growth of 23,858 over 20 years, this being 21,472 over 18 years. The mid-2012 ONS projection for 2029 is 153,049, which is a population growth of 15,313 from mid 2011. This is 28.7% less than the Joint SHMA.
This is a very significant change since, amongst other things, it
* Changes the number of dwellings to meet local need
* The lower population will need commensurately less infrastructure support, optimising the use of capacity in existing infrastructure
* Changes the emphasis on the selection of sites for new housing
* Allows brownfield and regeneration sites to be committed before greenfield sites meeting NPPF112 and PPG8-026 and this also places less pressure on Green Belt.
* Can provide a deliverable plan rather than a plan that is too ambitious and unrealistic in the period of the plan
The new projections indicate that 8,343 persons are due to natural change; movement between Warwick District and the rest of the UK account for 5,971 net inflow and International migration shows a net inflow of 999 persons over the plan period.
Further detail is given in Appendix 1 pages 1 to 7.
Until the population targets are revised to the latest projections, the plan cannot be considered ready for submission to Inspection.
Explanation paragraph 2.7 in relation to DS2 commences by saying "The Council's ambitions align with national policy in recognising that housing needs are met for all. "
The parish council agrees that housing needs identified in the district based on up to date population projections should be met, but that the ambitions of the district must also be realistic. Planning practice Guidance on the definition of need, advises that
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 that there is a supply of sites for new housing is clearly necessary with affordable housing and housing that can be afforded being an important part of the plan.

But it is also important to comply with NPPF 157 Crucially, Local Plans should:
* plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework;
* identify land where development would be inappropriate, for instance because of its environmental or historic significance; and
* contain a clear strategy for enhancing the natural, built and historic environment, and supporting Nature Improvement Areas where they have been identified.

The projected population increase of 15,313 people will clearly require employment opportunities but it is also important to balance the jobs/homes ratio so that the current ratio, generally regarded as good, is maintained.

4.1 The plan has to be prepared in accordance with the Duty to Cooperate with Neighbouring authorities. This has been accomplished through a joint SHMA. The mid-2012 ONS Population projection has had a similar result for the Warwickshire Districts. There is however a possible problem with the Coventry result.

4.2 This table summarises the revised population growth and the number of dwellings resulting from the same dwelling density as the Joint SHMA. The joint SHMA identified a need for 67,536 homes. The revised projections now identify 68,152 homes.


Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 74,796 36,168 +70.4%
TOTAL HMA 123,882 67,536 129,751 68,152 +4.7%

4.3 Coventry's 2011 ONS population was 316,915 and is projected by 2029 to be 391,711. This is an increase of 74,796 over the plan period. This is made up from
* The net effect of natural change which accounts for 50,734 people by 2029.
* The net effect of people moving in and out of Coventry from other parts of the UK is a net outflow of 50,592 over the plan period.
* The net effect of international migration is an inflow of 74,654 over the plan period.
However, analysis of the numbers of people in single age groups for each year from 2002 to 2029 identifies two problems with this projection.
The first is that the 2 universities currently have about 13,500 international students. Most Coventry students and many Warwick University students live in Coventry. Looking at the 17 to 20, 21 to 24, 25 to 29 and 30 to 34 age groups it was found that there was in increase in these cohort numbers of International inflow from 2005 but not a corresponding outflow. Between 2002 and 2004 the net inflow was between 3400 and 3700. From 2005 inflow increased in significant steps to 7700 by 2011. In younger and older age groups the numbers remained fairly constant for the whole period. This reflected a time when universities sought to increase international students.
There was not a corresponding change in international outflow until 2009 to 2011 but the volume of the outflow was less that the volume of the inflow 3 years earlier. This indicates that the increase in inflow may be due to international students on courses that are not yet completed.
The problem for the population projection is that the higher inflow is reflected in the population projections because it takes the 6 year average from 2007 to 2012 with the higher numbers, but a related outflow at the completion of courses has not yet begun except at a lower level. It would be expected that as courses and related academic activities for each student came to an end then the outflow would approach the previous level of inflow. Hence the projection for outflow on the same 6 year average is based on a low level. This represents a temporary student bulge that in the course of time should rectify as student turn over numbers give equating inflows and outflows.
The 2002 to 2004 net inflow was between 1000 and 2000 per year, but by 2011 and 12, this had become over 5,000 per year.
In the meantime this gives an overall increase of 74,654 due to international migration over the 18 year plan period. It does not make sense to plan to build homes for a population that is theoretical and will not be there.
If the student bulge is factored out by relating student age groups to the younger and older age groups to estimate the possible non-student element, this indicates that the total number of 74,654 will fall to between 25,000 and 40,000 depending the averaging method used. Without any other detail data this is the closest estimate that can be given. Take the worst case of 40,000 inflow due to migration, then this is still lower than the migration inflow in the Joint SHMA of 43,884.
Hence, Coventry would still have a reduced requirement over the JointSHMA of almost 9%, which would indicate that Coventry is unlikely to seek to ask neighbouring authorities to meet its housing need.
The table below shows the result.
Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 40,000 19,344 -8.85%
TOTAL HMA 123,882 67,536 94,954 51,327 +4.7%

4.4 Further detail is given in Appendix 1 pages 12 to 16.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 2.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS6
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure the Inspector is fully aware of the implications of the method by which the 2012 population projections are converted to the number of dwellings required in the plan and that a fully justified housing need is objectively assessed.
___________________________________________________________________________


DS6 states that the District will provide 12,860 homes over the plan period. This has to relate to the population projection that the up to date assessment of population growth determines.

This number needs to be revised to comply with the reduction in population growth now known.

To convert population to homes, the JointSHMA used an abstract concept of Headship rates, based on information contained in the 2011-based CLG household projections about the relationship between the total population in an age group and the number of household reference persons (HRPs) in that age group. But this is only true at the time the data is taken. HRP's can be any age and are mobile. It can only be a subjective and not an objective assessment.

It is critical because small changes in the average household size can alter homes required significantly. The JointSHMA bases its chosen headship rate on an arbitrary split between 2008 and 2011 headship rates.

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 less communal residents is added to the Joint SHMA plan,, the 2029 population becomes 156,150 plus communal. The combined dwellings total 71,603 and the resultant household size is 2.181.This is a very low figure compared with the 2011 census.

Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 21,472 = 156,150
dwellings 58,679 + 12,924 = 71,603
Persons/household 2.295 = 2.181

If the population growth is going to be less, then the household size to use needs to be addressed.

The following options could be considered -

a) If the population of 15,313 is substituted in to the table above so that the household size in 2029 remains as 2.181, then 10,100 would be needed.

b) Proportionately, the revised population growth would require 9,217 homes producing an average household size of 2.209.

c) Using census data for 2001, the average household size excluding communal was 2.32. But the 2011 size was 2.295. If the size dropped at the same rate in the next 18 years it would become 2.245. If this is used for the revised population projection, the calculation becomes
Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 15,313 = 149,991
dwellings 58,679 + 8,118 = 66,797
Persons/household 2.295 = 2.245


d) However, there is no evidence that says that any drop in household size will be at the same rate. The closer that the size gets to 1, the slower will be the reducing rate of change. If the 2011 census rate of 2.295 prevails then 6,715 homes would provide for 15,313 people.

e) Because the built home is normally constant, the size and tenure of a house, on average over time, is a better indicator of household size than the variable HRP. Given that we know from the 2011 census the number of people in the number of house of each tenure type, we have an up to date household size for each dwelling type, for example, the average household size for a detached house or bungalow was 2.585.

Further details are given in Appendix 1 pages 8 to 11 where a calculation for a typical development takes the 2011 census data for each dwelling type adds on the densities arising from Affordable homes that will be allocated to match families to the number of bedrooms they need and the market housing developers have selected the type they want to include in their development. From Page 10 in the appendix, in the example given, the average household size calculates at 2.325. So the likelihood is that the household size will rise rather than fall. If it should rise to 2.325 over the whole of the 2029 population, then only 5,785 homes will be required.

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. This is what the NPPF6 means by "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system. 7. There are three dimensions to sustainable development: economic, social and Environmental all of which should be achieved simultaneously."
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 3.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS4, DS7, DS10, DS11, NE5
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that in the selection of sites for development, compliance with all NPPF matters from provision of housing and infrastructure to protecting Green Belt, conserving the natural and historic environment is achieved.
___________________________________________________________________________


DS7 identifies 13,014 sites for a plan of 12860 homes. This has to relate to the population projection that the up to date assessment of population growth determines, so that this number needs to be revised to comply with the reduction in population growth now known.

DS7 lists sites completed between 2011 and 2013 as 406. This conflicts with a previously published number of 447 in the June 2013 % year housing land supply document.

It makes no provision for the following
1. As PPG3-036 no allowance has been made to deduct oversupply of 687 made in years previous to the start date of Apr 2011 when completions of 5,947 compared with the target was 5,260.
2. Completions of 450 in the 2013/14 financial year, listed in the rough update April 2014 is not shown.
3. No allowance is made for completions since 1st April 2014.
4. An up to date assessment of sites under construction is not included.
5. No allowance has been included for vacant dwellings returned to use since1/4/11 to date, as reported to DCLG and upon which new homes bonus has been received by the District.
6. No allowance for vacant dwellings being returned to use through the remainder of the plan period has been included.


Explanation 2.22 states that the balance of housing outside of DS7 is to be provided on allocated brownfield and greenfield sites across the District. Reference is made to DS4.



Policy NE5 Protection of Natural Resources para d) includes reference to NPPF112 concerning best & most versatile agricultural land. It is a somewhat watered down version of NPPF112 that requires LPA's to take into account the economic and other benefits of the b&mv ag land. Even where significant development of b&mv ag land is identified, it has to be demonstrated that it is necessary and seek to use poorer quality land in preference to it. Explanation clause 5.198 expands NE5d) satisfactorily until it gets to the last few lines where it alters the sense of NPPF112 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 last phrase 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.


Explanation 2.23 states that the housing strategy shows a timeline for the delivery of housing across the plan period. 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 Spatial Strategy contains statements that are not being observed.

a) 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 any (except for affordable homes on Queensway) previously developed land within the urban areas? Regeneration and enhancement sites remain to be identified in principle let alone activation. The strategy is right, but its needs to be fully implemented.

b) 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.

DS10 and DS11 sets out a list of allocated housing sites.

Taking these lists and the current programme position, the sites have been listed in appendix 2. This appendix shows that 8,482 sites have been identified as -

1. 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 up to 8482 dwellings for this set of supply categories , then no further applications need to be granted to meet the plan as there is already a surplus provision. This applies to options c), 8,118 d), 6,615 & e) 5,785 in Representation 2 from Bishop's Tachbrook Parish Council.

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.


2. This applies to the following sites (See also APPENDIX 2)

Land west of Europa Way
East of Whitnash/south of Sydenham
Campion hills
East of Kenilworth (Thickthorn)
Both Kenilworth School sites.
All villages except Bishops Tachbrook, Barford and Radford Semele
Land south of Harbury Lane, including the former sewage works which is wrongly classified under Urban Brownfield sites. In any event this is a valuable green part of the Tachbrook Valley with a significant range of ecological biodiversity implications, a series of deep tanks across the site that would make any development difficult and a slope across the site which at the proximity of the Tach Brook turns into a steep slope. It is well planted and supports a number of mammals. Otters are known in the brook.
The photo below shows the former sewage works. This is not urban brownfield.


3. The list also shows
* Grove Farm at 200 dwellings which is currently subject to appeal after refusal,
* future vacant dwellings return and
* a list of 543 C2 homes for the elderly, all of which can be counted towards the housing supply in accordance with PPG3-037.
037 How should local planning authorities deal with housing for older people?
Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.
With these it would no longer be necessary to keep the sensitive urban brownfield and sensitive greenfield shown at the end of appendix 2 in DS11.

So the 3 Kenilworth sites, land west of Europa Way and East of Whitnash/ south of Sydenham do not need to be included.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 4.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS13
5. Do you consider the Local Plan is :
5.1 Legally Compliant? Don't know
5.2 Complies with the Duty to Co-operate? No
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that best and most versatile agricultural land is protected sufficiently to conserve and enhance the Natural Environment
___________________________________________________________________________

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.

As part of the duty to cooperate, the District Council should work with the Parish Council, as we prepare our Neighbourhood Plan and in accordance with Policy NP2 stating that the Council will support communities preparing Neighbourhood Plans.

The developing Neighbourhood plan seeks to retain the agricultural economy of the land between Harbury Lane and the Tach Brook but at the same time open the area up in a limited way with a brookstray walk and habitat improvement for wildlife possibly through an extended Defra/ Natural England Stewardship scheme and a Local Greenspace designation over those stewardship areas. This could achieve the objectives in Explanation paras 2.57 but not commit to the expensive country park concept.

We doubt that the £1.5m needed to set up a Country Park, which will require car parks and facilities for the public, becoming urbanised and less friendly to wildlife, 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.




Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact.
Representation 5.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DM1
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that the Local Plan has been prepared to a realistic level that can be supported by adequate income from developments CIL and other government payments such as new homes bonus to ensure that the additional infrastructure necessary to accommodate the increased population of 15,313 people
___________________________________________________________________________

It is an important part of the local plan that the necessary infrastructure required to support the additional population has been fully identified , addressed in the plan as to where and how it will be delivered and that the costs have been assessed and a financial plan for their delivery determined.

An independent assessment of the plan for 12860 homes has been carried out by professionals concerned that this aspect is not properly covered, since the result of an inadequate financial plan would mean 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.

DM1 says it will happen but there does not appear to be a plan in place to ensure that it does. If this is the case, then the inspector, who will have to ensure that such a plan is in place, will find that it doesn't and the plan will be found unsound.

However the amount of infrastructure necessary will depend on the population to be planned for, the housing numbers necessary to meet that need and the location of housing.

Across the district currently, much of the infrastructure is fairly fully stretched. Major items such Education, Hospitals and road networks are heavily utilised. But there are parts where there is some spare capacity that new developments can utilise.

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.

For the 12,860 homes plan, our independent assessment indicates that the costs of the infrastructure required will be between £30m to £50m more than the income that will be received from section 106, CIL(when it applies), new homes bonus and other sundry incomes. This is on the assumption that the infrastructure costs are capital costs and that the revenue running costs will be met from income generated from Council tax and similar receipts.

In our assessment we have included the costs of road traffic schemes due to high concentrations of new traffic in underprovided areas, Health and hospitals, Education, sports facilities, recreational facilities , cultural and community , police and emergency services as well as parking provision for the additional users of the towns. All 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.

It will be appreciated that doing this exercise from outside the authority, much of the detail necessary is not available and it is dependent on published information from the District Councils website as to the amounts of payments so far agreed with developers on the early schemes.

Although the plan is for 12860 homes, many of these will not be paying contributions because they have been approved in advance of the programme, are affordable homes so will not be liable for payments and are part of small schemes for which 106 payments are not sought.

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. Some elements are population number dependent but lower numbers mean a smaller impact on them.

Depending on the housing number decided the assessment will to be reworked. Until thenthe plan does not have a sound infrastructure cost strategy.

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.
Paragraph: 037 Reference ID: 3-037-20140306

Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 1.
1. In responding to this consultation, the Parish Council emphasises that its sole interest is to help devise a Local Plan that is positively prepared, justified, effective and consistent with national policy, complying with the National Planning Policy Framework and the Planning Practice Guidelines published in March 2014.
2 It is our belief however that draft Local Plan is not sound in a number of aspects.
But over-riding all the matters is the fact that because the plan is based on the joint SHMA, it was only able to use the mid-2011 ONS Population Projections when it was prepared.
On the 29th May 2014, the ONS published the mid-2012 population projections. As we indicated to you at the Planning Forum before the publication draft was approved by the District Council on April 23rd, the new projections show a very significant reduction in population projection for the plan period up to 2029.
3. National planning policy places Local Plans at the heart of the planning system, so it is essential that they are in place and kept up to date. PPG12-001, NPPF157 * 2.
To start a new Local Plan based on outdated data cannot be seen as a sound plan and an Inspector will have to conclude that procedural requirements have not been met and question whether the Plan is sound.
For Warwick District, the joint SHMA uses for Proj 1A a population growth of 23,858 over 20 years, this being 21,472 over 18 years. The mid-2012 ONS projection for 2029 is 153,049, which is a population growth of 15,313 from mid 2011. This is 28.7% less than the Joint SHMA.
This is a very significant change since, amongst other things, it
* Changes the number of dwellings to meet local need
* The lower population will need commensurately less infrastructure support, optimising the use of capacity in existing infrastructure
* Changes the emphasis on the selection of sites for new housing
* Allows brownfield and regeneration sites to be committed before greenfield sites meeting NPPF112 and PPG8-026 and this also places less pressure on Green Belt.
* Can provide a deliverable plan rather than a plan that is too ambitious and unrealistic in the period of the plan
The new projections indicate that 8,343 persons are due to natural change; movement between Warwick District and the rest of the UK account for 5,971 net inflow and International migration shows a net inflow of 999 persons over the plan period.
Further detail is given in Appendix 1 pages 1 to 7.
Until the population targets are revised to the latest projections, the plan cannot be considered ready for submission to Inspection.
Explanation paragraph 2.7 in relation to DS2 commences by saying "The Council's ambitions align with national policy in recognising that housing needs are met for all. "
The parish council agrees that housing needs identified in the district based on up to date population projections should be met, but that the ambitions of the district must also be realistic. Planning practice Guidance on the definition of need, advises that
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 that there is a supply of sites for new housing is clearly necessary with affordable housing and housing that can be afforded being an important part of the plan.

But it is also important to comply with NPPF 157 Crucially, Local Plans should:
* plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework;
* identify land where development would be inappropriate, for instance because of its environmental or historic significance; and
* contain a clear strategy for enhancing the natural, built and historic environment, and supporting Nature Improvement Areas where they have been identified.

The projected population increase of 15,313 people will clearly require employment opportunities but it is also important to balance the jobs/homes ratio so that the current ratio, generally regarded as good, is maintained.

4.1 The plan has to be prepared in accordance with the Duty to Cooperate with Neighbouring authorities. This has been accomplished through a joint SHMA. The mid-2012 ONS Population projection has had a similar result for the Warwickshire Districts. There is however a possible problem with the Coventry result.

4.2 This table summarises the revised population growth and the number of dwellings resulting from the same dwelling density as the Joint SHMA. The joint SHMA identified a need for 67,536 homes. The revised projections now identify 68,152 homes.


Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 74,796 36,168 +70.4%
TOTAL HMA 123,882 67,536 129,751 68,152 +4.7%

4.3 Coventry's 2011 ONS population was 316,915 and is projected by 2029 to be 391,711. This is an increase of 74,796 over the plan period. This is made up from
* The net effect of natural change which accounts for 50,734 people by 2029.
* The net effect of people moving in and out of Coventry from other parts of the UK is a net outflow of 50,592 over the plan period.
* The net effect of international migration is an inflow of 74,654 over the plan period.
However, analysis of the numbers of people in single age groups for each year from 2002 to 2029 identifies two problems with this projection.
The first is that the 2 universities currently have about 13,500 international students. Most Coventry students and many Warwick University students live in Coventry. Looking at the 17 to 20, 21 to 24, 25 to 29 and 30 to 34 age groups it was found that there was in increase in these cohort numbers of International inflow from 2005 but not a corresponding outflow. Between 2002 and 2004 the net inflow was between 3400 and 3700. From 2005 inflow increased in significant steps to 7700 by 2011. In younger and older age groups the numbers remained fairly constant for the whole period. This reflected a time when universities sought to increase international students.
There was not a corresponding change in international outflow until 2009 to 2011 but the volume of the outflow was less that the volume of the inflow 3 years earlier. This indicates that the increase in inflow may be due to international students on courses that are not yet completed.
The problem for the population projection is that the higher inflow is reflected in the population projections because it takes the 6 year average from 2007 to 2012 with the higher numbers, but a related outflow at the completion of courses has not yet begun except at a lower level. It would be expected that as courses and related academic activities for each student came to an end then the outflow would approach the previous level of inflow. Hence the projection for outflow on the same 6 year average is based on a low level. This represents a temporary student bulge that in the course of time should rectify as student turn over numbers give equating inflows and outflows.
The 2002 to 2004 net inflow was between 1000 and 2000 per year, but by 2011 and 12, this had become over 5,000 per year.
In the meantime this gives an overall increase of 74,654 due to international migration over the 18 year plan period. It does not make sense to plan to build homes for a population that is theoretical and will not be there.
If the student bulge is factored out by relating student age groups to the younger and older age groups to estimate the possible non-student element, this indicates that the total number of 74,654 will fall to between 25,000 and 40,000 depending the averaging method used. Without any other detail data this is the closest estimate that can be given. Take the worst case of 40,000 inflow due to migration, then this is still lower than the migration inflow in the Joint SHMA of 43,884.
Hence, Coventry would still have a reduced requirement over the JointSHMA of almost 9%, which would indicate that Coventry is unlikely to seek to ask neighbouring authorities to meet its housing need.
The table below shows the result.
Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 40,000 19,344 -8.85%
TOTAL HMA 123,882 67,536 94,954 51,327 +4.7%

4.4 Further detail is given in Appendix 1 pages 12 to 16.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 2.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS6
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure the Inspector is fully aware of the implications of the method by which the 2012 population projections are converted to the number of dwellings required in the plan and that a fully justified housing need is objectively assessed.
___________________________________________________________________________


DS6 states that the District will provide 12,860 homes over the plan period. This has to relate to the population projection that the up to date assessment of population growth determines.

This number needs to be revised to comply with the reduction in population growth now known.

To convert population to homes, the JointSHMA used an abstract concept of Headship rates, based on information contained in the 2011-based CLG household projections about the relationship between the total population in an age group and the number of household reference persons (HRPs) in that age group. But this is only true at the time the data is taken. HRP's can be any age and are mobile. It can only be a subjective and not an objective assessment.

It is critical because small changes in the average household size can alter homes required significantly. The JointSHMA bases its chosen headship rate on an arbitrary split between 2008 and 2011 headship rates.

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 less communal residents is added to the Joint SHMA plan,, the 2029 population becomes 156,150 plus communal. The combined dwellings total 71,603 and the resultant household size is 2.181.This is a very low figure compared with the 2011 census.

Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 21,472 = 156,150
dwellings 58,679 + 12,924 = 71,603
Persons/household 2.295 = 2.181

If the population growth is going to be less, then the household size to use needs to be addressed.

The following options could be considered -

a) If the population of 15,313 is substituted in to the table above so that the household size in 2029 remains as 2.181, then 10,100 would be needed.

b) Proportionately, the revised population growth would require 9,217 homes producing an average household size of 2.209.

c) Using census data for 2001, the average household size excluding communal was 2.32. But the 2011 size was 2.295. If the size dropped at the same rate in the next 18 years it would become 2.245. If this is used for the revised population projection, the calculation becomes
Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 15,313 = 149,991
dwellings 58,679 + 8,118 = 66,797
Persons/household 2.295 = 2.245


d) However, there is no evidence that says that any drop in household size will be at the same rate. The closer that the size gets to 1, the slower will be the reducing rate of change. If the 2011 census rate of 2.295 prevails then 6,715 homes would provide for 15,313 people.

e) Because the built home is normally constant, the size and tenure of a house, on average over time, is a better indicator of household size than the variable HRP. Given that we know from the 2011 census the number of people in the number of house of each tenure type, we have an up to date household size for each dwelling type, for example, the average household size for a detached house or bungalow was 2.585.

Further details are given in Appendix 1 pages 8 to 11 where a calculation for a typical development takes the 2011 census data for each dwelling type adds on the densities arising from Affordable homes that will be allocated to match families to the number of bedrooms they need and the market housing developers have selected the type they want to include in their development. From Page 10 in the appendix, in the example given, the average household size calculates at 2.325. So the likelihood is that the household size will rise rather than fall. If it should rise to 2.325 over the whole of the 2029 population, then only 5,785 homes will be required.

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. This is what the NPPF6 means by "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system. 7. There are three dimensions to sustainable development: economic, social and Environmental all of which should be achieved simultaneously."
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 3.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS4, DS7, DS10, DS11, NE5
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that in the selection of sites for development, compliance with all NPPF matters from provision of housing and infrastructure to protecting Green Belt, conserving the natural and historic environment is achieved.
___________________________________________________________________________


DS7 identifies 13,014 sites for a plan of 12860 homes. This has to relate to the population projection that the up to date assessment of population growth determines, so that this number needs to be revised to comply with the reduction in population growth now known.

DS7 lists sites completed between 2011 and 2013 as 406. This conflicts with a previously published number of 447 in the June 2013 % year housing land supply document.

It makes no provision for the following
1. As PPG3-036 no allowance has been made to deduct oversupply of 687 made in years previous to the start date of Apr 2011 when completions of 5,947 compared with the target was 5,260.
2. Completions of 450 in the 2013/14 financial year, listed in the rough update April 2014 is not shown.
3. No allowance is made for completions since 1st April 2014.
4. An up to date assessment of sites under construction is not included.
5. No allowance has been included for vacant dwellings returned to use since1/4/11 to date, as reported to DCLG and upon which new homes bonus has been received by the District.
6. No allowance for vacant dwellings being returned to use through the remainder of the plan period has been included.


Explanation 2.22 states that the balance of housing outside of DS7 is to be provided on allocated brownfield and greenfield sites across the District. Reference is made to DS4.



Policy NE5 Protection of Natural Resources para d) includes reference to NPPF112 concerning best & most versatile agricultural land. It is a somewhat watered down version of NPPF112 that requires LPA's to take into account the economic and other benefits of the b&mv ag land. Even where significant development of b&mv ag land is identified, it has to be demonstrated that it is necessary and seek to use poorer quality land in preference to it. Explanation clause 5.198 expands NE5d) satisfactorily until it gets to the last few lines where it alters the sense of NPPF112 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 last phrase 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.


Explanation 2.23 states that the housing strategy shows a timeline for the delivery of housing across the plan period. 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 Spatial Strategy contains statements that are not being observed.

a) 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 any (except for affordable homes on Queensway) previously developed land within the urban areas? Regeneration and enhancement sites remain to be identified in principle let alone activation. The strategy is right, but its needs to be fully implemented.

b) 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.

DS10 and DS11 sets out a list of allocated housing sites.

Taking these lists and the current programme position, the sites have been listed in appendix 2. This appendix shows that 8,482 sites have been identified as -

1. 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 up to 8482 dwellings for this set of supply categories , then no further applications need to be granted to meet the plan as there is already a surplus provision. This applies to options c), 8,118 d), 6,615 & e) 5,785 in Representation 2 from Bishop's Tachbrook Parish Council.

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.


2. This applies to the following sites (See also APPENDIX 2)

Land west of Europa Way
East of Whitnash/south of Sydenham
Campion hills
East of Kenilworth (Thickthorn)
Both Kenilworth School sites.
All villages except Bishops Tachbrook, Barford and Radford Semele
Land south of Harbury Lane, including the former sewage works which is wrongly classified under Urban Brownfield sites. In any event this is a valuable green part of the Tachbrook Valley with a significant range of ecological biodiversity implications, a series of deep tanks across the site that would make any development difficult and a slope across the site which at the proximity of the Tach Brook turns into a steep slope. It is well planted and supports a number of mammals. Otters are known in the brook.
The photo below shows the former sewage works. This is not urban brownfield.


3. The list also shows
* Grove Farm at 200 dwellings which is currently subject to appeal after refusal,
* future vacant dwellings return and
* a list of 543 C2 homes for the elderly, all of which can be counted towards the housing supply in accordance with PPG3-037.
037 How should local planning authorities deal with housing for older people?
Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.
With these it would no longer be necessary to keep the sensitive urban brownfield and sensitive greenfield shown at the end of appendix 2 in DS11.

So the 3 Kenilworth sites, land west of Europa Way and East of Whitnash/ south of Sydenham do not need to be included.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 4.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS13
5. Do you consider the Local Plan is :
5.1 Legally Compliant? Don't know
5.2 Complies with the Duty to Co-operate? No
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that best and most versatile agricultural land is protected sufficiently to conserve and enhance the Natural Environment
___________________________________________________________________________

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.

As part of the duty to cooperate, the District Council should work with the Parish Council, as we prepare our Neighbourhood Plan and in accordance with Policy NP2 stating that the Council will support communities preparing Neighbourhood Plans.

The developing Neighbourhood plan seeks to retain the agricultural economy of the land between Harbury Lane and the Tach Brook but at the same time open the area up in a limited way with a brookstray walk and habitat improvement for wildlife possibly through an extended Defra/ Natural England Stewardship scheme and a Local Greenspace designation over those stewardship areas. This could achieve the objectives in Explanation paras 2.57 but not commit to the expensive country park concept.

We doubt that the £1.5m needed to set up a Country Park, which will require car parks and facilities for the public, becoming urbanised and less friendly to wildlife, 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.




Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact.
Representation 5.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DM1
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that the Local Plan has been prepared to a realistic level that can be supported by adequate income from developments CIL and other government payments such as new homes bonus to ensure that the additional infrastructure necessary to accommodate the increased population of 15,313 people
___________________________________________________________________________

It is an important part of the local plan that the necessary infrastructure required to support the additional population has been fully identified , addressed in the plan as to where and how it will be delivered and that the costs have been assessed and a financial plan for their delivery determined.

An independent assessment of the plan for 12860 homes has been carried out by professionals concerned that this aspect is not properly covered, since the result of an inadequate financial plan would mean 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.

DM1 says it will happen but there does not appear to be a plan in place to ensure that it does. If this is the case, then the inspector, who will have to ensure that such a plan is in place, will find that it doesn't and the plan will be found unsound.

However the amount of infrastructure necessary will depend on the population to be planned for, the housing numbers necessary to meet that need and the location of housing.

Across the district currently, much of the infrastructure is fairly fully stretched. Major items such Education, Hospitals and road networks are heavily utilised. But there are parts where there is some spare capacity that new developments can utilise.

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.

For the 12,860 homes plan, our independent assessment indicates that the costs of the infrastructure required will be between £30m to £50m more than the income that will be received from section 106, CIL(when it applies), new homes bonus and other sundry incomes. This is on the assumption that the infrastructure costs are capital costs and that the revenue running costs will be met from income generated from Council tax and similar receipts.

In our assessment we have included the costs of road traffic schemes due to high concentrations of new traffic in underprovided areas, Health and hospitals, Education, sports facilities, recreational facilities , cultural and community , police and emergency services as well as parking provision for the additional users of the towns. All 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.

It will be appreciated that doing this exercise from outside the authority, much of the detail necessary is not available and it is dependent on published information from the District Councils website as to the amounts of payments so far agreed with developers on the early schemes.

Although the plan is for 12860 homes, many of these will not be paying contributions because they have been approved in advance of the programme, are affordable homes so will not be liable for payments and are part of small schemes for which 106 payments are not sought.

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. Some elements are population number dependent but lower numbers mean a smaller impact on them.

Depending on the housing number decided the assessment will to be reworked. Until thenthe plan does not have a sound infrastructure cost strategy.

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.
Paragraph: 037 Reference ID: 3-037-20140306

Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 1.
1. In responding to this consultation, the Parish Council emphasises that its sole interest is to help devise a Local Plan that is positively prepared, justified, effective and consistent with national policy, complying with the National Planning Policy Framework and the Planning Practice Guidelines published in March 2014.
2 It is our belief however that draft Local Plan is not sound in a number of aspects.
But over-riding all the matters is the fact that because the plan is based on the joint SHMA, it was only able to use the mid-2011 ONS Population Projections when it was prepared.
On the 29th May 2014, the ONS published the mid-2012 population projections. As we indicated to you at the Planning Forum before the publication draft was approved by the District Council on April 23rd, the new projections show a very significant reduction in population projection for the plan period up to 2029.
3. National planning policy places Local Plans at the heart of the planning system, so it is essential that they are in place and kept up to date. PPG12-001, NPPF157 * 2.
To start a new Local Plan based on outdated data cannot be seen as a sound plan and an Inspector will have to conclude that procedural requirements have not been met and question whether the Plan is sound.
For Warwick District, the joint SHMA uses for Proj 1A a population growth of 23,858 over 20 years, this being 21,472 over 18 years. The mid-2012 ONS projection for 2029 is 153,049, which is a population growth of 15,313 from mid 2011. This is 28.7% less than the Joint SHMA.
This is a very significant change since, amongst other things, it
* Changes the number of dwellings to meet local need
* The lower population will need commensurately less infrastructure support, optimising the use of capacity in existing infrastructure
* Changes the emphasis on the selection of sites for new housing
* Allows brownfield and regeneration sites to be committed before greenfield sites meeting NPPF112 and PPG8-026 and this also places less pressure on Green Belt.
* Can provide a deliverable plan rather than a plan that is too ambitious and unrealistic in the period of the plan
The new projections indicate that 8,343 persons are due to natural change; movement between Warwick District and the rest of the UK account for 5,971 net inflow and International migration shows a net inflow of 999 persons over the plan period.
Further detail is given in Appendix 1 pages 1 to 7.
Until the population targets are revised to the latest projections, the plan cannot be considered ready for submission to Inspection.
Explanation paragraph 2.7 in relation to DS2 commences by saying "The Council's ambitions align with national policy in recognising that housing needs are met for all. "
The parish council agrees that housing needs identified in the district based on up to date population projections should be met, but that the ambitions of the district must also be realistic. Planning practice Guidance on the definition of need, advises that
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 that there is a supply of sites for new housing is clearly necessary with affordable housing and housing that can be afforded being an important part of the plan.

But it is also important to comply with NPPF 157 Crucially, Local Plans should:
* plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework;
* identify land where development would be inappropriate, for instance because of its environmental or historic significance; and
* contain a clear strategy for enhancing the natural, built and historic environment, and supporting Nature Improvement Areas where they have been identified.

The projected population increase of 15,313 people will clearly require employment opportunities but it is also important to balance the jobs/homes ratio so that the current ratio, generally regarded as good, is maintained.

4.1 The plan has to be prepared in accordance with the Duty to Cooperate with Neighbouring authorities. This has been accomplished through a joint SHMA. The mid-2012 ONS Population projection has had a similar result for the Warwickshire Districts. There is however a possible problem with the Coventry result.

4.2 This table summarises the revised population growth and the number of dwellings resulting from the same dwelling density as the Joint SHMA. The joint SHMA identified a need for 67,536 homes. The revised projections now identify 68,152 homes.


Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 74,796 36,168 +70.4%
TOTAL HMA 123,882 67,536 129,751 68,152 +4.7%

4.3 Coventry's 2011 ONS population was 316,915 and is projected by 2029 to be 391,711. This is an increase of 74,796 over the plan period. This is made up from
* The net effect of natural change which accounts for 50,734 people by 2029.
* The net effect of people moving in and out of Coventry from other parts of the UK is a net outflow of 50,592 over the plan period.
* The net effect of international migration is an inflow of 74,654 over the plan period.
However, analysis of the numbers of people in single age groups for each year from 2002 to 2029 identifies two problems with this projection.
The first is that the 2 universities currently have about 13,500 international students. Most Coventry students and many Warwick University students live in Coventry. Looking at the 17 to 20, 21 to 24, 25 to 29 and 30 to 34 age groups it was found that there was in increase in these cohort numbers of International inflow from 2005 but not a corresponding outflow. Between 2002 and 2004 the net inflow was between 3400 and 3700. From 2005 inflow increased in significant steps to 7700 by 2011. In younger and older age groups the numbers remained fairly constant for the whole period. This reflected a time when universities sought to increase international students.
There was not a corresponding change in international outflow until 2009 to 2011 but the volume of the outflow was less that the volume of the inflow 3 years earlier. This indicates that the increase in inflow may be due to international students on courses that are not yet completed.
The problem for the population projection is that the higher inflow is reflected in the population projections because it takes the 6 year average from 2007 to 2012 with the higher numbers, but a related outflow at the completion of courses has not yet begun except at a lower level. It would be expected that as courses and related academic activities for each student came to an end then the outflow would approach the previous level of inflow. Hence the projection for outflow on the same 6 year average is based on a low level. This represents a temporary student bulge that in the course of time should rectify as student turn over numbers give equating inflows and outflows.
The 2002 to 2004 net inflow was between 1000 and 2000 per year, but by 2011 and 12, this had become over 5,000 per year.
In the meantime this gives an overall increase of 74,654 due to international migration over the 18 year plan period. It does not make sense to plan to build homes for a population that is theoretical and will not be there.
If the student bulge is factored out by relating student age groups to the younger and older age groups to estimate the possible non-student element, this indicates that the total number of 74,654 will fall to between 25,000 and 40,000 depending the averaging method used. Without any other detail data this is the closest estimate that can be given. Take the worst case of 40,000 inflow due to migration, then this is still lower than the migration inflow in the Joint SHMA of 43,884.
Hence, Coventry would still have a reduced requirement over the JointSHMA of almost 9%, which would indicate that Coventry is unlikely to seek to ask neighbouring authorities to meet its housing need.
The table below shows the result.
Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 40,000 19,344 -8.85%
TOTAL HMA 123,882 67,536 94,954 51,327 +4.7%

4.4 Further detail is given in Appendix 1 pages 12 to 16.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 2.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS6
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure the Inspector is fully aware of the implications of the method by which the 2012 population projections are converted to the number of dwellings required in the plan and that a fully justified housing need is objectively assessed.
___________________________________________________________________________


DS6 states that the District will provide 12,860 homes over the plan period. This has to relate to the population projection that the up to date assessment of population growth determines.

This number needs to be revised to comply with the reduction in population growth now known.

To convert population to homes, the JointSHMA used an abstract concept of Headship rates, based on information contained in the 2011-based CLG household projections about the relationship between the total population in an age group and the number of household reference persons (HRPs) in that age group. But this is only true at the time the data is taken. HRP's can be any age and are mobile. It can only be a subjective and not an objective assessment.

It is critical because small changes in the average household size can alter homes required significantly. The JointSHMA bases its chosen headship rate on an arbitrary split between 2008 and 2011 headship rates.

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 less communal residents is added to the Joint SHMA plan,, the 2029 population becomes 156,150 plus communal. The combined dwellings total 71,603 and the resultant household size is 2.181.This is a very low figure compared with the 2011 census.

Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 21,472 = 156,150
dwellings 58,679 + 12,924 = 71,603
Persons/household 2.295 = 2.181

If the population growth is going to be less, then the household size to use needs to be addressed.

The following options could be considered -

a) If the population of 15,313 is substituted in to the table above so that the household size in 2029 remains as 2.181, then 10,100 would be needed.

b) Proportionately, the revised population growth would require 9,217 homes producing an average household size of 2.209.

c) Using census data for 2001, the average household size excluding communal was 2.32. But the 2011 size was 2.295. If the size dropped at the same rate in the next 18 years it would become 2.245. If this is used for the revised population projection, the calculation becomes
Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 15,313 = 149,991
dwellings 58,679 + 8,118 = 66,797
Persons/household 2.295 = 2.245


d) However, there is no evidence that says that any drop in household size will be at the same rate. The closer that the size gets to 1, the slower will be the reducing rate of change. If the 2011 census rate of 2.295 prevails then 6,715 homes would provide for 15,313 people.

e) Because the built home is normally constant, the size and tenure of a house, on average over time, is a better indicator of household size than the variable HRP. Given that we know from the 2011 census the number of people in the number of house of each tenure type, we have an up to date household size for each dwelling type, for example, the average household size for a detached house or bungalow was 2.585.

Further details are given in Appendix 1 pages 8 to 11 where a calculation for a typical development takes the 2011 census data for each dwelling type adds on the densities arising from Affordable homes that will be allocated to match families to the number of bedrooms they need and the market housing developers have selected the type they want to include in their development. From Page 10 in the appendix, in the example given, the average household size calculates at 2.325. So the likelihood is that the household size will rise rather than fall. If it should rise to 2.325 over the whole of the 2029 population, then only 5,785 homes will be required.

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. This is what the NPPF6 means by "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system. 7. There are three dimensions to sustainable development: economic, social and Environmental all of which should be achieved simultaneously."
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 3.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS4, DS7, DS10, DS11, NE5
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that in the selection of sites for development, compliance with all NPPF matters from provision of housing and infrastructure to protecting Green Belt, conserving the natural and historic environment is achieved.
___________________________________________________________________________


DS7 identifies 13,014 sites for a plan of 12860 homes. This has to relate to the population projection that the up to date assessment of population growth determines, so that this number needs to be revised to comply with the reduction in population growth now known.

DS7 lists sites completed between 2011 and 2013 as 406. This conflicts with a previously published number of 447 in the June 2013 % year housing land supply document.

It makes no provision for the following
1. As PPG3-036 no allowance has been made to deduct oversupply of 687 made in years previous to the start date of Apr 2011 when completions of 5,947 compared with the target was 5,260.
2. Completions of 450 in the 2013/14 financial year, listed in the rough update April 2014 is not shown.
3. No allowance is made for completions since 1st April 2014.
4. An up to date assessment of sites under construction is not included.
5. No allowance has been included for vacant dwellings returned to use since1/4/11 to date, as reported to DCLG and upon which new homes bonus has been received by the District.
6. No allowance for vacant dwellings being returned to use through the remainder of the plan period has been included.


Explanation 2.22 states that the balance of housing outside of DS7 is to be provided on allocated brownfield and greenfield sites across the District. Reference is made to DS4.



Policy NE5 Protection of Natural Resources para d) includes reference to NPPF112 concerning best & most versatile agricultural land. It is a somewhat watered down version of NPPF112 that requires LPA's to take into account the economic and other benefits of the b&mv ag land. Even where significant development of b&mv ag land is identified, it has to be demonstrated that it is necessary and seek to use poorer quality land in preference to it. Explanation clause 5.198 expands NE5d) satisfactorily until it gets to the last few lines where it alters the sense of NPPF112 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 last phrase 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.


Explanation 2.23 states that the housing strategy shows a timeline for the delivery of housing across the plan period. 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 Spatial Strategy contains statements that are not being observed.

a) 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 any (except for affordable homes on Queensway) previously developed land within the urban areas? Regeneration and enhancement sites remain to be identified in principle let alone activation. The strategy is right, but its needs to be fully implemented.

b) 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.

DS10 and DS11 sets out a list of allocated housing sites.

Taking these lists and the current programme position, the sites have been listed in appendix 2. This appendix shows that 8,482 sites have been identified as -

1. 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 up to 8482 dwellings for this set of supply categories , then no further applications need to be granted to meet the plan as there is already a surplus provision. This applies to options c), 8,118 d), 6,615 & e) 5,785 in Representation 2 from Bishop's Tachbrook Parish Council.

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.


2. This applies to the following sites (See also APPENDIX 2)

Land west of Europa Way
East of Whitnash/south of Sydenham
Campion hills
East of Kenilworth (Thickthorn)
Both Kenilworth School sites.
All villages except Bishops Tachbrook, Barford and Radford Semele
Land south of Harbury Lane, including the former sewage works which is wrongly classified under Urban Brownfield sites. In any event this is a valuable green part of the Tachbrook Valley with a significant range of ecological biodiversity implications, a series of deep tanks across the site that would make any development difficult and a slope across the site which at the proximity of the Tach Brook turns into a steep slope. It is well planted and supports a number of mammals. Otters are known in the brook.
The photo below shows the former sewage works. This is not urban brownfield.


3. The list also shows
* Grove Farm at 200 dwellings which is currently subject to appeal after refusal,
* future vacant dwellings return and
* a list of 543 C2 homes for the elderly, all of which can be counted towards the housing supply in accordance with PPG3-037.
037 How should local planning authorities deal with housing for older people?
Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.
With these it would no longer be necessary to keep the sensitive urban brownfield and sensitive greenfield shown at the end of appendix 2 in DS11.

So the 3 Kenilworth sites, land west of Europa Way and East of Whitnash/ south of Sydenham do not need to be included.


Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 4.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS13
5. Do you consider the Local Plan is :
5.1 Legally Compliant? Don't know
5.2 Complies with the Duty to Co-operate? No
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that best and most versatile agricultural land is protected sufficiently to conserve and enhance the Natural Environment
___________________________________________________________________________

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.

As part of the duty to cooperate, the District Council should work with the Parish Council, as we prepare our Neighbourhood Plan and in accordance with Policy NP2 stating that the Council will support communities preparing Neighbourhood Plans.

The developing Neighbourhood plan seeks to retain the agricultural economy of the land between Harbury Lane and the Tach Brook but at the same time open the area up in a limited way with a brookstray walk and habitat improvement for wildlife possibly through an extended Defra/ Natural England Stewardship scheme and a Local Greenspace designation over those stewardship areas. This could achieve the objectives in Explanation paras 2.57 but not commit to the expensive country park concept.

We doubt that the £1.5m needed to set up a Country Park, which will require car parks and facilities for the public, becoming urbanised and less friendly to wildlife, 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.




Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029

Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact.
Representation 5.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DM1
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that the Local Plan has been prepared to a realistic level that can be supported by adequate income from developments CIL and other government payments such as new homes bonus to ensure that the additional infrastructure necessary to accommodate the increased population of 15,313 people
___________________________________________________________________________

It is an important part of the local plan that the necessary infrastructure required to support the additional population has been fully identified , addressed in the plan as to where and how it will be delivered and that the costs have been assessed and a financial plan for their delivery determined.

An independent assessment of the plan for 12860 homes has been carried out by professionals concerned that this aspect is not properly covered, since the result of an inadequate financial plan would mean 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.

DM1 says it will happen but there does not appear to be a plan in place to ensure that it does. If this is the case, then the inspector, who will have to ensure that such a plan is in place, will find that it doesn't and the plan will be found unsound.

However the amount of infrastructure necessary will depend on the population to be planned for, the housing numbers necessary to meet that need and the location of housing.

Across the district currently, much of the infrastructure is fairly fully stretched. Major items such Education, Hospitals and road networks are heavily utilised. But there are parts where there is some spare capacity that new developments can utilise.

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.

For the 12,860 homes plan, our independent assessment indicates that the costs of the infrastructure required will be between £30m to £50m more than the income that will be received from section 106, CIL(when it applies), new homes bonus and other sundry incomes. This is on the assumption that the infrastructure costs are capital costs and that the revenue running costs will be met from income generated from Council tax and similar receipts.

In our assessment we have included the costs of road traffic schemes due to high concentrations of new traffic in underprovided areas, Health and hospitals, Education, sports facilities, recreational facilities , cultural and community , police and emergency services as well as parking provision for the additional users of the towns. All 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.

It will be appreciated that doing this exercise from outside the authority, much of the detail necessary is not available and it is dependent on published information from the District Councils website as to the amounts of payments so far agreed with developers on the early schemes.

Although the plan is for 12860 homes, many of these will not be paying contributions because they have been approved in advance of the programme, are affordable homes so will not be liable for payments and are part of small schemes for which 106 payments are not sought.

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. Some elements are population number dependent but lower numbers mean a smaller impact on them.

Depending on the housing number decided the assessment will to be reworked. Until thenthe plan does not have a sound infrastructure cost strategy.

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.
Paragraph: 037 Reference ID: 3-037-20140306