Publication Draft

Object

Representation ID: 66083

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

Legally compliant? Yes

Sound? Yes

Duty to co-operate? No

Strategic Policy DS2 refers to the need to provide in full for the objectively assessed housing need. However, it does not plan for any un met need in the surrounding areas. The Plan goes on to recognise a potential un met need in Coventry and Birmingham. The Strategic Policy should recognise the potential need in this regard.

Support

Representation ID: 66084

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

Gleeson supports the spatial strategy out in the Plan, concentrating the majority of growth to the most sustainable locations, namely Warwick, Leamington Spa and Kenilworth. The Proposed Publication Draft Plan is in accordance with the "golden thread" running through the planning system of sustainable development. Moreover, the Plan seeks to utilise brownfield or previously developed sites prior to building on Greenfield sites. Development on the two existing school sites in Kenilworth accords with this advice given their brownfield nature.

Support

Representation ID: 66085

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

Policy DS5, is entirely consistent with paragraph 14 of the NPPF. The Council's presumption in favour of sustainable development and the need for sustainable economic growth is entirely consistent with paragraph 14 of the NPPF and is supported.

Object

Representation ID: 66086

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan recognises that other authorities in the Housing Market area are at differing stages of the Plan preparation. There may be a need to take unmet need from other planning authority areas, most noticeably from Coventry and Birmingham. Indeed, the earlier versions of the Core Strategy proposed accommodating a significant proportion of housing from Coventry within Warwick District. The Council proposes to deal with this potential unmet need via a possible early review.

However Policy DS6 is considered unsound as it fails to acknowledge the need to potentially accommodate an element of unmet need from nearby districts.

Support

Representation ID: 66087

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

The distribution of housing across the District and especially to Kenilworth on both urban Brownfield sites and Greenfield sites on the edge of the town reflects the identified need/demand findings of the SHMA. It also accords with the "golden thread" of sustainable development set out in the NPPF.

Object

Representation ID: 66088

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Whilst the proposed allocation of site ED02 - Southcrest Farm for a new Secondary School and 6th Form Centre is supported, the site should not appear in the list under Policy DS11 because it is not a Housing Site. It is correctly allocated under policy DS12.

Support

Representation ID: 66089

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

Inline with Policy DS19, the Council has identified that Southcrest Farm will be removed from the Green Belt in accordance with the exceptional circumstances set out in the NPPF. This is entirely in accordance with NPPF policy. However, should the land swap between Southcrest Farm and the two Kenilworth school sites not take place, the land at Southcrest Farm should be "safeguarded" in accordance with paragraph 85 of the NPPF to meet longer term development needs both within the current plan period and beyond in accordance with the NPPF. This would either be to meet unmet needs for housing and/or educational uses arising out of the failure to deliver the proposed level of housing at Thickthorn and the two existing school sites.

Object

Representation ID: 66090

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy DS20 picks up on the potential for meeting any un met housing need arising outside of Warwick District. There is a high potential that such a situation will exist, for example to meet the housing needs of Coventry, Stratford-upon-Avon and Birmingham. Indeed, Coventry had previously been considering around 3,500 houses on a strategic site to the north of Warwick District. Having progressed a Core Strategy with significantly reduced housing figures than the RSS figures, the Plan was withdrawn partly due to lack of a joint Strategic Housing Market Assessment. Similarly Stratford-upon-Avon is currently proposing a housing figure around 700 houses short of its objectively assessed need figure. Birmingham City Council has indicated a need for between 80,000 to 105,000 houses over a plan period up to 2031, but with an identified capacity to accommodate only 43,000 houses, with a further 6,000 if a review of Green Belt was undertaken.


The NPPG states at paragraph 12-008-20140306 that "Local planning authorities should also consider whether a plan making activity by other authorities has an impact on planning and the Local Plan in their area. For example, a revised Strategic Housing Market Assessment will affect all authorities in that housing market area and potentially beyond, irrespective of the status or stage of development of particular Local Plans."

Given the above, the first sentence of Policy DS20 "The existence of unmet housing need arising outside of the District will not render this Plan out of date...." conflicts with the advice in the
NPPG.

Object

Representation ID: 66091

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Criteria a) should include reference to not only meeting the Objectively Assessed Need for housing in the District, but also, where necessary, any unmet need arising from outside of the District.

Object

Representation ID: 66092

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy H2 refers to a need for a minimum of 40% affordable housing to meet the local needs. However, the evidence base does not justify this level of affordable housing. Indeed, the Base Line Market Position in the Viability Assessment Final Report (Nov 2011 DTZ) which pre-dates the NPPF and NPPG confirms that no development was viable at 40% (paragraph 10.6). Paragraph 10.8 of the Affordable housing Viability Assessment states: "....DTZ would suggest Warwick District Council consider producing a zoned affordable housing policy which has different affordable housing percentages by area."

This stance should be considered in policy H2. Policy H2 should therefore be re-written to ensure that the level of affordable housing renders development viable.