Publication Draft

Object

Representation ID: 65695

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy sets out requirement for 12,860 homes over Plan period 2011-2029, equating to 720 dwellings per annum.
Proposed housing requirements drawn from 2014 Coventry and Warwickshire Joint SHMA. The Joint SHMA covers local authority areas of Rugby, Coventry, Warwick, North Warwickshire, Nuneaton and Bedworth and Stratford-on-Avon and identifies a mid-point of need of 3,750 dpa based on 2011 and 2008 headship rates as representing a reasonable level of provision on which to base the housing needs of the HMA. Preparation of the Joint SHMA comes after the withdrawal of Coventry's Core Strategy in 2012, particularly in light of lack of consistent/joint approach to meeting housing needs of the area and failure to discharge the authority's Duty to Cooperate.
Reviewing the housing requirements in the Local Plan and the findings of the joint SHMA, submit that proposed WDLP - Publication Draft Consultation housing requirements set out in Policy DS6 are too low to meet housing needs of the district and are not based on robust evidence. Whilst welcoming the SHMA, we submit that the assessment of the housing needs it provides for the HMA and the district underestimates level of housing required to support future demographic needs and economic potential. Whilst SHMA recognises the need to address market signals, query whether these have been properly factored into future assessment of housing needs, whilst noting proposed housing needs for HMA will be insufficient to meet affordable housing for the area as a whole. Strongly submit that the Council has underestimated future level of housing that must be provided.
Aware of independent objective assessment of housing needs for Coventry and Warwickshire HMA. Incorporating critique of Joint SHMA, the Coventry and Warwickshire Sub-Regional Housing Study finds that to meet the full objectively assessed needs of the HMA and Warwick District, an overall housing requirement of at least 5,100 dpa, based on an economic-led modelling scenario linked to economic forecasts used in the Coventry and Warwickshire LEP Strategic Economic Plan. Consultants find this level of housing growth would enable demographic needs to be met, forecasted ecomic growth to be accommodated, sufficient affordable housing to be supplied and make a significant contribution towards addressing adverse market signals in the area. Translated into requirements for individual authorities in the HMA, this would require a housing requirement of 18,000 dwellings to be provided through the Warwick LP, equating to 900 dpa.
To be found sound at Examination the Warwick District LP must be based on effective joint working on cross boundary strategic issues. In this regard the LP and Coventry and Warwickshire SHMA discuss and recognise the issue of cross-boundary housing needs within the HMA and unmet requirements arising from neighbouring authority areas. Policy DS20 specifically describes the work that has taken place between the Council and other authorities within the Coventry and Warwickshire HMA to agree a process for addressing unmet needs from one or more of the HMA authorities should they arise. Outside of the HMA, the LP also identifies that there may be an issue of unmet housing needs arising from the Greater Birmingham area.
Whilst welcoming the Council's willingness to work with its neighbouring authorities to address unmet housing needs, submit that the actions proposed by the LP and the Coventry and Warwickshire Joint Committee are not sufficient. There is a long-standing and existing acknowledgement that Coventry will be unable to meet the housing needs in its own administrative area, with a report to the Coventry and Warwickshire Joint Committee on 20th March 2014 clearly stating that "there is a significant risk that Coventry City Council will not be able to accommodate 23,600 dwellings (1,180 dpa) within the City boundary". The submission draft of Birmingham City Council's LDP also identifies an initial shortfall of 29,000 dwellings against its full objectively assessed needs. There is therefore a clear requirement for effective working to be undertaken to address these needs now, and for a positive response through the LP to meet them.
In light of the need to provide for a higher housing requirement in the district, submit that Policy DS6 is not positively prepared as it fails to propose a sufficient level of housing to meet Warwick's needs and those of it surrounding neighbours. LP not justified as it is not supported by robust assessment of full objectively assessed needs for the district, and is not effective as it fails to adequately address cross-boundary housing issues. In a number of instances Council's approach is not consistent with the requirements of the Framework.To be considered sound, submit that proposed housing requirements set out in the LP should be increased, at least being consistent with the assessment of the district's housing needs prepared by consultants. To address unmet housing needs already acknowledged to exist in relation to Coventry and Birmingham there is need for action to address these unmet needs now, rather than deferring this to future work or a review of the Local Plan.
In light of our concerns over the adequacy of the Council's proposed housing requirement, reserve the right to undertake an independent objective assessment of the authority's housing needs, consistent with the requirements of the Framework and the PPG on Housing and Economic Development Needs Assessments, and submit this to the Local Plan Examination.

Object

Representation ID: 66275

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

District Council has not made adequate provision to meet full and objectively assessed needs for market and affordable housing (para 47 of NPPF). Quantum of housing development needs to be substantially increased and the distribution of provision needs to be amended to release more housing in sustainable rural locations such as Growth Villages to achieve core planning principles set down in NPPF (paragraph 17) and requirement to deliver wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities (NPPF, paragraph 50). Even if quantum of housing not increased, distribution of housing growth needs to be reconsidered to allow more housing growth to take place within sustainable rural locations such as Growth Villages
RDS (June 2013) recognised (Policy RDS3) desirability of distributing growth across District, including within and/or on edge of some villages, and allowed for a hierarchy of growth in rural area to include higher level of growth in larger, more sustainable villages with services. RDS provided for circa 1,000 dwellings to be provided in the then designated Primary/Secondary Service Villages and subsequent appraisal work does not remove need to provide for more housing across the District, in order to meet requirements of NPPF/Council's own objectives. Appraisal work does not justify reducing amount of housing to be directed to larger, more sustainable villages.

Object

Representation ID: 66465

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Alongside dwellings already completed and comitted 393 dwellings are expected to come forward from small urban sites and 269 homes from the consolidation of existing employment areas. Significant proportion of future housing needs are proposed to be met through sites allocated through the LP, whilst a windfall allowance of 2,485 dwellings for Plan period is also identified.
Submit that there is need to identify further housing sites in Warwick, over and above those already identified through LP, consistent with need to meet a higher housing requirement to meet the authority's full objectively assessed needs. If Council cannot demonstrate sufficient supply of deliverable/developable housing sites to meet authority's housing needs over the Plan period, the LP cannot be considered effective.
Council cannot currently demonstrate five year housing land supply. As shown in the Council's most recent Five Year Housing Land Supply Assessment report published in July 2013, the Council could only demonstrate a 2.8 year supply against previous emerging LP target of 683 dpa. Whilst LP Housing Trajectory paper shows that more commitments have since come forward, based on making up the delivery that has already occurred since the start of the LP period over the next five years and factoring in a 20% buffer for persistent under-delivery,question whether Council will not be able to demonstrate a five-year supply against its proposed requirement going forward. If sites proposed to be allocated through the LP are taken into consideration, this is still likely to be the case.
Council's strategy heavily reliant on delivery of three large SUEs on Land West of Europa Way, Land South of Harbury Lane and East of Kenilworth. Collectively these are anticipated to deliver 3,395 dwellings, representing 54% of the sites to be allocated through the LP. Whilst supporting general principle of SUEs and their sustainability benefits, submit that sites can often be slow coming forward, delivering housing at slower rate than anticipated and failing to deliver level of home envisaged. Council should ensure that it has allowed for sufficient contingency in LP housing supply, providing flexibility for sites that do not come forward as planned.
Whilst recognising ability for local authorities to make allowance for windfall sites in their housing land supply, we remind the Council that it must ensure that its windfall assumptions are appropriately justified and based on a robust understanding of how windfall sites are likely to continue to come forward, alongside other identified commitments and housing allocations.
Conclusions on Soundness
Submit that in its current form the LP is not effective, as it fails to identify sufficient deliverable/developable housing sites that can come forward over the Plan period to meet the authority's full objectively assessed needs. Council cannot currently demonstrate five-year housing land supply. Whilst recognising that further commitments have come forward since publication of latest Five Year Housing Land Supply Assessment report and envisaged supply of housing provided through the LP, submit that this is likely to continue to be the case. Whilst recognising that the LP already provides an element of flexibility in its proposed housing supply, submit that this will not be sufficient to meet the authority's housing needs.
To be found sound at Examination submit that there is need to identify further deliverable/developable sites, in particular that can come forward in the short term in sustainable locations. Remind Council that if it is not able to demonstrate a five year housing land supply at the time of the LPs adoption, its policies for the supply of housing will be out-of-date as soon as they are intended to come into effect.

Support

Representation ID: 66466

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Policy directs 1,330 dwellings to brownfield sites within the urban areas of the district's settlements, 850 dwellings to greenfield sites on the edge of Kenilworth, 3,245 dwellings to greenfield locations on the edge of Warwick, Leamington and Whitnash, and 763 dwellings to sites within the districts Growth Villages and rural area.
LP explains proposed spatial strategy aims to meet housing needs by allocating sites across towns and in more sustainable villages. Seeks to maximise use of brownfield land by directing allocations to pd sites in urban areas first, bring forward greenfield sites where these are in sustainable locations, and avoid coalescence between settlements. Sets out that Green Belt sites will be limited to locations where exceptional circumstances can be justified.
Policy Analysis
Generally supportive of distribution strategy. Growth should be directed to key towns and villages with established services/facilities, ensuring creation of sustainable communities that have good access to range of jobs, community facilities, key services and infrastructure. However should not overlook need for further development in lower order sustainable settlements that could help to sustain existing services/facilities. Submit that further growth should be directed to identified Growth Villages, particularly in light of need to provide for a higher level of homes than currently proposed through LP.
Support identification of Radford Semele as location for further sustainable growth. As one of the Growth Villages, Radford Semele is one of the larger villages in the authority area with a population of nearly 2,000 and just over 800 dwellings. Village benefits from good range of local services/facilities,and from good public transport links to both Leamington Spa and Southam, where a wider range of employment opportunities and facilities are available.
Whilst supporting the decision to identify Radford Semele as a Rural Service Village, object to level of development proposed to be directed to the settlement. Previous LP Village Housing Options and Settlement Boundaries Consultation identified the village as an appropriate location to receive an allocation of 100-150 dwellings, but this has now been reduced to 50 dwellings consistent with proposed allocation North of Southam Road. Strongly submit there is no robust justification for this change in policy stance. The Council's May 2013 Draft Settlement Hierarchy Report identified Radford Semele as appropriate location to receive 100-150 dwellings. There is no basis for this figure to now be reduced based on the capacity of the North of Southam Road Allocation.
Radford Semele is not washed over by Green Belt or any other landscape designations. Although its development is constrained by an Area of Restraint that seeks to prevent the coalescence of the village with neighbouring urban areas, it is less constrained than other settlements and has ability to support further development. Although aware that further work has been undertaken to assess sensitivity of the landscape around the village to further development, submit that there are no justifiable reasons that would preclude Radford Semele from accommodating further sustainable development that could come forward in the short term to meet the district's housing needs. Submit that development targets for the village should be increased to at least 180 dwellings.
Would be opposed to re-use of previously developed land if this would preclude development from coming forward on sustainable greenfield sites. Whilst §111 of the Framework states that planning policies should encourage effective use of land by re-using land that has previously been developed, it does not state that brownfield development should be prioritised.
Conclusions on Soundness
Generally supportive of proposed distribution strategy, Growth Villages, particularly in light of the need to provide for a higher level of homes in the district. Whilst supporting identification of Radford Semele as a location for further growth, submit that there is no justifiable basis to now reduce level of residential development to be directed to the village.
6.1.9 There is no reason why Radford Semele cannot accommodate further sustainable development that could come forward in the short term. In this regard we submit that the housing targets for the village should now be increased to at least 180 homes.

Object

Representation ID: 66467

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Consistent with the proposed spatial strategy policy, identifies sites within and on the edge of the main urban areas of Warwick, Leamington Spa, Whitnash and Kenilworth and allocations for the district's identified Growth Villages. The Policy also makes provision for a site to be allocated on the edge of Coventry.
Council previously consulted on its proposed site allocations in the district's Growth Villages through the LP: Village Housing Options and Settlement Boundaries Consultation in November 2013. Through this consultation and with particular regard to Radford Semele, Council identified Land to the East of Church Lane as their preferred option to provide a housing site in the village. However, citing comments received to the LP: Village Housing Options and Settlement Boundaries Consultation and further work that has now been undertaken on landscape quality and sensitivity, the preferred allocation in the village has been amended to Land North of Southam Road.
Policy Analysis
Previously made clear strong support for the Council's decision to promote Land to the East of Church Lane, Radford Semele, as preferred locations for a future allocation within the village. Alongside site-specific representations prepared, we submitted that this represented a wholly sustainable and suitable location for further residential development to accommodate a proposal of up to 130 homes. Highlighted that there were no significant constraints to bringing site forward that could not be overcome through an appropriately planned scheme.
In light of our previous representations therefore strongly object to decision to withdraw Land to the East of Church Lane as preferred location for further development in the village. Whilst we are aware of the further work undertaken to assess landscape quality/sensitivity around Radford Semele, we object to the results of this assessment in relation to development on Land to the East of Church Lane, which indicates only a small portion could be developed. Clearly demonstrated through a number of technical studies prepared for our recent planning application for the site, a scheme of up to 130 dwellings can come forward in this location whilst still respecting the setting and views of St Nicholas Church and the landscape character of the site. Submit that Land to the East of Church Lane, Radford Semele, should now be reallocated for a development of up to 130 dwellings, to meet the authority's housing needs.
Site represents wholly sustainable location and is available/achievable now. Submit there are no justifiable reasons why could not contribute to district's housing needs.
Further details for this site have been prepared. These representations further demonstrate the suitability of site for residential development and should be read alongside this submission.
Conclusions on Soundness
Object to Council's decision to withdraw Land to the East of Church Lane as their preferred location for an allocation in Radford Semele. Demonstrated this site represents a wholly sustainable and suitable location for further development to meet the authority's housing needs. In the process of preparing a planning application for the site, have prepared number of technical studies which clearly demonstrate that there are no significant constraints that would preclude a development of
up to 130 dwellings on the site. Strongly question findings of Council's landscape quality and sensitivity assessments for the site.

Object

Representation ID: 66468

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Outlines that unmet needs outside of district will not render Plan out of date, but that the Plan will be reviewed if evidence demonstrates that significant housing needs arising outside the district should be met within the district and cannot be adequately addressed without a review. To establish this, it sets out that Council will work with other local authorities in the Coventry and Warwickshire HMA to prepare joint evidence base on housing need, agree a strategic approach to address any shortfall in land availability to deliver the full objectively assessed need, and where evidence and the Duty to Cooperate clearly indicates unmet needs would be most appropriately met in the district, seek to meet these needs and review the Local Plan.
Policy Analysis
Whilst welcoming the sentiment of Policy DS20 we submit that its provisions are not sufficient to address the unmet housing needs that are already acknowledged to exist outside of the district. There is a clear need for action to be taken to address these needs now, rather than deferring them to future joint working or a review of the Local Plan. We further query the statement in Policy DS20 that unmet needs will not render the Local Plan out-of-date. Once the Local Plan comes into effect the Council is still obliged to work with its neighbouring authorities on an ongoing basis to address unmet housing needs.
Conclusions on Soundness
Whilst welcoming the provisions of Policy DS20, submit that measures it proposes are insufficient to address unmet housing needs that are already acknowledged to exist outside the district. If the Council does not make adequate
provision to assess and address these needs now we submit that Policy DS20 and the Local Plan cannot be considered positively prepared or effective.

Object

Representation ID: 66469

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Sets out that development will not be permitted unless provision is made for 40% affordable housing of sites of 10 or more dwellings, or 0.3 ha or more within the urban areas, and on sites of 5 or more dwellings or 0.17 ha within rural areas.
Policy Analysis
Council should ensure that its affordable housing requirements are based on robust evidence, taking account of development viability. In this regard we note that the authority's most recent Affordable Housing Viability Study was published in 2011, with a further addendum prepared in 2012. Concerned as to whether this evidence is out-of-date inadequate to support the LP's proposals.
Conclusions on Soundness
In light of the time that has passed since publication of affordable housing viability evidence, query whether this is still up to date and sufficient to support the approach set out in Policy H2.

Support

Representation ID: 66470

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

New development should be of high quality and should be bought forward in a way which enables strong communities to be formed/sustained. To meet the policy's aims, a number of specific criteria against which proposals will be assessed are proposed.
Policy Analysis
Support principle of delivering high quality development, but concerned that provisions are overly onerous and could place an undue burden on the ability to deliver sustainable development. We note that Policy BE1 Layout and Design also outlines a set of prescriptive policy requirements against which the design of proposals will be assessed.
Conclusions on Soundness
Submit that it would now be sensible to consolidate requirements of Policies SC0 and BE1, other LP requirements related to layout and design of developments, into single policy.

Object

Representation ID: 66473

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Development sites of over 200 dwellings, or sites which form part of a wider development area which exceeds 200 dwellings, or other developments which have a significant impact on the character and appearance of an area, will be expected to comply with a development brief. Policy outlines specific requirements that should be contained within such development briefs, which includes densities - that should not be lower than 30 dwellings per hectare average.
Policy Analysis
Whilst recognising need for developments on larger sites to come forward in coordinated manner, query whether it will always be necessary to prepare development brief for this purpose and whether objectives of policy cannot be better achieved through preparation of site masterplan/development framework. In relation to site densities, submit it would be more appropriate to determine site densities at a level consistent with site's character/location, rather than setting a minimum target.
Conclusions on Soundness
Submit that in its current form the provisions of Policy BE2 are too prescriptive. In some instances it would be more appropriate to prepare a site masterplan or development framework for proposals, as opposed to a site development brief. Opposed to setting minimum site densities.

Object

Representation ID: 66477

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Sets out all new dwellings required to achieve Code for Sustainable Homes Level 4 from the date of adoption and Level 5 from 2016. Outlines that Council will expect applicants to consider potential to incorporate large scale decentralised district heating networks on strategic sites identified through the Plan.
Applicants will be required to prepare Sustainable Buildings Statement demonstrating how proposals meet requirements of LP's climate change policies.
Policy Analysis
Submit that requirements set out in Policy CC3 are too onerous. Unclear whether justified by supporting evidence and properly tested for effects on viability. Remind Council of guidance in §173 of the Framework, which states that "Plans should be deliverable. Therefore, the sites and scale of development identified in the Plan should not be subject to such a scale of policy obligations that their ability to be developed viably is threatened".
Conclusions on Soundness
Whilst recognising aims of this policy, question whether requirements are appropriately justified. Risk that its provisions could threaten viability of development and consequently the delivery of the LP.