Publication Draft

Object

Representation ID: 66575

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Given past rates of completions, even when the hoiusing market was at its highest, the proposed rates of completion are highly ambitious and between 2014/15 to 2019/20 these are implausible. In practice, completion rates are likely to be held back by a combination of lack of demand, rising interest rates, limited capacity within the building industry and shortage of public sector resources.

In our view, the 'front-loading' of the house building figures in the trajectory is misguided and will prove unachievable. It would be far more realistic to plan for a steady increase in provision over the next few years, as compared with the very low levels of recent years.

Object

Representation ID: 66576

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The greenfield and in some cases Green Belt allocations in Policy DS11 are not justified and the Green Belt locations would be contrary to national policy. A housing requirement of approximately 8,000 dwellings would not require any significant greenfield land to be used, and housing in Green Belt could be limited to 1-2 houses on sites within washed-over villages (Policy H11).

Object

Representation ID: 66577

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Because the Plan assumes substantial continuing in-migration, there is already in effect significant provision for meeting needs originating elsewhere. However Policy DS20 of the Plan is ominous because it envisages even higher housing provision than is currently proposed. It is fundamentally wrong to act simply as a repository for housing development not wanted elsewhere in order to fuel the Council's growth aspirations.
The revised ONS figures for households in Coventry (issued in May 2014) have significant methodological faults. The claimed requirements for the City Council area are not reliable and should not be given weight.

Object

Representation ID: 66578

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Net in-migration fell from a figure of over 2,000 per annum in the years immediately following the millennium to 400 in 2008-9 and net out-migration of 700 in 2009-10. In view of this dramatic change it is not acceptable, as the 2012 SHMAA did, to take the 460 average and simply project it forward over the plan period. There is a real possibility that there will be net out-migration from rather than in-migration to the district over the plan period. The past rate of growth of population and in-migration is unsustainable. the District Council should be planning for a very much lower level of growth in which housing and employment are balanced against environmental objectives.

The SHMAs cannot claim to have been an objective assessment of housing need. The work was commissioned by local authorities and the steering committees were dominated by development interests who have a vested interest in talking up the housing needs figures. Wider interests such as residents' groups and environmental bodies were excluded from the process. WDC have assumed population growth of 17% between 2011 and 2029. This rate of growth would be above that for almost all the SHMA Projection Scenarios, despite the plan period being two years shorter than that of the SHMA. No justification is provided in the Plan for the choice of this figure. Employment forecasts are subject to great uncertainty and cannot be reliably used.

The proposal for 12860 houses is not justified in the text. The Plan is therefore unsound in its provision for housing.

The Plan does jot take account of the latest ONS population projections, which shows a much lower rate of population growth than assumed in the JSHMA. This could suggest a reduction in the housing requirement of about 3700 homes. Further average household has recently stablilised, but the plan assumes continued reductions.

Taking all these factors into account, we consider that the Plan is unsound because its housing provision is based on out-of-date information and on an over-optimistic, inflated view of both employment and population growth prospects.

Object

Representation ID: 66579

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS5 appears to add nothing to the NPPF but it misrepresents Government policy. It is therefore unsound. The NPPF explicitly excludes Green Belt land from the presumption in favour of sustainable development but Policy DS5 makes no mention of this important fact. The Council's persistent failure to acknowledge this, also evident during the Coventry and Warwickshire Gateway public inquiry, goes to the heart of its cavalier approach to the Green Belt. The Plan proposes to remove no fewer than thirteen sites from the Green Belt. This is inconsistent with ministerial statements.

Object

Representation ID: 66580

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS8 is unsound - it does not satisfy the requirement to meet objectively assessed development requirements. The plan proposes excessive allocation of employment land. The Plan proposes redevelopment of existing employment land and this is part of the rationale for this. The SA's section on Consultation Responses shows no recognition of CPRE's earlier consultation responses despite claiming positive effects of the ammountof employment land. This makes both the proposed Plan and the associated Sustainability Appraisal unsound.

in summary:
 The margin "to provide flexibility of supply" (16.5ha) is excessive (almost 50% extra on top of the established demand of 36ha) in order to provide 'choice'. In terms of 'additional buffer to ensure choice' for housing, the NPPF proposes a 5% buffer. Even double that buffer (10%) amounts to 3.6ha rather than 16.5ha;
 The addition of a further 13.5ha for "potential replacement for redevelopment of existing employment areas" is also unjustified. This approach conflicts with the 'brownfield first' approach of policies DS4 (Spatial Strategy) and EC3 (Protecting Employment Land). There is no valid justification for releasing existing employment land in urban areas rather than regeneration as employment land, improving effective use of existing urban employment sites.

The established employment land requirement is 39.6ha. The Plan shows that there are 47.55ha of available employment land, confirming that there is an excess supply of employment land.

Object

Representation ID: 66583

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS9 is unsound - it does not satisfy the requirement to meet objectively assessed development requirements.

Policy DS9 is predicated on the erroneous claim that an additional 19.7ha of employment land is needed. If the calculation is corrected as outlined in the previous section, WDC has an excess of employment land. There is no justification for the proposal to allocate green-field land for employment use and in particular, there are no exceptional circumstances for allocating 8ha of Green Belt land at Thickthorn.

Object

Representation ID: 66584

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

As described in our response to Policy DS16, there is no justification for circumstance d) in the Rural Areas section of Policy EC1