Publication Draft

Object

Representation ID: 65468

Received: 27/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The housing target in policy DS6 should be clearly identified as a minimum to enable the full objectively assessed needs to be met.
We strongly support Strategic Policy DS2 which provides a clear commitment to providing "in full for the Objectively Assessed Housing Need". The Joint SHMA 2013 sets out the basis for establishing the District's objectively assessed affordable housing need. It identifies a need for 268 new affordable homes each year between 2013 and 2031. However this figure of 268 has been calculated based on an assumed period of 18 years over which the backlog of affordable housing need should be met.

Following national guidance to reduce the affoirdable housing reducing the backlog to 5 years, the affordable housing requirement increases from 35 to 127 affordable dwellings per annum. The overall affordable housing need therefore increases from 268 to 360 affordable dwelling per annum.

the zero migration scenario used in the 2013 SHMA is likely to have underestimated the need for affordable housing. In addition the 2012
SHMA identified a need for 698 affordable dwellings per annum in the District. This is a significantly higher level of need, identified only the year before the Joint SHMA.
As such we would recommend that the overall housing target as set out in policy DS6 is stated as a minimum which could be exceeded.

In the light of an average performance of just 14.4% affordable housing delivery over this period the realism of achieving 40% must be seriously questioned. This emphasises that if sufficient numbers of affordable dwellings are to be delivered then correspondingly sufficient numbers of market dwellings must be delivered too.
Local Plan provides for 12,860 new homes between 2011 and 2029, which equates to approximately 714 dwellings per annum. This provision figure is over 100 dwellings less than what the Joint SHMA states is the objectively assessed housing target for the District based on an annual housing need of 720 homes over the 20 year period 2011 to 2031.

Support

Representation ID: 65470

Received: 27/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

The Trust supports the Council's decision to direct most new development to sites within, or to the edge, of the main towns within Warwick District namely Leamington, Warwick, Whitnash and Kenilworth. Having regard to existing development constraints within the district, including the extent of designated Green Belt land, we also support the Council's decision to direct some development to named 'Growth Villages"

Support

Representation ID: 65472

Received: 27/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

The Trust supports the Council's decision to direct most new development to sites within, or to the edge, of the main towns within Warwick District namely Leamington, Warwick, Whitnash and Kenilworth. Having regard to existing development constraints within the district, including the extent of designated Green Belt land, we also support the Council's decision to direct some development to named 'Growth Villages'.
Accordingly, the Trust broadly supports the distribution of housing growth and the spatial hierarchy set out in policy DS10 'Broad Location of allocated Housing Sites' and Policy H1 'Directing New Housing'.

Support

Representation ID: 65474

Received: 27/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

We support this recommendation and the Council's decision to allocate the site for development under Policy DS11 in the Draft Local Plan; site reference H27 'Hampton Magna - South of Arras Boulevard'.
It is the Trust's considered view that not only is Hampton Magna a suitable location for additional growth, we strongly believe that the village can benefit greatly from well planned development of an appropriate scale.

Furthermore from our own Green Belt appraisal and baseline assessment of the site's development potential, we consider that land South of Arras Boulevard is not only a logical location for new development at Hampton Magna but the best site.

The Trust can also confirm that not only does the site offer a suitable location for development now, but it is also viable and achievable, with a realistic prospect that housing will be delivered on site within five years.

Support

Representation ID: 65475

Received: 27/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

The District Council's decision to review Green Belt boundaries is consistent with national planning policy guidance. The lack of suitable and available sites to meet objectively assessed housing needs provides the exceptional circumstances for a review of Green Belt boundaries. However before land can be released from the Green Belt for development it has to be shown that doing so would not be in conflict with the fundamental aim of Green Belt policy nor the stated five purposes it serves (refer NPPF paragraphs 79 - 80). This has been achieved via the Warwick District Council's own review of village green belt boundaries undertaken in 2013 to inform the Village Housing Options and Settlement Boundary Consultation (November 2013).
We consider the approach adopted in the District Council's Green Belt study to be sound and the key findings robust.

Object

Representation ID: 65476

Received: 27/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

AMEC has commenced baseline technical work to confirm the true development potential of the site through identification of development opportunities and constraints. Through our technical work a small parcel of land in the Trust's ownership, which sits outside of the proposed allocated site boundary to the south, has been identified as a suitable area for locating part of the overall SUDS scheme.

By locating some of the SUDS infrastructure in this location we are not only able to realise the full development potential of the site, without negatively impacting on housing densities and the character of the area, but also help enhance a small non-statutory biodiversity site located immediately to the south.

Object

Representation ID: 65477

Received: 27/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We broadly support the 40% affordable housing target to meet local needs. However the policy wording may not allow sufficient flexibility to take into account viability or site specific factors. Not in all cases will 40% affordable housing be viable.

Viability is referred to in the second paragraph of the policy; however this appears to relate solely to the form of provision, its location on site and the means of delivery.

Whilst we acknowledge that the SHMA is an important source of housing needs information, applying this policy rigidly may not necessarily assist in meeting local housing needs. The SHMA is only a 'snapshot' in time and will not always reflect the dynamic nature of the housing market. We would emphasise the need for flexibility to ensure that a wider range of factors can also be taken into account in determining the overall housing mix. These may include site specific factors relating to the existing local area or site specific viability factors.

There is a very real danger that pockets of relative social exclusion may result and indeed that the mix prescribed for the urban extension may prejudice its compatibility and full social integration into the main core community to which it relates. Such dangers are obviously exacerbated in circumstances in which relatively high percentages of affordable housing and, within this, relatively high proportions of social rented tenures are being inflexibly required, with no scope for reasonable negotiation.

Object

Representation ID: 65478

Received: 27/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Trust recognises the positive intent of Policy 10 'Bringing forward allocated sites in the Growth Villages' but considers that as currently worded it would act to potentially jeopardise the successful delivery of housing sites as it effectively restricts house building in the Growth Villages to a maximum of 50 dwellings in any 5 year period based. We consider that the District Council has failed to recognise likely unintended negative consequences of such a policy restriction:
-construction activity being spread over a much longer period
-inefficient and fragmented improvements to and/or delivery of new infrastructure
-fragmented scheme designs if different developers build-out different parts of the original site.
Policy H10 is not in alignment with the presumption in favour of sustainable development nor does it accord with the intention of the NPPF to provide a significant boost to the supply of housing

Support

Representation ID: 66764

Received: 27/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

Throughout previous consultation stages of the Local Plan the settlement of Hampton Magna has been identified as being capable of accommodating between 100 and 150 new homes. Informed by the findings of a green belt review, in 'Village Housing Options and Settlement Boundaries Consultation' (November 2013) the District Council identified land held by the Trust as the preferred site for new housing in the village. We support this recommendation and the Council's decision to allocate the site for development under Policy DS11 in the Draft Local Plan; site reference H27 'Hampton Magna - South of Arras Boulevard'.
It is the Trust's considered view that not only is Hampton Magna a suitable location for additional growth, we strongly believe that the village can benefit greatly from well planned development of an appropriate scale. Measuring approximately 6 hectares the allocated site has the capacity to comfortably deliver 100 dwellings in a location which would not undermine the stated purposes of the Green Belt. As equally important, given the site's size, sufficient land is available to accommodate new tree planting to help screen the development and create a well defined edge to the southern part of the village without compromising the overall scheme by forcing up densities.
Furthermore from our own Green Belt appraisal and baseline assessment of the site's development potential, we consider that land South of Arras Boulevard is not only a logical location for new development at Hampton Magna but the best site based on the following factors:
 Least impact on the Green Belt
 Least landscape and visual impact
 Physically well connected to the village, with good vehicular access
 Physically well located to the primary school and existing local facilities
 Physically set back from the A46 and the railway line - sources of visual and noise
 impact
 No known physical or environmental constraints to development
The Trust can also confirm that not only does the site offer a suitable location for development now, but it is also viable and achievable, with a realistic prospect that housing will be delivered on site within five years.
Finally, the King Henry VIII Endowed Trust has well established strong links with the local community and is keen to bring forward development that is built to a high standard of design and environmental performance, which the Charity, Hampton Magna and the District Council can be proud.