Publication Draft

Object

Representation ID: 65723

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The strategy of the plan is considered to be inherently sound and positively prepared. However considers that the plan may not be able to achieve its 15 year vision due to the end date of 2029. This should be extended at the very least to 2030, however to built in flexibility should the plan slip extending the period to 2031 would be justified. Encouraged by the Council's commitment to ensuring the duty to cooperate is met. However it is important that mechanisms are in place to ensure compliance with the duty and further detail about the process are made available perhaps in the form of a duty to cooperate statement. This should also address how co-operation has been discharged in neighbouring housing market areas, particularly the major urban areas. Endorses the view that high house prices are a key issue in the district and that the local plan needs to tackle the issue. Share the view of the Local Plan that, in order to do so, there is a need to plan positively to provide more housing to meet future needs. Supports vision for the district, it is clear and concise. The spatial strategy in para 1.43 is sound however there is concern that it is very much in summary form. This is easily overcome by paragraph 1.43 cross referring to the full spatial strategy contained at Policy DS4 of the Plan.

Object

Representation ID: 66786

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Paragraph 1.46 states that the Local Plan will identify and maintain a supply of land for housing to meet the objectively assessed needs for market and affordable housing. This objective of the Local Plan is supported as sound and responds to the issue of affordability identified at paragraph 1.30 part (b) of the Plan and the strategic priority to provide the homes the District needs identified at paragraph 1.42 of the Plan. There is a concern that in practice the policies of the Plan which follow (particularly Policy DS6) are at risk of failing to meet the objectively assessed need for housing contrary, not only to the NPPF, but to the strategic priority and objective 1 of the draft Plan.

Object

Representation ID: 66787

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

3.1 Policy DS1 supports the vision of the Council to facilitate the growth of the local economy and is supported as consistent with the NPPF's objective for the country to build a strong, competitive economy. There is a concern however that the Plan is not effectively balancing housing and employment growth as currently drafted. In order to help support economic growth and meet the projected target (11.6% employment jobs growth) for Warwick District over the plan period, there needs to be an increase in population, in particular the working population. This, in essence, requires an increase in the supply of housing over that currently proposed in the Plan. Please refer to the representations to Policy DS6 and Policy PC0.

Object

Representation ID: 66788

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In light of the statement of intent proffered through Strategic policy DS2 that the full objectively assessed need for housing will be met in the Plan is robust, credible and sound. Policy DS2 is therefore supported as sound. It is laudable that the LPA has produced a joint SHMA however there are concerns about the robustness of the findings and, as a consequence, whether the housing requirement figure contained within the Plan at Policy DS6 (12,860 new dwellings as derived from the SHMA) is sufficient to meet the full, objectively assessed need for housing.

Object

Representation ID: 66789

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In broad terms the spatial strategy is inherently sound and positively prepared and consistent with national policy. However in contrast to RDS3 of the RDS it introduces two further aspects to the spatial strategy at parts e (avoiding development that has a detrimental impact on heritage impacts unless mitigation can be put in place) and f (avoiding development in areas assessed as high landscape value). Whilst laudable these are not these are not provisions that are relevant to the broad, strategic spatial strategy of the plan. Suggest these are superfluous and should be deleted .

Support

Representation ID: 66790

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

We welcome the inclusion of a policy in accordance with the presumption in favour of sustainable development set out in the NPPF. Policy DS5 is sound and supported.

Object

Representation ID: 66791

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

A key function of the plan is to meet in full the need for housing over the plan period. Policy DS6 does not, in our view, achieve this. It is considered that the requirement figure of 12,860 dwellings 2011 to 2029 is not positively prepared and is unsound. There is concern that the migration assumptions that have fed into the SHMA are not reflective of representative or normal migration patterns which instead have been influenced by the artificial policy constraint arising from the housing moratorium in place in Warwick District between 2005 and February 2009 . There was a period of recession once the moratorium was lifted which also has the effect of constraining supply and influencing migration trends.
There is also concern about the household formation rates used in the SHMA which use a blended approach utilising both 2008 and 2011 headship rates. It is considered that the use of 2011 headship rates to 2021 then 2008 headship rates for the following 10 years is far too pessimistic. The SHMA supports growth in labour supply of around 12% for the baseline assessment which falls short of the Experian forecast of 14.3%. It makes reference to unmet need which has not been added to the projections despite planning practice guidance stating it should be. Using the Chelmer model an alternative assessment has been undertaken for Warwick District which concludes the starting point for determining the actual housing requirement for Warwick is a figure of 15,084 dwellings over the plan period 2011 to 2029 based on the most up to date demographic information. To fulfil economic potential and to provide for projected employment growth within the plan period a higher requirement of circa 18,043 should be considered. In light of this it is considered that the delivery of 715 homes per annum would not deliver the full objectively assessed need for housing in the District. It would not assist in delivering economic growth, wouldn't address the serious imbalance in supply and demand and would not deliver the affordable housing needed. In the past the District has delivered rates of 900 + which suggests a rate of 1000 per annum could be achieved.

Object

Representation ID: 66794

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Raises concerns over the composition of the Council's 12,600 housing requirement. Of those sites with planning permission not all will be developed, it is suggested that a 10% non implementation discount is applied. In relation to windfalls the NPPF only refers to them being included in the 5 yr. supply where there is compelling evidence that such sites have become available in the area and will continue to provide a reliable supply. There is no reference to windfalls being allowed within a local plan. If all sites are identified as part of the SHLAA there should be a limited amount of windfalls arising as part of the supply. If undertaken correctly the SHLAA should reduce uncertainty of unknown sites coming forward during the plan period. The Council's windfall paper fails to acknowledge that the number of windfall sites has been greater than plan allocations due to the existence of a policy vacuum with few allocated site remaining. The lack of a five year housing supply is likely to have encouraged sites of a windfall nature to come forward. The level of windfalls going forward is likely to reduce. In terms of the analysis of different windfall types it is unclear why sites in and on the edge of rural villages have not been assessed as part of the SHLAA process. The Council has attempted to estimate future trends for this category and added 40%. There is no justification for this. In terms of conversions and changes of use, it is accepted that development arising from this source can be unexpected and reactive to socio economic changes. There is a finite supply of such sources (such as public buildings) and it should not be assumed trends will continue. Known vacant sites should be assessed in the SHLAA. For the category relating to redevelopment/ new build sites with a capacity of 5 or more dwellings, these should all be identified within the SHLAA and accordingly if deliverable it should be categorised as an identified SHLAA site as being suitable within the plan. The inclusion of a windfall allowance is not encouraged by government policy. The correct approach is to undertake a comprehensive review of all land supply in order to get a true understanding of the land likely to come forward. The only category worthy of inclusion as windfall within the Local Plan is redevelopment/ new builds fewer than 5 dwellings. It would then total 144 dwellings over the whole plan period for windfalls.

Support

Representation ID: 66795

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

The site is deliverable / developable in the terms identified at footnotes 11 and 12 of paragraph 47 of the NPPF. The site is available now, offers a suitable location for development now and there is every prospect that a number of houses can be delivered on the site within five years. Indeed, the site is very well advanced. A planning application was registered for this site in May 2014. Cognisant of paragraph 14 of the NPPF, there are no adverse impacts in developing this site that significantly and demonstrably outweigh the benefits. There is, therefore, the potential to bring forward the site to contribute significantly to the 5 year supply of housing land. The site is sustainable and is easily accessible to employment opportunities and will have a positive impact on social factors such as improving the availability of sustainable transport, access to local services and facilities.

Object

Representation ID: 66796

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is necessary for the authority to allocate additional sites to make up the housing shortfall in order to meet objectively assessed housing need. Land identified as South of Gallows Hill should be allocated for this purpose for 450 dwellings with associated green infrastructure. The site is available now, offers a suitable location for development now and there is every prospect that a number of houses can be delivered within five years. The site has sustainability benefits similar to land South of Harbury lane and the sole reason why the site is not allocated for development is due to the heritage settings assessment. Technical work undertaken by Turley Associates raises concerns regarding the robustness of the Council's evidence base and draws very different conclusions in terms of the acceptability of development on the site. This reaches the conclusion that only a very limited degree of harm would arise from development south of Gallows Hill. In the context of the NPPF, paragraph 134 this constitutes less than substantial harm where the harm is to be weighed against the public benefits of the proposal. Indeed this approach is advocated in proposed Policy HE4 of the Draft Local Plan. It is not the case, as advanced in the Council's evidence base and SA, that because there is harm, no matter how limited that is, that a site should not be developed. Such an interpretation is not consistent with the NPPF, is not justified and is unsound. This would be in the public benefit consistent with paragraph 134, NPPF as it would deliver sustainable development in a location that would not require further incursions into the statutory Green Belt.