Publication Draft Local Plan: Focused Consultation

Deeley Group Ltd object to the omission of a Proposed Amendment at paragraph 2 of the document. It is considered that this is an appropriate opportunity to amend the Plan period of 2011- 2029. It is considered that the plan period should be extended from 2029 to 2031. The current approach is considered 'unsound' as it does not conform with the provisions of NPPF which requires Plans to cover an appropriate time period, preferably a 15 year time horizon from adoption. Since the plan is unlikely to be adopted before summer 2015 at the earliest, this period appears too short. Extending the period to 2031 would ensure a 15 year period is provided for and also bring the plan into line with the housing evidence base i.e. the Joint Coventry and Warwickshire SHMA that has been used to consider housing allocations. This document makes provision for housing between 2011 and 2031.

Stratford on Avon District Council, a neighbouring Authority which has recently submitted its Proposed Submission Core Strategy, has extended its plan period to 2031 in recognition of this position and has noted that its plan could run the risk of being found 'unsound' at examination unless a period to 2031 was provided for. They are slightly ahead of Warwick in the plan process and consider that a time frame to 2031 is appropriate. Stratford altered the time period through a focused consultation process, so this is a recognized way of making an amendment of this nature through this process.

Deeley Group Ltd object to the omission of a vital piece of evidence base, that has recently been published, that should be taken into account in this Focused Consultation. This includes the G L Hearn Report on behalf of the Joint Coventry and Warwickshire Authorities produced in September 2014 which is an addendum to the 2013 SHMA. The addendum Report is entitled '2012- based Sub-National Population Projections & Economic Forecasts: Implications for Housing Need in Coventry and Warwickshire'. For ease we will refer to this document as the SHMA update.

The SHMA update gives consideration to household projections and overlays economic forecasts; it considers the interplay between demographic projections and affordability. In summary, the Report identifies that the 2013 Joint SHMA had a requirement for 3,800 homes per annum across the Housing Market Area (HMA), however the SHMA update concludes that this should be increased to 4,000 dwellings per annum across the HMA as a minimum figure. The SHMA update has considered up to date evidence in the 2012 Sub-National Population Projections (SNPP) and models household formation rates using a 'part return to trend' methodology.

It is considered that in order for the Warwick Local Plan to comply with NPPF and PPG it must consider the most up to date evidence base as part of its background work. By omitting to consider the findings of the SHMA update it is considered that the Plan is unsound.

It is considered that the Local Plan as currently drafted is not consistent with the Framework or PPG in terms of calculating Objectively Assessed Need. This point is highlighted in paragraph 5.27 of the SHMA Update which states;

'5.27 In developing local plans. we would advise local authorities to consider how the housing evidence matches their evidence, regarding economic prospects, and to adjust as appropriate their conclusions regarding assessed housing need to take account of their detailed local evidence regarding economic growth prospects. The alignment of housing provision with evidence regarding future economic growth potential within plans is required by paragraph 158 of NPPF. '

The Council have not taken account of the requirements of paragraph158 of the Framework. The Local Authority have not based their housing requirement on the most up to date evidence base, in particular with regard to the SHMA update and its requirement to consider detailed local evidence regarding economic growth prospects. This position is considered particularly inconsistent given that the Council have identified within this Focussed Consultation that there is an updated position in terms of the economic evidence base provided in the Joint Strategic Employment Land Study. It is therefore clear that it would be appropriate to consider the SHMA update through this process as well. Furthermore, it is considered that the Local Plan as currently drafted also fails to meet the requirements of paragraph 47 of the Framework. This makes it clear that Local Authorities should 'use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area.'

Stratford on Avon District Council, a neighbouring Authority, have recently increased their housing requirement in light of the SHMA update. It is considered that Warwick should acknowledge the existence of the document and revise their housing requirement accordingly.

In addition, the Local Plan as currently drafted has failed to provide an adequate explanation of the extent to which it has complied with the duty to co-operate with neighbouring authorities particularly in the HMA. This point is highlighted at paragraph 5.31 of the SHMA update, which states:

'5.31 In line with paragraph 158 of NPPF, Council's will need to ensure that their strategies for housing and economic growth align with one another. The authorities working together could, taking account of economic evidence, housing land availability and potential investment in infrastructure, consider an alternative distribution strategy for housing to encourage sustainable travel patterns. The Planning Practice Guidance supports this.'

Accordingly, it is considered that Warwick District Council has not provided an objective assessment of the housing needs of the Housing Market Area as required by the Framework and it has failed to provide adequate explanation to which it has complied with the duty to co-operate; the emerging Local Plan is considered to be fundamentally flawed in this respect.