Testun llawn:
The Inspector correctly states at para 31 of his letter of 1st June 2015 that "The merits of individual site allocations and the assumptions about delivery have not been subject to detailed scrutiny at this stage in the examination." It is of major concern that the Modificatons now allocate additional sites rather than just indicating that there is more than adequate deliverable land to meet the housing need requirements of the Plan
By allocating certain sites and not allocating others, this implies that a fully transparent, public debate has taken place on an objective analysis of the selection criteria.
If it has not, then such a public debate should take place as part of the Examination in Public as the allocated sites, with consequent release from the Green Belt, are a fundamental part of the Modified Plan.
There is opportunity to make representation on the allocated sites but NOT on those not being allocated. Comparative comment must therefore be made in relation to a proposed, allocated site.
The site selection appears to be based on the Sustainability Appraisal Addendum Report of February 2016.
The Council makes a strong proposal to allocate land at Kings Hill and release it from the Green Belt. The principle of allocation in this area is not opposed - only the scale of release and the lack of clear and objective analysis of the site and the alternatives. As a result, the Modified Plan remains unsound and may also fail to be 'positively prepared' as it does not allow for proper public consultation on possible allocations of land and therefore does not give the required degree of certainty for residents and future residents.
In common with other possible sites for allocation, this land adjoins the built up area. The most significant and comprehensive study into the possible release of land from the Green Belt for development on the periphery of Coventry, which is fully in the public domain, was published in 2009. This study analysed all the potential development sites and classified them into the degree of constraint which applied to the land.
See the attached figure.
It will be noted that a large portion of Kings Hill was classified as "Least Constrained" but this does NOT cover the whole site which the Council now propose to allocate for development.
It is possible that the Council is merely being pragmatic and attempting to maximise the development in specific areas rather than positively choosing the least constrained land.
Land at Cryfield Grange / Land South of Gibbet Hill Road (SHLAA Ref C27/C28) has been proposed to the Council.
● It directly adjoins the built up area;
● 100% of the land was classified as "Least Constrained" (not just part)
● it is suggested that part of Kings Hill could be developed (but not extending too far from the built up boundary or into the area previously not classified as "least constrained") and the land at Cryfield/Gibbet Hill could be developed at the same time.
● Both areas are of very similar standard (neither being 'worse' or more constrained than the other);
● it would limit the geographic distance of new development from the current built up boundary;
● it would add diversity to the land choice available;
● provide enhanced competition; and,
● ensure early development would be achieved.
Comparison between Cryfield/Gibbet Hill and Kings Hill:
The Council has chosen to "allocate" land at Kings Hill (SHLAA Ref C06) in preference to land at Cryfield (SHLAA Ref C27/C28. The reasoning appears to be based on the Sustainability Appraisal Addendum Report Feb 2016 from Enfusion. An analysis of the reasoning shows very little objective difference between the two sites other than Kings Hill is larger and may apparently provide for a greater range of services within the site.
However, whilst the possible housing numbers are larger it is also recognised that the site contains a Local Nature Reserve, an area of Ancient Woodland, a Scheduled Ancient Monument and 3 Listed Buildings.
There are very positive comments on Cryfield/Gibbet that updated landscape evidence found that the site offers potential for expansion of the Gibbet Hill residential area...... and these matters are reflected in slightly higher scores than Kings Hill, in related objectives.
A significant difference is that Air, Water and Soil Quality Objective 9 rates as a Major Negative on Cryfield and a Slight Negative on Kings Hill. The narrative does little to explain other than it is not known on either site whether the land contains Agricultural Classification 3a or 3b with both having an area of Grade 2. The report then assumes that that Kings Hill would avoid the Grade 2 land but doesn't make the same assumption on Cryfield, which then obtains a more negative score.
Other than that, there is no material negative difference on Cryfield that should result in it not being allocated.
As another example, it is also noted that whilst the narrative for both sites indicates that some noise, light and dust pollution may be possible during the construction work, at Cryfield there should be no significant health disbenefits whereas at Kings Hill the potential effects appear to be less insignificant and in order to mitigate properly it would restrict the capacity of the site.
The effects on Biodiversity and associated landscape matters at Cryfield would be little or none whereas at Kings Hill it would appear that there is a far greater risk and the necessary mitigation has not yet been fully ascertained.
In most other respects (agricultural land quality, Green Belt, flood risk, landscape, etc) there is little or no objective difference although the summation seems to conclude a very minor preference for Kings Hill - partly because of the negative score for air, noise and soil quality(?) - see above.
Objectively, it is not believed that there is any material difference between the sites.
Whilst it is appreciated that that there may be a fine difference between the two sites with Kings Hill being "allocated" in preference it is not believed that the minor differences withstand objective scrutiny. As this allocation process SHOULD be objective, transparent and open to public input, it is suggested that the Plan is clearly unsound and has not been comprehensively prepared i.e. not positively prepared.