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 Westwood Heath and release it from the Green Belt. The principle of allocation in this area may be acceptable although the lack of clear and objective analysis of the site and the alternatives, hinders objective conclusion. 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 for development on the periphery of Coventry, which is fully in the public domain, was published in 2009. This study fully 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 Westwood Heath was classified as "Least Constrained" within the same parcel as the Land at Cryfield Grange / Land South of Gibbet Hill Road (SHLAA Ref C27/C28).
The 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"
● It is suggested that Westwood Heath could be developed at the same time as the land at Cryfield/Gibbet Hill.
● Both areas are of very similar standard (neither being 'worse' or more constrained than the other);
● Both sites would limit the geographic distance of new development from the current built up boundary;
● It would add diversity to the land choice available;
● It would provide enhanced competition; and,
● It would ensure early development would be achieved.
Comparison between Cryfield/Gibbet Hill and Westwood Heath:
The Council has chosen to "allocate" land at Westwood Heath 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 and the earlier SA Report of February 2015.
An analysis of the reasoning shows very little objective difference between the two sites.
It is worth noting that Cryfield/Gibbet at an estimated 371 houses apparently scores lower than the much larger strategic sites in terms of likely provision of new facilities. However, Westwood Heath is only an estimated 425 houses or a mere 14% larger. It therefore seems strange that a site which will only provide an estimated 14% more homes is much more advantageous in terms of catalysing new facilities?
It is also said that at Westwood Heath there is "Potential for a medium to long term negative effect on SA objective 2 (sustainable transport) through increased levels of traffic on the surrounding road network." However, it is not considered that there is any material difference with Cryfield/Gibbet as, what is effectively the same road, services both sites. However, access is cited as a reason why Cryfield was not allocated i.e. "development in this area has to be limited given highway capacity constraints."
Again, it is noted that 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.
Comparison of Westwood Heath and Cryfield /Gibbet is not as easy owing to the assessments having been carried out at different times and published in different reports. However, whilst it is appreciated that that there may be fine differences between the two sites, with Westwood Heath being "allocated" in preference, it is not believed that the minor differences withstand objective scrutiny.
It is further noted that Burton Green Parish Council has responded to the consultation by explaining why it believes Westwood Heath should NOT be allocated and its preference for development of the Cryfield/Gibbet Site.
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. it is not positively prepared.