Other

ID sylw: 107563

Derbyniwyd: 07/03/2025

Ymatebydd: Coventry City Council

Draft Policy Direction 1 provides a range of dwelling numbers over the plan period, with the
lower figure being that of the HEDNA and the higher figure being that of the new version of
the Standard Method which was introduced in December 2025.
Whilst the HEDNA is a robust joint evidence base between the Housing Market Area
authorities, its application in terms of calculating housing need for the purpose of plan
making is determined by the transitional arrangements for implementing the new NPPF.
Given the timetable for the production of the SWLP it would appear that this will not meet
the deadlines for the transitional arrangements and that therefore the new Standard Method
calculations will apply.
In terms of employment need, Coventry City Council welcomes the use of the findings of
the HEDNA in producing more up to date evidence i.e. the WMSESS / HEDNA alignment
study, and the South Warwickshire Employment Land Study. This is consistent with
Coventry’s own approach.
Coventry City Council works closely with partners across the Housing Market Area (HMA)
and the Functional Economic Market Area (FEMA), and this includes regular meetings and
discussions under the Duty to Co-operate. Coventry has reached the Regulation 19 stage
of plan making and as partners are aware intends to accommodate its own identified
housing need but has a shortfall of 45 hectares for local employment need and is seeking
help from partners across the FEMA in addressing this, along with addressing the wider
issue of strategic employment. Discussions are ongoing across the FEMA and Coventry
welcomes acknowledgement of this through the SWLP Preferred Options.

Other

ID sylw: 107566

Derbyniwyd: 07/03/2025

Ymatebydd: Coventry City Council

Coventry City Council strongly objects to intensified and significant growth in the SG01 area
beyond those schemes which are already consented. It is important to emphasise that
growth of this scale would have significant impacts not only in relation to the development
itself but also in terms of the infrastructure which would be needed to support it.
The Green Belt in this area has been assessed as having a moderate / strong function and
indeed all parcels score as having a strong contribution regarding their role in checking the
unrestricted sprawl of the built up area. The assessment for parcels COV2, COV3, and
KEN1, KEN 13 and KEN 14 recognises the strong function of the Green Belt in that area.
However, in relation to COV4, this is assessed as ‘moderate’ whereas Coventry City Council
would contest this and considers that it should be increased to a ‘strong’ function especially
in terms of checking unrestricted sprawl and preventing neighbouring towns merging and
given that this sits adjacent to an existing allocation. This principle also applies KEN3 and
KEN4 which are adjacent to Kenilworth. Cumulatively the development of these parcels
would serve to merge Kenilworth with Coventry, undermining the significant role of the
Green Belt here.
SG01 is also an area with particular ecological significance, including SSSI, Local Nature
Reserves and Ancient Woodland. These ecological designations should be protected and
green infrastructure links strengthened and development proposals have the potential to
cause harm and fragmentation.
The Sustainability Appraisal assesses SG01 as one of the worst performing options,
identifying it as is identified as being the worst performing for biodiversity (SA Objective 3)
and has also been identified to be amongst the worst performing options for landscape (SA
Objective 4), pollution (SA Objective 6), and natural resources (SA Objective 7). It is not in
the top five best performing for any objective. Coventry City Council welcomes this
conclusion and trusts that the results of this assessment will be used to shape the next
stage of plan making and that this option for growth will be rejected as being unsustainable.

Individual sites
• Site REFID47 ‘Westwood Heath Garden Suburb’ and sites in the vicinity being promoted through SG01
Please see previous comments objecting to SG01.

• Other sites: general comments
Coventry City Council notes that assessment has been undertaken of a number of sites
which cross over into Coventry’s boundary (Strategic Growth Locations SG01 and SG03)
and strongly objects to this approach.

Whilst it is understood that growth locations do not necessarily follow administrative areas,
it is considered they should be depicted differently on a spatial map so that the reader is
aware that some areas fall under a different administration (eg ‘greyed out’), and that there
should be no assessment undertaken of those sites without the express agreement of the adjoining Council.
As such, the City Council objects to the process of the assessment of some sites / parcels of land and these are set out below.

Site REFID 227 University of Warwick main campus
Within this assessed site, it is essential that the SWLP reflects the provisions of the
University of Warwick Campus Framework Masterplan which was jointly adopted by
Coventry City Council and Warwick District Council on 3 December 2024.
those parts of the Framework Masterplan which sit within Coventry’s
administrative boundary should be ‘greyed out’ as whilst there are cross boundary matters
to consider, the SWLP cannot make decisions on behalf of another area. At present this
has not been done: Site REFID227: University of Warwick Main Campus needs amending to delineate between the two administrative areas and with a clear contextual link to the
adopted SPD.

Development proposals for this site must accord with the SPD. It is noted under Draft Policy
Direction 14 Major Investment Sites reference is made to ‘further development in the south
of this site will be explored but may require a link road from the A46 depending on the nature
of development due to access through a residential area’. This is not in accordance with the
SPD.

Site REFID 122 Land at Gibbet Hill Coventry
This site as a whole sits within the Green Belt. The element of land to the top north east of
the site sites within Coventry’s administrative area but this is not referenced anywhere and
should not have been included in the assessment process.
Coventry City Council objects to the SWLP having assessed a site within its boundaries
and outside of the SWLP area. Furthermore this site forms part of a wider Green Belt parcel
(COV2 in the South Warwickshire Green Belt Review), an area assessed as making a
strong contribution to the five purposes of Green Belt. It is also in close proximity to ancient
woodland and local wildlife sites to the north (in Coventry) and any development could
fragment wider ecological connectivity. Coventry City Council therefore objects to the
inclusion of REFID 122 as a potential development site

Site REFID 103 Land South of Stoneleigh Road / Kenilworth Road
This site as a whole sits within the Green Belt. The element of land to the north west of the
site sites within Coventry’s administrative area but this is not referenced anywhere and
should not have been included in the assessment process.
Coventry City Council objects to the SWLP having assessed a site within its boundaries
and outside of the SWLP area. Furthermore, this site forms part of wider Green Belt parcels
(COV3 and COV4 in the South Warwickshire Green Belt Review), an area assessed as
making a strong / moderate contribution to the five purposes of Green Belt. It is also good
quality agricultural land.
Coventry City Council therefore objects to the inclusion of REFID 122 as a potential
development site.

SG03 Coventry Airport Group
REFID43
The allocation of the Airport REFID43 is welcomed and supported and already has outline
planning consent.

Yes

ID sylw: 107582

Derbyniwyd: 07/03/2025

Ymatebydd: Coventry City Council

Coventry City Council supports and welcomes the principles behind Draft Policy Direction
4, which states:

"The South Warwickshire Local Plan will be underpinned by a housing need and
availability evidence base that considers the Coventry and Warwickshire Housing
Market Area as well as the Greater Birmingham and Black Country Housing Market
Area. This evidence base will consider a strategic approach that addresses any
shortfall of land availability to deliver in full the Housing Market Area's Objectively
Assessed Housing Need or other evidenced housing need arising outside South
Warwickshire.
If evidence and the duty to co-operate process clearly indicates that there is a
housing or employment need that cannot be met within the administrative boundaries
of the authority in which the need arises and part or all of the need could most
appropriately be met within the South Warwickshire Local Plan, reserve sites will be
released for this purpose, or when the relevant authority's 5 year housing land supply
calculation falls below the thresholds set out in national planning policy guidance."

As set out earlier in these representations, Coventry City Council works closely with
partners across the Housing Market Area (HMA) and the Functional Economic Market Area
(FEMA), and this includes regular meetings and discussions under the Duty to Co-operate.
Coventry has reached the Regulation 19 stage of plan making and as partners are aware
intends to accommodate its own identified housing need, however this does need to be
tested through examination.

It is also requested that the policy is amended to include clarification that the
accommodation of any shortfall arising from neighbouring authorities should be located
within the geographical housing market area from which that shortfall arises and that its
should be made clear which sites are selected for such purpose.

As the two councils producing the SWLP will be aware, Coventry City Council considers
that it has a shortfall of 45 hectares for local employment need and is seeking help from
partners across the FEMA in addressing this, along with addressing the wider issue of
strategic employment. Discussions are ongoing across the FEMA and Coventry welcomes
acknowledgement of this through the SWLP Preferred Options and further discussions
would be welcomed.

Other

ID sylw: 107583

Derbyniwyd: 07/03/2025

Ymatebydd: Coventry City Council

In terms of safeguarded land the draft policy direction states:

"Areas of existing safeguarded land such as the land at Westwood Heath designated
in the adopted Warwick District Local Plan will also need to be revisited to determine
whether they are suitable for development, based on the latest available evidence."

The sequential approach is supported, and accords with national policy. In terms of the
safeguarded Land at Westwood Heath, this now needs to be considered in the round with
other options being put forward and in line with the updated evidence base. Coventry City
Council, through its Regulation 19 Plan has not identified a future shortfall in terms of
housing need and whilst this remains yet to be examined it seems unnecessary to retain
safeguarded land in this location when through the sequential approach other locations
would be more appropriate. This is also significant in terms of the conclusions of the
Sustainability Appraisal which identifies the SG01 area (which neighbours the safeguarded
land) as scoring especially poorly in terms of biodiversity, landscape, natural resources and
pollution. Development should be steered elsewhere and the safeguarded land should be
returned to the Green Belt.

Other

ID sylw: 107586

Derbyniwyd: 07/03/2025

Ymatebydd: Coventry City Council

In terms of MIS 4 the allocation of the Coventry Airport site of a Gigafactory is welcomed
and supported. The reference to further employment to help meet unmet need is supported
in principle and further discussions would be welcomed.
In regard to MIS 7, this relates to the Warwick University site. Development proposals for
this site must accord with the jointly adopted University of Warwick Framework Masterplan
SPD as set out earlier in these representations . Reference is made in MIS 7 to ‘further
development in the south of this site will be explored but may require a link road from the
A46 depending on the nature of development due to access through a residential area’.
This is not in accordance with the SPD.

Other

ID sylw: 107587

Derbyniwyd: 07/03/2025

Ymatebydd: Coventry City Council

As options are refined detailed discussions on infrastructure will be needed.
The harmful impacts of infrastructure should be accounted for, assessed and appropriately
mitigated for. This includes infrastructure with cross boundary impacts. Coventry City
Council would also wish to emphasise the importance of community infrastructure and that
where development is located close to other local authority boundaries joint working should
take place to ensure that all communities benefit, not just those to whom the plan- making
boundaries apply.