Yes

ID sylw: 99214

Derbyniwyd: 06/03/2025

Ymatebydd: Coventry City Council and Coventry Airport Ltd

Asiant : Mr Robert Barnes

Coventry City Council and Coventry Airport Ltd as owners and operators of the Airport support the inclusion within the Plan of location SG03 as a place to accommodate growth. This should be understood in the context of further comments made in relation to Draft Policy Direction 7 (indicating that it should be taken out of the Green Belt) and Draft Policy Directions 14 and 16 (considering the nature of any allocation there).

Other

ID sylw: 99229

Derbyniwyd: 06/03/2025

Ymatebydd: Coventry City Council and Coventry Airport Ltd

Asiant : Mr Robert Barnes

The Regulation 18 document recognises that some Green Belt development is likely to be required. Draft Policy Direction 7 notes that, “if there are clear sustainability benefits to utilising one or more Green Belt locations, then this will form the basis of an argument that "exceptional circumstances" exist to justify releasing that land from the Green Belt.” It advocates a sequential approach to allocating growth, and identifies the need for further evidence around sustainability of locations, their Green Belt contribution, and impact on the wider Green Belt if released.

This approach is supported, on the basis that it is applied positively so that the notable resource of Green Belt land in South Warwickshire capable of sustainable development can be properly utilised. One significant example in this regard is Sustainable Growth Location SG03 which addresses Coventry Airport.

In NPPF terms this comprises previously developed land, that is, “Land which has been lawfully developed and is or was occupied by a permanent structure and any fixed surface infrastructure associated with it, including the curtilage of the developed land… It also includes land comprising large areas of fixed surface infrastructure such as large areas of hardstanding which have been lawfully developed.” The Councils’ Green Belt Review Stage 1 report concludes that the Airport makes a weak contribution overall to the Green Belt. As previously developed land enclosed on three sides by built development and the fourth side by a busy road this overall conclusion is correct and inescapable. In NPPF terms the Airport should be regarded as “Grey Belt”.

Noting that the Airport makes a weak contribution to the Green Belt and is largely enclosed by developed non-Green Belt land the impact on the wider Green Belt if released would be significantly limited. It presents as an anomalous finger of Green Belt land between heavily developed areas and road infrastructure. Planning permission has already been granted for its comprehensive redevelopment, and it forms an integral part of the wider Major Investment Site identified by the emerging Plan here. Its location immediately adjacent to the edge of Coventry and good integration with sustainable transport links on the southern side of the City, and location as part of the “Core Opportunity Area”, also contribute to its suitability and sustainability for development. There is a clear case to be made for releasing it from the Green Belt, and this should be pursued in the next version of the emerging Plan.

Other

ID sylw: 99241

Derbyniwyd: 06/03/2025

Ymatebydd: Coventry City Council and Coventry Airport Ltd

Asiant : Mr Robert Barnes

The identification of the MIS for employment use and the main focus of new employment development is supported. The recognition within the treatment Draft Policy Direction 14 provides for MIS.4 (South of Coventry Area) for Gigafactory development at the Airport is appropriate, mindful of the planning permission already secured there for such a scheme. However, two observations should be made in this regard.

First, the wording as currently expressed indicates the allocation will be for “a” Gigafactory and “a” facility. As the site is brought forward this might still be the case, but the scale and nature of development permitted here and evolution in the approaches taken by manufacturers mean that one potential outcome is more than one operator taking space in the scheme. As such any allocation should support advanced industry associated with this sector more generally.

Second, the text for MIS.4 also includes, “There is also opportunity for further employment development here that could link to the automative industry and the National Battery Industrialisation Centre, and could contribute to South Warwickshire or Coventry's unmet need.” It is important that this sentiment is carried through into any policy for MIS.4 and the type of development that will be supported across this area.

The current expectation that the Airport can accommodate battery manufacturing development is noted, including in the context of paragraph 86 c) of the NPPF which states that policies should, “pay particular regard to facilitating development to meet the needs of a modern economy, including by identifying suitable locations for uses such as…gigafactories…”. However, the same paragraph goes on to state (part e)) that policies should, “be flexible enough to accommodate needs not anticipated in the plan, and allow for new and flexible working practices and spaces to enable a rapid response to changes in economic circumstances.”

The emerging Plan is expected to operate over an extended period. As explained elsewhere in these representations the Airport is a valuable brownfield resource capable of contributing materially to meeting development requirements in a highly sustainable location that should be released from Green Belt. It represents a suitable location for advanced manufacturing development and that should be recognised by the Plan, but an allowance should also be made such that it can contribute flexibly to changes in economic circumstances for employment development if required. The Plan should allow for such flexibility here.

Other

ID sylw: 99246

Derbyniwyd: 06/03/2025

Ymatebydd: Coventry City Council and Coventry Airport Ltd

Asiant : Mr Robert Barnes

The identification of the MIS for employment use and the main focus of new employment development is supported. The recognition within the treatment Draft Policy Direction 14 provides for MIS.4 (South of Coventry Area) for Gigafactory development at the Airport is appropriate, mindful of the planning permission already secured there for such a scheme. However, two observations should be made in this regard.

First, the wording as currently expressed indicates the allocation will be for “a” Gigafactory and “a” facility. As the site is brought forward this might still be the case, but the scale and nature of development permitted here and evolution in the approaches taken by manufacturers mean that one potential outcome is more than one operator taking space in the scheme. As such any allocation should support advanced industry associated with this sector more generally.

Second, the text for MIS.4 also includes, “There is also opportunity for further employment development here that could link to the automative industry and the National Battery Industrialisation Centre, and could contribute to South Warwickshire or Coventry's unmet need.” It is important that this sentiment is carried through into any policy for MIS.4 and the type of development that will be supported across this area.

The current expectation that the Airport can accommodate battery manufacturing development is noted, including in the context of paragraph 86 c) of the NPPF which states that policies should, “pay particular regard to facilitating development to meet the needs of a modern economy, including by identifying suitable locations for uses such as…gigafactories…”. However, the same paragraph goes on to state (part e)) that policies should, “be flexible enough to accommodate needs not anticipated in the plan, and allow for new and flexible working practices and spaces to enable a rapid response to changes in economic circumstances.”

The emerging Plan is expected to operate over an extended period. As explained elsewhere in these representations the Airport is a valuable brownfield resource capable of contributing materially to meeting development requirements in a highly sustainable location that should be released from Green Belt. It represents a suitable location for advanced manufacturing development and that should be recognised by the Plan, but an allowance should also be made such that it can contribute flexibly to changes in economic circumstances for employment development if required. The Plan should allow for such flexibility here.