Issue and Options 2023
Search form responses
Results for Lenco Investments search
New search2 OVERVIEW OF THE SITE Site context and description 2.1 Coventry’s Southern Gateway is a strategic growth area and has a common boundary with the City of Coventry in the West Midlands. Whilst Coventry Gateway is located within Warwick District, its built form physically adjoins the Coventry urban area and being approximately 6.5km from Coventry City Centre the area looks to the city for both its social and economic needs. 2.2 The nearest train station is Coventry Station (approximately 2.5 miles to the north). Coventry Gateway is also served by local bus services from Coventry. Coventry Airport lies to the east of the Stoneleigh Road with the main runway lying within approximately 500m of the eastern boundary of the site. However, the airport is only open to private light aircraft traffic. The Airport is facing possible closure, given in February 2021, a joint venture partnership between Coventry City Council and The Rigby Group proposed to build a Gigafactory producing batteries for electric cars on the Coventry Airport site, if the project attracts investment and government funding. It is therefore clear that with the site being adjacent to an area of substantial change it is well placed to form part of that change and in particular benefit from substantial road infrastructure that has recently been implemented. 2.3 The site could gain access to the A45 strategic road network to the north via the newly constructed Silver Eagle Way with residential development in this location balancing the very substantial employment base on the southern side of Coventry (UK BIC, Gateway South & Middlemarch Industrial Estate), all of which are a very short distance from the site. 2.4 The site extends to approximately 50 hectares of greenfield land which comprises mainly fields enclosed by hedgerows albeit with a few properties along its eastern boundary. The site in its entirety and its immediate context is indicated in the vision document. Approximate capacity 2.5 As indicated in the accompanying Vision Document, the site is suitable for a variety of land uses. Two potential options have been put forward. 2.6 Firstly, based upon the density assumptions of the consultation and acknowledging the likely densities that could be achieved at this site, the estimated capacity of this site promotion, when taking account for the effect of constraints on net developable area for the site at this stage which has been explored through the vision document’s technical work that an estimated capacity equates to over 1000 dwellings (at 40dph with 50% of site for residential and remaining 50% for supporting facilities, green and blue infrastructure). 2.7 Secondly, an option for a new business park has been presented. The key ambition of an employment/commercial-led proposal is to set any development within a new landscape structure to ensure the delivery of high-quality development that relates well to the wider employment offer at the Coventry Gateway sites. Whilst taking account of the site constraints, ensuring a balance of green open spaces and access to the existing green network for potential users, at this stage the estimated capacity for possible commercial uses equates to approximately 23 hectares. Site constraints 2.8 The basis of analysed site constraints is incorporated into the accompanying vision document for the site (Section 3 of Vision Document) and forms the initial technical evidence base work for the site. For the avoidance of repetition, only matters that are not discussed through Vision Document are outlined, as follows: Agricultural Land Classification 2.9 The provisional Agricultural Land Classification (ALC) provides a method for assessing the quality of farmland to enable informed choices to be made about its future use within the planning system. It helps underpin the principles of sustainable development. Natural England’s Open Data Publication grades the agricultural land across the site as Grade 31. Figure 2-1 ALC Grades (ADAS & DEFRA) 1 Provisional Agricultural Land Classification (ALC) (England) | Provisional Agricultural Land Classification (ALC) (England) | Natural England Open Data Geoportal (arcgis.com) Tree Preservation Orders 2.10 There are no tree preservation orders within the site extents. Public Rights of Way 2.11 There is a public right of way from Baginton to Stoneleigh along the river corridor, that links with a wider network of public rights of way within the locality. Heritage Assets 2.12 The development site does not contain any listed buildings. 2.13 In the vicinity of the site, in Church Road there are a series of listed buildings including, Lucy Price House, Oak Farm, No. 2 Church Road and the Old Rectory, together with the Church of St John the Baptist. The Church is Grade I listed and is of 13th Century origin. It is set in an attractive church yard with numerous yew trees and an 18th Century brick wall at defines the northern boundary. These are a considerable distance from the Site, with very little or no intervisibility between the two, therefore either proposal will have a neutral effect on the heritage assets, and even if the Council concluded there were some harm to that asset, it would be less than substantial, and objectively outweighed by many public benefits. 2.14 In regard to, Scheduled Ancient Monuments, Baginton Castle and Fishponds are scheduled and located at some distance from the northern boundary of the site and does not present any overall constraint on the development of the site. Watercourses and Flood Risk 2.15 The Environment Agency’s Flood Maps for planning shows that part of the site lies immediately east of the River Sowe. The topography of the steeply sloping river valley sides ensures that although there are areas likely to be flooded to the west of the site land, it is restricted to the immediate vicinity of the river. It is not proposed that this area be developed as indicated in the vision document, the entirety of the developable site area is within Flood Zone 1. Ecology 2.16 No Sites of Importance for Nature Conservation (‘SINCs’) or Sites of Local Importance for Nature Conservation (‘SLINCs’) are identified within the site boundary. 2.17 The ecological data search undertaken on the site concluded there were no known nationally important sites (e.g., SSSI) which fall within the immediate area of the site. There are no designated sites of nature conservation importance within the site boundary. This information has informed the preparation of the Illustrative Concept Masterplan. The proposal will deliver in excess of 10% biodiversity net gain. Warwick District Council’s Local Plan Review (2012) 2.18 The adopted Key Diagram proposals map below highlights the urban areas and the extent of the Green Belt within the District boundary, there exists a concentrated extent of Green Belt land towards to the north of the district adjacent existing built-up areas. The principal component of which is south of Coventry. As indicated below, various sites were removed from the Green Belt and allocated for housing / employment in the adopted plan (see Figure 2-2). This includes the adjoining site (Ref. H19) which was previously removed from the Green Belt and is currently subject to a part planning approval. 2.19 The allocations shown in the map (Figure 2-3) shows the WDLP Allocations that were previously released from the Green Belt and is allocated as part of policy DS11 [Allocated Housing Sites] and policy DS16 [Regional Employment Sites] as development opportunities on greenfield sites on the edge of Coventry. The inclusion of the Site in the SWLP would represent a logical extension to the existing allocations identified on the edge of Coventry. Figure 2-3 Previous Green Belt Release Allocations in the South of Coventry area Kenilworth/south of Coventry area 2.20 An important context for the site, is the work being undertaken by Warwick District Council, alongside partners Warwickshire County Council, Coventry City Council and the University of Warwick, looking at a master planning framework for land to the north of Kenilworth/south of Coventry area. The site its firmly in the centre of this study area and is well placed to o utilise the supporting infrastructure already in place. Considering Coventry Gateway West in the future context, the Site would benefit from access to the infrastructure that will now be delivered at the Southern Gateway (application reference W/21/1370) and possibly at the Airport and be able to provide further employment opportunities for new residents or an expansion of the commercial activities on the site through a new commercial business park. Figure 2-4 Map showing previous allocations, permissions, with first round Call for Sites submissions and HS2 safeguarded route 2.21 When presenting the current adopted plan allocations (housing and employment) on a map with the new Call for Sites submissions (from May 2021) and the defensible boundary that will be formed by HS2, it becomes visually clear that a growth pattern (i.e., a southern arc) can be formed around Coventry. The Site at Coventry Gateway West (outlined in red above) is strategically placed between existing and new employment opportunities and existing housing allocations, creating a clear opportunity for sustainable growth including travel options for potential new residents or new places of work for existing residents. 2.22 In summary, inclusion of the Site in the SWLP would represent a logical extension to the existing allocations identified on the edge of Coventry, when viewed in the existing and future context of largescale neighbouring development.
3.2 Agreed. The Councils rightly recognise that to meet Sustainable Development Needs an allowance for growth in new homes that meets the diverse needs of all residents, including affordable, specialist and self and custom build housing must be addressed in the SWLP. Recognising that the population of the Coventry and Warwickshire area is growing and changing, the projected change in population 2022-2032 is expected to be +6.4%, equating to around 60,632 more people living in Coventry and Warwickshire by 2032 (HEDNA, Table 5.30). This means there will be more homes required of different types and sizes. The Council’s recognise the challenge to accommodate all of this housing within the districts in the most sustainable locations. RPS recognise that the HEDNA’s identified housing need across the Housing Market Area (‘HMA’) for 4,906 dwellings per annum: lower than the standard method as published, and lower mainly due to the stated issues in published population projections for Coventry. Notwithstanding that, it is considered necessary for a number of policies (including Green Belt) to be changed through the plan-making process in order to overcome constraints and meet housing need. 3.3 The Council recognises the need to accommodate the growth in employment opportunities that builds upon the diverse economy in South Warwickshire and neighbouring authorities, through the strategic objective ‘delivering opportunities for jobs’. The HEDNA envisages: 3.4 “a continuing focus of strategic B8 growth … with a greater potential role for South Warwickshire than seen historically. Given the need for Green Belt development if the needs identified are to be met, it would be advisable to coordinate assessment of suitable sites at a sub-regional level to integrate relevant consideration including landscape harm, and limit harm to Green Belt purposes”. Concluding, “It would not be appropriate in our view to simply replicate past development patterns in respect of the spatial distribution of development by local authority. Planning for strategic [employment] development is inevitable in an area where it will be important that the local authorities in the sub-region continue to collaborate”. 3.5 We consider that there is an opportunity to focus growth and development on the edge of urban areas. In the north of Warwick district, the Green Belt adjoins the urban edge of Coventry’s administrative boundary. The urban area provides the main source of jobs, services and public transport and has the potential, with improved infrastructure where necessary, to accommodate significant levels of sustainable growth. This aligns with the objectives regarding ‘supporting vibrant and distinct centres’, ‘providing infrastructure in the right place at the right time’, ‘contributing towards Net Zero Carbon targets’ and ‘connecting people to places’. 3.6 For these reasons, RPS agrees with the strategic objectives and the challenge regarding ‘delivery homes that meet the needs of all our communities’.
Q-I2. Please select the option which is most appropriate for South Warwickshire. 3.7 RPS considers Option I2b with a ‘focus on the strategic infrastructure relating specifically to the growth strategy’ is most appropriate. Noting that in the interim, existing Core Strategy and Local Plan policies would be retained, resulting in different approaches across the two districts. Given the site promotion at Coventry Gateway West relies on the strategic infrastructure currently underway on the new access road to the A45/A46, other development schemes in close proximity to the site are most applicable to the delivery of our site. 3.8 RPS acknowledges that infrastructure provision is a factor in assessing the potential suitability of development in terms of location. Nonetheless, national policy (NPPF 2021, paragraph 20b and 20c and 20d) makes clear that strategic policies should ‘…make sufficient provision for…infrastructure’ and ‘should...anticipate and respond to long-term requirements and opportunities such as those arising from major improvement in infrastructure…” (paragraph 22). 3.9 Therefore, national policy does not consider existing levels of infrastructure provision as being an absolute constraint on development, but rather encourages local planning authorities to find solutions to blockages in infrastructure provision that can unlock the potential to support additional growth where this supports the wider strategic objectives and policies of the development plan. 3.10 Furthermore, the provision of significant new infrastructure investment can also be a catalyst for increased demand for housing and other uses that was not previously in use when previous plans were being prepared, most notably the significant investment planned as part of the HS2 project, as well as other significant infrastructure investments that has recently come into operation, i.e. Toll Bar End roundabout, and infrastructure provision associated with development around Coventry Airport, all in close proximity to the site. QI3. Please select the option which is most appropriate for South Warwickshire. 3.11 Option I3a - A single Levy would provide clarity and greater certainty regarding likely development costs. 3.12 National policy makes clear that contributions, either as part of a development or through in-kind benefits, should be defined in development plans (NPPF 2021, para 34). It also states that such policies should not undermine the deliverability of the plan. Furthermore, contributions or in-kind benefits secured through planning obligations must only be sought where they meet all of the three tests set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010 (NPPF 2021, para 57). 3.13 Therefore, the SWLP needs to ensure that any enhancements that are sought are consistent with national policy, fully justified on the evidence, and also do not go beyond the legal tests highlighted above.
Intensification options Q-S2. Please select the [Intensification] option most appropriate for South Warwickshire 3.14 The housing requirement identified across the Coventry and Warwickshire HMA shows a need for 4,906dpa. The SWLP will therefore need to set out a potential total supply for the plan period. Not achieving this would mean that the approach towards supply and delivery of housing land is not justified, effective or consistent with national policy. The Council’s general approach to estimating dwelling capacity to date has been to assume a density of 35dph for greenfield sites and 50dph for urban brownfield sites. The net developable area for edge of village sites and most brownfield sites is assumed as 66% of the gross site area and for strategic greenfield sites this previously has fallen to 50% to reflect the additional infrastructure and strategic landscaping which is likely needed. RPS consider that the Council should take a cautious approach to estimating site capacity through intensification, to ensure they are realistic and justified. 3.15 We therefore consider Option S2c ‘Not having a policy which encourages intensification’, to be the most appropriate option for South Warwickshire given the rural nature of the district and recognising that the estimates are not the upper limits on the number of dwellings that could come forward on sites. Q-S3.2. Option [brownfield development] which is most appropriate for South Warwickshire 3.17 RPS consider that broadly the proposed housing growth option most appropriate for South Warwickshire is Option S3.2c. We do not agree with the way that this option sets out greenfield sites (particularly in respect of the Green Belt) as a measure of last resort only to be considered if all alternative options are exhausted. Neither the NPPF nor planning guidance defines Green Belt as an absolute constraint on development that should automatically preclude Green Belt sites from the assessment of suitability for development and does not specifically identify Green Belt as a constraint (ID: 3-018). Notably, the PPG states that: 3.18 “Identified sites, which have particular constraints (such as Green Belt), need to be included in the assessment for the sake of comprehensiveness but these constraints need to be set out clearly, including where they severely restrict development. An important part of the desktop review, however, is to identify sites and their constraints, rather than simply to rule out sites outright which are known to have constraints.” (ID: 3-010) 3.19 The guidance is clear that Green Belt development sites should be considered alongside other options rather than separately or as a later phase of the process. Notwithstanding the other concerns regarding a brownfield approach, such as concerns relating to loss of businesses and our concerns that brownfield sites may struggle to provide green infrastructure due to site constraints, and blanket approaches can often impede development. 3.20 Equally, in the context of changes to national planning policy, the Department for Levelling Up, Housing and Communities (‘DLUHC’) is consulting on proposed changes to Green Belt reviews, whereby “Green Belt boundaries are not required to be reviewed and altered”. However new paragraph 142 of the draft Framework text goes onto state, “strategic policies should establish the need for any changes to Green Belt boundaries…”. RPS therefore contend it is important for SWLP authorities to maintain a Green Belt review on the southern side of Coventry (even in the event the draft changes put forward by Government are agreed), as this is an area of strategic important for the sub-regional economy and cross-boundary housing needs. Growth of existing settlements and the growth strategy Q-S4.1. Do you think that growth of some of our existing settlements should be part of the overall strategy? 3.21 Yes, we agree that a distribution strategy for new development within South Warwickshire is important to consider the potential for growth around the edges of the existing settlements. 3.22 We accept that existing towns and villages provide varying levels of facilities and services to meet the needs of the people who live or work in and around them. Some of the larger settlements act as a hub for surrounding small villages. It is important to recognise the benefits of 20-minute neighbourhood principles whereby people are able to meet their regular day-to-day needs within reasonable walking distances. This concept follows the objective of sustainable development and aligns with the overarching principles of this Local Plan review. 3.23 RPS take issue with the exclusion of settlements on the edge of the district boundaries where the benefits of adjacency to a larger urban area is of benefit to the locality (i.e., edge of Coventry). The I&O consultation document states that to help inform consideration as to whether there is potential for new development - to help deliver the advantages of a 20-minute neighbourhood - a settlement analysis evidence base has been developed to help identify the opportunities and constraints to growth in and around the edges of the following settlements and locations across South Warwickshire. Yet, we contend some settlements should be subject to connectivity, accessibility and density analysis, should include settlements surrounded by Green Belt – such as south of Coventry and in particular Coventry Gateway West site. This will help determine their favourability and sustainability credentials and whether they would fall within a growth option. Development distribution strategy Q-S10. Development distribution strategy for South Warwickshire 3.29 RPS advocate for a mix of approaches which is consistent with the desire for a 'flexible and responsive' spatial development strategy as highlighted in the SWLP, which would better enable the full growth needs of SW area to be achieved as intended. 3.30 In addition, in relation to the housing distribution strategy, RPS would recommend that key consideration in identifying suitable locations to address these neighbouring shortfalls should be to prioritise locations that are accessible and in close proximity to where the unmet need arises, thus reducing travel distances as well as offering the potential for linked service provision to meet the wider needs of the new communities. In strategic terms, this means that the re-distribution of any unmet housing need should be related to settlements on a duty to cooperate basis (whether this is from the West Midland conurbation, Coventry and / or Redditch), and which would clearly lead to an increase in the overall level of growth to be accommodated within the SWLP and the need for additional land to accommodate that growth. 3.31 RPS further recommends that key consideration is given to identifying suitable locations for employment opportunities also, to address the strategic employment issues that are crucial to accommodating suitable level of growth for the sub-regional economy. This is reflective of the ‘flexible and responsive’ strategy RPS considers is necessary.
3.16 We welcome and support the recognition at section 4.6 of the Urban Capacity Study that an identified capacity of around 19,950 compares to a housing need for South Warwickshire over the new plan period of 30,750. Concluding that, “whilst the measures considered through this study could allow the SWLP to get a reasonable way towards meeting housing needs through urban sites and existing commitments, we consider it impossible to meet development needs without significant greenfield development”. This report clearly demonstrates that the district authorities cannot meet their own housing need on previously development land while building at appropriate densities or utilising public car park sites. Given the scale of need that is expected to be unable to be met on previously developed land, this suggests exceptional circumstances exist to review the Green Belt.
