Issue and Options 2023
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Results for Hallam Land Management Limited (HLM) search
New searchIt is imperative that that SWLP adequately considers accommodating unmet housing needs which are arising from outside of South Warwickshire, to ensure compliance with the Duty to Cooperate and so the SWLP can demonstrate adherence with the positively prepared test of soundness set out in the NPPF8. It is recognised that national planning policy and law has the potential to change during the course of the preparation of the SWLP, including in relation to the Duty to Cooperate and replacement with an ‘alignment policy’, however there is no suggestion the requirement for local authorities to address unmet needs arising from within their Housing Market Areas will be removed. We consider that there are two likely sources of unmet housing needs which require consideration in the development of the SWLP: Birmingham and Black Country and Coventry and Warwickshire. Birmingham and Black Country There are clearly significant unmet housing needs arising from the Birmingham and Black Country Housing Market Area which require addressing by this Plan. Birmingham published a New Local Plan Issues and Options consultation document in October 2022. This identifies an overall housing need in Birmingham to 2042 (derived from the Standard Method) of some 149,286 dwellings, with total housing supply equating to just 70,871 – leaving a shortfall of some 78,415 dwellings. There are significant limitations to the potential for such substantial unmet needs to be met by Birmingham’s neighbouring authorities due to lack of available land in the Black Country and significant Green Belt coverage in the Black Country and elsewhere (Bromsgrove, Solihull, North Warwickshire, and Lichfield). This was evident in the work undertaken in the now abandoned Black Country Local Plan Review, which was subject to Regulation 18 consultation in 2021 and identified a shortfall in supply across the Black Country of some 28,239 dwellings to 2039. There are strong functional relationships between Birmingham and South Warwickshire, in terms of transport connections and commuting patterns, and development in South Warwickshire can contribute towards meeting unmet needs. The Councils clearly need to engage with Birmingham and the Black Country authorities and others to determine an appropriate level of unmet needs to be directed to South Warwickshire. That process needs to be transparent in accordance with paragraph 27 of the NPPF, and effective in accordance with paragraph 35 c) of the NPPF. The lack of any published Statement of Common Ground showing progress made so far by the Councils is a concern that needs to be addressed before the next round of consultation. The Councils need to properly grapple with this issue, and not allow the failings of the last round of Local Plans to be repeated. It is noted that the SA has tested the effects of an additional 5,000 to 10,000 dwellings to accommodate Birmingham’s unmet needs, however given the numbers discussed above HLM consider 5,000 dwellings to be at the lower end of what could be expected to be accommodated in South Warwickshire. At this stage of the process and in advance of those discussions, as a working assumption for the level of unmet need to be accommodated, the figure should be an additional 10,000 dwellings. Coventry and Warwickshire Although the question does not address Coventry’s unmet needs, this cannot be ignored. Coventry has by far the greatest level of housing need across Coventry and Warwickshire as set out in the HEDNA, with a housing need calculation derived from the Standard Method of some 3,188 dwellings per annum, adjusted in the HEDNA trend-based approach to 1,964 dwellings per annum. Applying the housing need calculated in the HEDNA to the proposed SWLP Plan period suggested from 2022 to 2050 equates to some 54,992 dwellings to be accommodated to meet Coventry’s needs, as a minimum. Coventry is highly constrained by a tightly drawn administrative boundary, with potential for brownfield redevelopment but limited opportunity for greenfield development. This was reflected in the adopted Coventry Local Plan (December 2017), where the local housing need in Coventry in the period 2011 to 2031 was calculated at 42,400. The Coventry Local Plan set a housing requirement of just 24,600 (some 60% of its local housing need), leaving a shortfall of some 17,800 dwellings to be met elsewhere. It is therefore highly unlikely that Coventry will be able to meet its local housing need identified in the HEDNA of 54,992 dwellings to 2050. Even assuming that Coventry can accommodate a proportion of its local housing need consistent with that set out in the adopted Coventry Local Plan (i.e. 60%), which is itself a challenge, Coventry could only accommodate 33,000 dwellings to 2050 leaving a shortfall of some 22,000 dwellings to be met elsewhere. Given South Warwickshire’s functional relationship with Coventry, and as South Warwickshire makes up around half of the population of Warwickshire according to the 2021 Census data early releases9, an assumption that around 50% of this shortfall will be directed to South Warwickshire is considered appropriate. This equates to approximately 11,000 dwellings and should be taken into consideration at this stage of the process as a working assumption for the level of unmet need to be accommodated.
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With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, HLM consider that settlements or areas with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should include Southam.
The following comments are made in respect of the Sustainability Appraisal (SA) for Kenilworth. As a general point, the fact that a Broad Location may not be the best performing location does not automatically mean that within that Broad Location there are no suitable sites that should not come forward as a strategic allocation. The Councils will need to be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations. The Site promoted by HLM (Site 102) forms part of Kenilworth Northeast (Broad Location 5). It is noted that in assessing the six Broad Locations (BL) identified against the SA Objectives, the SA concludes that parcels to the north of Kenilworth perform better overall. The following specific comments are made in relation to the SA and Kenilworth Northeast. SA Objective 2: Flood Risk acknowledges that only very small proportions of Kenilworth Northeast coincide with Flood Zone 3, and therefore there is negligible impact. All BLs perform arguably equally, and should be assessed as such. SA Objective 3: Biodiversity considers Kenilworth Northwest is the best performing BL, but it is very marginal. Whilst Kenilworth Northeast is located within close proximity to a Local Nature Reserve, as recognised in the SA it is possible to mitigate potential adverse effects through layout and location of development. With regard to SA Objective 4: Landscape, reference is made to increased risk of coalescence with Gibbet Hill to the north, although the SA acknowledges that mitigation can be provided to create a robust settlement edge. Such a robust settlement edge is demonstrated as deliverable within the Illustrative Masterplan submitted by HLM, which will not extend the built form of this part of Kenilworth closer to Gibbet Hill than is already experienced. SA Objective 6: Pollution raises concerns in relation to Kenilworth Northeast with regard to coincidence with a Groundwater Source Protection Zone, proximity to an Air Quality Management Zone (AQMA) and vicinity of either a railway line or main road. However, and as acknowledged in the SA, mitigation can be achieved to limit any adverse impacts. SA Objective 10: Health also raises concerns in relation to Kenilworth Northeast with regard to target distances for leisure facilities, GP surgeries and a hospital with an A&E department, and proximity to a main road or AQMA. However, and again as acknowledged in the SA, mitigation can be achieved to limit any adverse impacts. SA Objective 11: Accessibility concludes that Kenilworth North is the best performing BL due to its connectivity score. It is considered that Kenilworth Northeast performs equally as well in the connectivity assessment within the Settlement Design Analysis. It is also within the target distance for a bus stop (Coventry Road). Kenilworth Northeast is therefore equal best performing option; the SA should be amended accordingly in the next iteration. Further, with regard to SA Objective 12: Education, Kenilworth North is considered to be the best performing BL as it will likely require less mitigation. However, Kenilworth Northeast performs equally as well in terms of access to primary, secondary and tertiary education. The SA should be amended accordingly in the next iteration. Kenilworth Northeast performs better than has been recorded in this SA, and this should be recognised in the next iteration of the SA. Further, what is evident from the SA is that where adverse impacts are identified they can very often be mitigated or avoided.
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The following comments are made in respect of HLM’s Site, which is referenced as falling within part of Area 8 within the Kenilworth North area. In respect of Connectivity, the Area has been assessed as ‘C’, however this is disputed given the interrelationship of the Area with Coventry Road which is a primary street and has bus stops which provide frequent access to Coventry, Leamington Spa and Warwick. The Area also has proximity to the Kenilworth Greenway. References to flood plain and the railway line are noted, but these do not impact on connectivity with the settlement. There are therefore no significant barriers to connectivity. With regard to Landforms, it is noted there are no physical constraints on Area 8 save for Flood Zones 2 and 3 to the north which can be suitably mitigated. It is recognised that Kenilworth has a number of landform constraints, notably Green Infrastructure, which limits development potential elsewhere. In respect of local facilities within 800m, it is noted that the report highlights the absence of Places to Meet, Healthcare and Education for Area 8. However, the distances are not significantly greater than 800m and the Area is well served by public transport. When taking account of the evidence above, Area 8 as illustrated within the illustrative masterplan submitted with these representations is considered to be a suitable location to accommodate a strategic allocation, as there are no barriers to connectivity to the town and generally most facilities are available within 800m.
HLM strongly agree with the proposal to review Green Belt boundaries, in order to ensure that the most sustainable growth strategy in South Warwickshire can be achieved. To avoid Green Belt release in the SWLP would limit the potential for growth of a number of South Warwickshire’s more sustainable settlements, including Kenilworth. The SWLP should be supported by an up-to-date Green Belt Study which assesses individual land parcels. In association with a development strategy which supports growth in the most sustainable locations, including on the edge of settlements such as Kenilworth, the Plan should remove land which serves the five purposes of the Green Belt the least.
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With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, HLM consider that settlements with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should include Kenilworth given its rail and bus links.
The following three comments are made in respect of the SA. Firstly, as a general comment, it is noted from the Introduction and description of the SWLP area that the SA has focussed on what is inside the boundary administered by the two authorities. But the SA should also recognise what is beyond the boundary, and notably Coventry as a major City on its borders that has a significant influence over the area should be recognised in the description of the area. Secondly, the Appraisal has only assessed South Coventry for 50-500 homes as a reasonable alternative Small Settlement Location (SSLs) alongside a number of villages. South Coventry has a level of infrastructure, jobs, and services (not least a World Class University) which dwarfs the other SSLs and therefore is out of place in this list. South Coventry is clearly more akin to the Main Settlements, and therefore Broad Locations (BL) should be appraised for up to 2,000 homes as reasonable alternatives. South Coventry as an area is sufficiently large that it could have three or more BLs in accordance with paragraph 3.6.1 of the SA. Further, having regard to Figure 3.3 of the SA, the area around South Coventry is within 800m of service provision that is either existing (e.g. bus interchange at the University, Woodfield Primary School, GP and retail facilities at the University, Tocil Wood Nature Reserve, Wainbody Wood, Crackley Woods Nature Reserve) or planned as part of the Kings Hill SUE or Coventry South Rail Station and Public Transport Interchange. Finally, land has been put forward through the call for sites process in 2021 (including the HLM site 103) which could accommodate a scale of growth up to 2,000 homes in this location, so this is a ‘realistic option’ having regard to Paragraph: 018 Reference ID: 11-018-20140306 of the NPPG. It is not clear from the SA on what basis the HLM site has not been assessed in the SA, with only one site south of Coventry having been assessed as an SSL (C.17). Having regard to Figure 3.3 of the SA, the entire HLM site falls within 800m of the existing Woodfield Primary School, and the planned Primary School which is part of Phase 1 of the Kings Hill SUE to the immediate north of the site (illustrated within the Vision Document). Whilst it is acknowledged that Woodfield Primary School is a special education school, and that the primary school at Kings Hill SUE is yet to be built, it will be within the next 5 years based on the Council’s Housing Trajectory. Further, the Transport Authorities for the area have consulted on a new train and bus station/interchange within the HLM site, and are planning for its delivery during the early part of the Plan period (as illustrated within the Vision Document). In respect of GP surgery and local shop, all of these facilities will be provided within the Kings Hill SUE to the north of the site. This is likely to be slightly beyond 800m, however, the HLM site is of a scale such that it has capacity to accommodate a GP surgery and local shop within a local centre as illustrated within the Vision Document. In respect of publicly accessible greenspace, the majority of the site is within 800m of Wainbody Wood to the north as acknowledged within the Landforms Analysis in the Settlement Design Analysis. The HLM site does therefore satisfy the criteria within Figure 3.3 for primary schools and publicly accessible greenspace, and can satisfy the criteria in respect of all other elements during the Plan Period. As only one criteria needs to be satisfied, the HLM site is therefore a BL and should be assessed as a reasonable alternative. An overly rigid application within the SA of Figure 3.3 that ignores planned service provision that is to be delivered early in the Plan period, and ignores potential service provision that can be delivered within the site, will result in missed opportunities to contribute sustainably towards growth up to 2050. It is worth remembering that paragraph 73. a) requires Councils to consider the opportunities presented by existing or planned investment in infrastructure when deciding the location of new development. The SA should therefore take into account the planned facilities at Kings Hill SUE. The HLM site 103 is well placed to achieve the 20 minute neighbourhood principle for all services listed in Figure 3.3, and is therefore a BL reasonable alternative which HLM would request be assessed as part of the next iteration of the SA. Failure of the SA to appraise realistic growth options south of Coventry as a reasonable alternative could result in the Plan not demonstrating that its proposals are ‘appropriate’ and ‘justified’.
Yes, HLM consider a policy should be included that safeguards specific infrastructure. This should include the Coventry South Rail Station and Public Transport Interchange, Track widening of the Leamington to Coventry Rail Line, Coventry’s Very Light Rail Track Proposals, and the A46 Strategic Link Road as illustrated within the Vision Document. Any designation on the Proposals Map will need to identify a zone to allow flexibility at the detailed design stage.
