Revised Development Strategy

Support

Representation ID: 55429

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

On the whole RPS supports the Strategic Vision, which provides specific principles relating to key elements of sustainable development, including meeting housing needs of existing and future population of the District. This includes identifying land for approximately 550 new homes per year on new allocated sites, totalling 9,900 allocated dwellings to be delivered between 2011 and 2029.

Object

Representation ID: 55430

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

Supports the Strategic Vision, which provides specific principles relating to key elements of sustainable development, including meeting housing needs of existing and future population of the District.

This includes identifying land for approximately 550 new homes per year on new allocated sites, totalling 9,900 allocated dwellings to be delivered between 2011 and 2029.

The Strategic Vision is, however, not followed through via Draft Policy RDS4, which only proposed 6,630 dwellings as allocations.

Considers that the Council should be working towards a much higher figure of proposed allocations that includes Greenfield and Green Belt sites as it is evident that there is limited land available within the urban area.

The housing target for Warwick District should be increased in line with the more recent evidence on economic growth. Therefore, additional sites need to be allocated to meet this key principle in addition to any unmet need arising from Coventry.

Object

Representation ID: 56594

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

A higher level of housing is required to meet Warwick District's needs and support cross-boundary requirements of adjacent authorities, further sites need to be allocated within the Local Plan.

The exclusion of sustainable sites on the periphery of Coventry from the list of housing allocations is not supported, and the allocation of only 70 to 90 dwellings to Baginton is highly inappropriate.

Part of Coventry City Council's housing targets provision needs to be delivered on sites on the periphery of Coventry in sustainable locations, such as to the south of Coventry within Warwick District which was previously acknowledged by the West Midlands RSS Panel Report and Coventry Core Strategy Inspectors Report as being an appropriate location for accommodating future growth for Coventry.

Approximately 1,000 dwellings can be delivered on Lenco's site at Baginton:

* infrastructure improvements proposed for the Gateway scheme will provide better access into the airport site and improve junctions including the A45/A46 roundabout.

* these improvements will also be able to provide new roads and links to assist residential development at this location

Options 1 and 2 of the Preferred Options consultation document referred to a link between employment growth and level of housing required.

It is important to provide large-scale sustainable development in locations where people can live and work in close proximity, such as at the Lenco's site at Baginton (SHLAA reference C10) which is adjacent to the recently approved Coventry and Warwickshire Gateway proposals at Coventry Airport:

* it would be logical and sustainable for a proportion of the District's housing supply to be co-located on a sustainable and deliverable site close to employment opportunities; and provide large-scale sustainable development where people can live and work in close proximity.

* The site has good access into Coventry City Centre, nearby Business Parks and major road links of the A45 and A56.

* Is within commuting distance to employment opportunities within Warwick Town Centre and other surrounding towns and cities such as Coventry and Birmingham.

* provides an opportunity for delivering balanced housing growth and community facilities on adjoining land, which is available for development assist in meeting future housing needs and cross-boundary requirements, to support economic growth in accordance with the NPPF.

Object

Representation ID: 56595

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

Supports the increase in housing from the 10,800 dwellings in the previous version of the plan to this Preferred Options consultation document. However, the evidence illustrates that 12,300 dwellings is still insufficient to meet Warwick's own housing needs, let alone assisting with cross-boundary development requirements.

The extensive evidence gathering and scenario testing by the Council to establish a housing and employment figure has not been used or applied consistently.

The 12,300 figure is not justified on GVA terms, nor is it justified through the economic or demographic evidence available in the Economic or Demographic Forecasting Study.

The 12,300 figure will also not support the 10,200 jobs being planned for in accordance with figure 42 of the Councils forecasting study.

It is expected that the 2013 joint SHMA will provide a greater degree of clarity on the housing need for Warwick (including cross boundary need) but in the absence of this, the figure needs to be reflective of the evidence available.

It is also noted that the Inspector for the [Coventry] Core Strategy has indicated that there is a need for an up to date SHMA in order to have effective and robust cross boundary evidence of cooperation. On this basis the figure should be reflective of the economic potential of the district based upon the influence of the Gateway Development and high levels of GVA than 2.5%.

This should therefore be considerably higher than the 13,900 dwellings (figure 42). The justification for this is:

* The authority is planning to provide some 10,200 additional jobs over the plan period which is even higher than the 9,900 associated with 13,900 dwellings RPS recommends is the minimum to be considered ;

* GVA forecasts are predicated to in the range of 2.9% and not 2.4%;

* GVA from the Gateway Development is expected to push GVA up to at least 3%

* The Gateway site already now has planning consent (subject to S106) and will have an impact on the district's requirements including the provision of some 10,000 new jobs;

* The needs of Coventry have not been considered and will need to be taken into account in addition to Warwick's needs;

*The demographic study has used 2011 census household size figures and forecast them across the whole plan period. This is unlikely to occur and trends akin to the 2008 projections or close to them are accepted by many as likely to occur

The 2012 Strategic Housing Land Availability Assessment (SHLAA) inappropriately excludes that site at Baginton. Therefore, it is evident that a greater number of dwellings than the interim level proposed, can be delivered within the District to contribute towards housing needs.

Warwick District Council should work with Coventry to assist in providing a proportion of Coventry's housing requirement in accordance with NPPF requirements.

Object

Representation ID: 56596

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

Although it is agreed that brownfield land should be prioritised for development, it is evident that to deliver a higher level of housing (as suggested in representation on RDS1), further Greenfield and Green Belt land will need to be released as there is a lack of suitable urban brownfield sites available.

RDS4 indicates the broad location of development, which focuses 4,550 dwellings on sites at the edge of Warwick, Leamington and Whitnash, with 700 dwellings at Kenilworth, 380 dwellings on urban brownfield sites, and 1,000 dwellings allocated to village development.

This number of allocations is considered to be significantly lower than what should be delivered to meet the projected increase in population and housing requirements.

It is also lower than, and therefore contrary to, the key principles within the Strategic Vision (paragraph 3.5) which state that 550 dwellings a year should be provided on new allocated sites, which equates to 9,900 allocated dwellings to be delivered in the plan period.

The Local Plan should include references to the level of cross-boundary growth that will be provided to meet adjacent authorities' needs, which should be in addition to the level of housing suggested (in representation on RDS1) to meet Warwick's own needs and reflect the predicted levels of growth as identified through the evidence base.

Further greenfield and Green Belt sites in sustainable locations should therefore be allocated to deliver this housing.

The 2012 Coventry SHLAA indicates that Coventry cannot meet their housing needs in their administrative boundary.

Lenco's site at Baginton/Coventry Gateway could provide approximately 1,000 dwellings and community facilities, and therefore should be favoured by the Council as an allocation to assist with cross-boundary provision, and support employment growth within the area particularly the recently approved Gateway scheme which will provide up to 10,500 jobs and 6.5ha of Warwick's employment needs.

Object

Representation ID: 56597

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

The SHLAA Site at Baginton/ Coventry Gateway (reference C10) has been promoted through all previous stages of both the Warwick and Coventry Local Development Framework processes, as an appropriate site for a Sustainable Urban Extension.

It should be recognised by the Council as a sustainable site adjacent to the urban area and large-scale employment.

It could accommodate a significant proportion of housing that would contribute towards the growth of Coventry and support the Gateway scheme, ensuring compliance with the NPPF in relation to the duty to co-operate, and should be allocated within the Local Plan.

The site was identified in the 2012 SHLAA, ref. C10, but was discounted as being unsuitable for a residential development due to landscape impact, noise and air pollution from the airport, and air pollution from the sewage works.

Extensive technical assessments have been undertaken for the site in relation to flood risk, noise, ecology, conservation and heritage, landscape, which have previously been submitted to the Council.

These reports demonstrate that the site is suitable for a significant residential-led development either in isolation or in connection with proposals for the wider area. An Air Quality Assessment can also to be undertaken to demonstrate the site's suitability for development.

The principal reasons for discounting the site from the SHLAA as being suitable are therefore all unjustified and evidence has/can be provided to demonstrate already that the site is suitable.

In respect to landscape impact, not aware of any specific Landscape Assessment prepared to an industry standard methodology that provides the evidence that this area of land has significant landscape importance and the development would impact upon it.

The site was appraised for Landscape under the Green Belt Assessment work and scored Medium Value as part of a larger area of survey. However, this assessment is not sufficient to justify exclusion from the SHLAA on landscape impact as it has not assessed the site on that basis. The Council have no evidence that can justify this position at examination.

In progressing the Local Plan, Warwick District Council should ensure that it uses the most up to date evidence available to it and significant recent events to ensure that the plan is robustly justified at examination.

In this context, it should have due regard to the approval of the Gateway site and the most recent landscape evidence (submitted as part of representation) which indicates that the area can be incorporated into the landscape satisfactorily and that it has the opportunity to assist in developing local green infrastructure assets and the integration of the Gateway Development into the local landscape.

On this basis, the area clearly scores favourably on assisting the countryside from encroachment through improving the natural buffer and integration of the Gateway Site and the provision of Green Infrastructure Assets helps contribute to the setting of Baginton in a considerably positive manner through development, as demonstrated by the Council's own landscape assessment evidence.


Noise and Air pollution

Extensive technical assessments have been undertaken for the site in relation to flood risk, noise, ecology, conservation and heritage, landscape, which have previously been submitted to the Council.

These reports demonstrate that the site is suitable for a significant residential-led development either in isolation or in connection with proposals for the wider area. Similarly air quality would also not rule out the site's suitability for residential development.

It is also noted that the Council is consulting on the Gypsy and Traveller site options and have included a significant part of the site promoted (SHLAA site C10) as a suitable location for Gypsy and Traveller accommodation.

Cannot see how the Council can consider the site acceptable for residential use for Gypsy and Traveller accommodation in the context of noise and air pollution and at the same time consider it not acceptable for residential use in the SHLAA on the same grounds.

The discounting of this site on such grounds for open residential use is therefore not justified.

Sustainability Appraisal.

This site should be considered as a reasonable alternative for accommodating future housing requirements. It offers a sustainable location on the edge of a significant urban area with extremely accessible links to existing and new areas of employment and can offer to meet the needs of Coventry and Warwick.

The site should therefore form part of the assessment of alternative and option sites and appraised formally through the local plan process.

This should also involve sufficient consultation by the Council prior to examination. Expects this site to be fully appraised alongside the preferred sites as a reasonable alternative in light of the Judgment on the appraisal of alternatives from the Norfolk authorities SA case. This expects alternatives to be given the same level of appraisal and assessment to that of the preferred approach.

Object

Representation ID: 63510

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

The Strategic Vision is, however, not followed through via Draft Policy RDS4, which only proposed 6,630 dwellings as allocations. RPS therefore considers that the Council should be working towards a much higher figure of proposed allocations that includes Greenfield and Green Belt sites as it is evident that there is limited land available within the urban area. This is particularly as RPS is of the opinion that the housing target for Warwick District should be increased in line with the more recent evidence on economic growth. Therefore, additional sites need to be allocated to meet this key principle in addition to any unmet need arising from Coventry.

Object

Representation ID: 63511

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

The Council has indicated that the 12,300 figure may change once the joint SHMA is published in August 2013. Given the evidence and that this is an interim figure, it has to be accepted that the figure will change and 12,300 is therefore not sufficiently robust. This is particular the case as there is no cross boundary element. Cross boundary arrangements will need to be implemented to facilitate the needs of Coventry in Warwick. 12,300 is evidence that WDC is unable to fix a definitive figure for its strategy given that it will have to accept addition need from Coventry. RPS therefore supports the increase in housing from the previous version of the plan to this Preferred Options document. However 12,300 is still insufficient. To meet Warwick's needs, let alone assisting with cross-boundary requirements.

The RDS as presented is currently not sound, justified or positively prepared based on the basis that 12,300 is only an interim figure. It is not clear how the evidence has actually informed or justified the final 12,300 figure.

The NPPF clearly sets out in paragraph 159 that LPA's should prepare a SHMA to assess their full housing needs and work with neighbouring authorities where housing markets cross administrative boundaries. The SHMA will also assess housing needs, population changes and migration and demographic changes. It is therefore clear that the need for a SHMA that addresses the cross boundary issues is required. The SHMA guidance also sets out that SHMA should include local economic forecasting as part of the housing needs evidence base.

Due to the cross boundary needs of Coventry it is vital that Warwick's own Objectively Assessed Need for market and affordable housing is established in accordance with paragraph 47 of the NPPF before any need associated with Coventry is considered. In this context, the Council has commissioned a number of studies including an updated SHMA which is due to be published in August 2013. However, until this is available the Council has based the interim figure on evidence already in the public domain. This presumably comprises principally the 2012 SHMA and the 2012 Economic and Demographic Forecasts Study (EDFS). These have been informed by a series of population and household projection, including some of the most recent 2011 census data.

Object

Representation ID: 63512

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

-Paragraph 4.16 outlines that the evidence in the updated SHMA indicates a range between 11,300 and 14,300 based upon demographic and economic scenarios. However it is not clear how these figures have been derived. According to Paragraph 4.1.8, the EDFS study identifies that the employment led population and household suggestions hat there is a need for between 13,300 and 13,800 additional homes between 2011 and 2029.
-In arriving at a final figure of 12,300 dwellings in paragraph 4.1.10 the Council's Revised Strategy, the justification appears to come from different a source of evidence and assumptions of GVA and 'economic modelling work' which is not apparent in the documents in the public domain.
-It is not clear in the evidence where this economic modelling is documented or justified, nor how it has considered the full range of scenarios assessed in detail in the Economic and Demographic Forecast Study. This is therefore not justified at present unless a clear audit of the evidence base can be demonstrated.
-Furthermore the assumptions about GVA are incorrect according to the Council's own evidence. The GVA evidence in the Councils forecasting study indicates that GVA for Warwick will outperform the West Midlands on its base forecast and will be as high as 2.9% by 2025 (Figure 5) compared to a figure of 2.6% for the west midlands. Given that the document consistently refers to the district outperforming the West Midlands it would therefore appear logical to plan on the basis of at least 2.9% rather than 2.4%. This is further substantiated by Figure 12 of the document indicating that the Gateway Development itself could increase GVA in Warwick District by between 8% and 10% over its base figure, thus it is likely to be in the region of 3% overall.

Object

Representation ID: 63513

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

-On the basis that all net new employees at Gateway site require homes in Warwick and Coventry, the EDFS study assumes that workers are already accounted for within the existing floorspace provisions are therefore do not require new homes. The housing requirement is therefore likely to be proportionally lower. However, on the basis that 25% or 50% of employment is being displaced from existing areas, these areas will either lose employment or gain replacements. This may leave vacant employment land at other locations but on this basis that it is backfilled by other employment, the scenarios do not result in a housing decrease as there would always be a net gain in workforce required. The issue needs more clarity and justification if the authority is to use the scenarios within any final housing requirement figure.
-The employment land to the new Gateway site south of Coventry will be meeting Warwick's needs but this is not expressed as a percentage in order to compare it with the scenarios tested, nor is it confirmed as to whether this is a displacement resulting in lost employment elsewhere or if it is backfilled. The conclusion in the document is, however, that 6.5ha of the district's employment land will be provided for through the Gateway site south of Coventry. Despite the uncertainty of this statement and the lack of clarity on its relationship to the sensitivity scenarios that have been undertaken, it is assumed by RPS that this 6.5ha of employment land to be provided at the Gateway site is in fact net additional employment land.
-In seeking to justify its housing requirement, the Council has accepted that a degree of shift in employment will take place from existing areas to the Gateway site, but it is not clear how this has actually translated into the justification of housing need in establishing the requirement of 12,300 dwellings.
-Paragraph 4.1.8 sets out that the economic projections point to a need of between 13,300 dwellings and 13,800 dwellings between 2011 - 2029, depending upon the Gateways Scheme displacing jobs in the district. However, paragraph 6.6 and figure 44 set out that the figures are between 13,100 and 13,900 dwellings for 8,745 jobs and 9,900 jobs respectfully. Given the above, and the acceptance by the Council that the Gateway Scheme is likely to have a small influence on the district, the figure is therefore likely to be closer to the 13,900 dwellings figure (with the associated 9,900 jobs)