Proposed Modifications January 2016

We agree with the Inspector that considerably greater provision for new housing must be made - in part to meet unmet need in the SHA; in part to assist with meeting unmet need across the Region; and, fundamentally to provide a substantial and deliverable degree of flexibility should site allocations not come forward as expected. Past performance has not met promised targets by a large degree as Councils have sought to restrict land allocations to the minimum degree necessary.
This may be understandable but is nevertheless unjustified. In order to meet the over-arching objectives of the NPPF, a basic minimum requirement is that clear and deliverable flexibility must be built in to not just meet but also exceed stated targets and deliver essential development through the presumption in favour of sustainable development.
By way of example, the Birmingham Development Plan identifies the need for 37,900 houses to be supplied in Authorities outside its own area. The means by which these are to be supplied is not specified but it is suggested that additional focus is required both in the SHMA AND in neighbouring Authorities. It will NOT be acceptable just to say that discussions are ongoing as a means of complying with the Duty to Cooperate and actually supplying the needed homes.
It is not considered that
● there is a sufficient degree of flexibility in the modified Plan to ensure that housing requirements are met, and
● the sites which the Council have identified to meet their estimated need are neither the most appropriate nor the most sustainable.
● As a result, it is suggested that the Plan is still not "sound" in terms of being positively prepared, justified, effective or consistent with national policy.

It is recognised that the Inspector concluded that the Council had complied with the duty to cooperate. However, whilst the key question may well be whether engagement has been constructive and maximised the effectiveness of the Plan, it is nevertheless considered that the level of housing need to be met IS a material consideration. Apart from the cooperation necessary to understand the housing needs across Coventry and Warwickshire Housing Market Area it is suggested that a degree of greater emphasis may need to be placed on the unmet and growing needs of the Greater Birmingham area.
It is suggested that unmet need will only grow as Birmingham continues to grow, plus the effects of HS2 and other transport linkages, so it is essential that the Warwick Plan should recognise that need and make provision now.

By way of example, the Birmingham Development Plan identifies the need for 37,900 houses to be supplied in Authorities outside its own area. The means by which these are to be supplied is not specified but it is suggested that additional focus is required both in the SHMA AND in neighbouring Authorities. It will NOT be acceptable just to say that discussions are ongoing as a means of complying with the Duty to Cooperate and actually supplying the needed homes.

Failing to properly and effectively discharge that Duty, could render the plan out of date before it is adopted and as result, it is unsound.

This modification is helpful as it clearly prioritises land on the edge of the built up area for development where greenfield land is required for housing. As an example, it is considered that SHLAA Site C27/C28 also complies with this policy, and is broadly equal in application of sustainability criteria, to other sites which are being "allocated" by the Council. Further details are set out elsewhere and can be amplified at the Examination.

It is considered that the modifications still do not provide for sufficient land to meet the unmet need nor provide for adequate flexibility in meeting future need.

Whilst technically in a separate SHMA, Birmingham has substantial unmet need which must be fulfilled by surrounding Authorities.

Apart from the practical point of providing homes from which people can readily commute to their work (Coventry and Warwick being on prime commuter routes into Birmingham) the definition of SHMAs and other relevant Study Areas vary considerably as they try to reflect what actually 'happens on the ground'. It is believed that the Warwick Local Plan area,with Coventry, are inextricably linked to the wider Birmingham area and the provision of new homes should reflect the practical position.

No representation is made regarding the calculation and categorisation of housing numbers which will be assessed by others although it is considered that insufficient flexibility has been included to provide for unmet need across the Region.
However, by way of example, the Birmingham Development Plan identifies the need for 37,900 houses to be supplied in Authorities outside its own area. The means by which these are to be supplied is not specified but it is suggested that additional focus is required both in the SHMA AND in neighbouring Authorities. It will NOT be acceptable just to say that discussions are ongoing as a means of complying with the Duty to Cooperate and actually supplying the needed homes.
Of greater concern is that sites are being "allocated" by way of these modifications and seemingly based on the Sustainability Appraisal Report which has not been the subject of transparent debate. As a result, it is believed that there are clear flaws in the assessment process.

It is considered that the modifications still do not provide for sufficient land to meet the unmet need nor provide for adequate flexibility in meeting future need. There has not been a proper, transparent debate on which sites should be "allocated" which means that there has not been a proper transparent debate on the relative merits of those sites "allocated" and sites which have not.
Land on the edge of Coventry is vital to this process and it is strongly believed that in the study used to allocate/not allocate sites, there are clear flaws in the assessment process

Support the principle of allocating sites in and adjacent to the main urban areas. However, it will be noted from objections to other modifications, that concern exists to ensure that 'identified need' should take greater account of additional flexibility in a Plan to 2029.

For reasons set out elsewhere and in particular to Policy DS11 it is not considered that the proposed Strategic Sites have been properly identified through the Plan process. There has been inadequate Community Involvement and the proposed sites are based on a flawed analysis in the Sustainability Appraisal Addendum Report.
It also seems wholly wrong to state at THIS stage that "Proposals for the allocated strategic sites will be approved...." These sites have not been openly debated and it is strongly suggested that suitable additions/alternatives exist.

It is recognised that a Policy is required to remove land from the Green Belt.
For compliance with a proposed amendment to Modification 14, this Modification 16 should also list 'Land at Cryfield Grange / Land South of Gibbet Hill Road'.

Whilst not objecting to the proposed modification wording, there is an associated concern that, at various other sections e.g. DS New 1, it is stated and/or implied that other known issues will be resolved by way of an additional Masterplan and/or Plan Review relating to an undefined area south of Coventry.
If the issue is known about it should be resolved NOW and certainly as part of the current Examination of the Plan, including its soundness.