representor link number: 1048 representation id number ... · document (dpd) mr “ publication...

Representor Link Number: 1048

Representation ID Number: 374 (policy H2), 375 (policy H3), 376 (policy H6)

Representor Name: Martin Herbert Company: Brown and Co

COVENTRY LOCAL PLAN 2016

S:\Agency\Martin Herbert\Walpole-Brown\2016\Coventry City Council - Response Forms\Representations.doc

REPRESENTATIONS

MADE BY

BROWN & CO

AGENTS FOR AND ON BEHALF OF

LANDOWNER/SHAREHOLDER OF PROPERTY

Generally we support the Plan and overall we feel it is, subject to a few minor changes (see summary

below), legally compliant and Sound.

The reason for making these comments is to generally support the position taken by Coventry City

Council and to draw to your attention issues relating to two principal sites. The first is the SUE proposed

at Keresley and the second relates to land at Walsgrave Hill Farm/Hillfields Farm which falls into the

area managed by Rugby Borough Council. We have recently made representations to the Rugby Local

Plan. There is a significant issue in the Rugby Plan on which we would hope to enlist the support of

Coventry City Council. The Rugby Borough Council Plan is, we feel, not in accordance with the wishes

of Coventry City Council insofar as their development strategy is concerned.

By way of a general overview we would mention the following in relation to the Draft Plan and whilst we

take the view that generally the Plan is legally compliant and Sound. The declared aims of Coventry City

Council have not been followed by Rugby Borough Council in their development strategies. This would

suggest that there has either been a lack of coordination between the two Councils or Rugby Borough

Council have not taken into account the needs of Coventry when producing their Plan. Therefore, there

remains the question as to whether the Council have adequately addressed their duty to cooperate.

There needs to be adequate level of liaison between the two parties to create a sound Planning base for

future decisions relating to land on the periphery of Coventry and to serve Coventry’s needs. We will

illustrate this further in our comments below.

Just by way of general comment we would make reference to the following extracts from your Local

Plan:

REPRESENTATIONS

MADE BY

No Page Policy Comment

1. 15 Relevant to comments which follow we support the view that ... in bringing

forward land for housing and employment that sits adjacent to the City’s

existing administrative boundaries. This is Coventry’s aim but has not

been achieved by Rugby Borough Council. 2. 16

There is reference to the occupation and potential expansion of Ansty Park

to the north east of the City. The Rugby Borough Plan is very deficient in

terms of its approach to Ansty Park and the facilities and growth that could be

provided. Because it sits at the edge of their administrative boundary they have

made very little reference to that in their Plan document. It, together with the

land adjoining, offers huge scope for a much needed high quality mixed use

development.

3. 17 Again there is general reference to cross-administrative boundary

developments. Consistent with our comments at 2 above, we will draw to your

attention the need to make sure that Rugby provide in their Plan, Policies and

allocations which allude to your aspirational thoughts in terms of good quality

development and an expansion of Ansty Park.

4. 20 DS2 We applaud your aspirations to ... work with partners in preparing joint

development Plan documents, supplementary Planning documents ... this is in

connection with the Ansty Park Walsgrave Hill/Hillfields Farm development as

promoted before. This straddles the City’s administrative boundary. Rugby

Borough Council have not made adequate provision for the housing and

employment needs of Coventry City Council in their Plan.

COVENTRY LOCAL PLAN 2016

S:\Agency\Martin Herbert\Walpole-Brown\2016\Coventry City Council - Response Forms\Representations.doc

BROWN & CO

AGENTS FOR AND ON BEHALF OF

LANDOWNER/SHAREHOLDER OF PROPERTY

In summary, we generally support the Plan and the Policies contained therein and just by way of minor

amendment we would propose alterations as indicated above in comments 11 and 12 to make sure that

the Plan is sustainable and deliverable.

No Page Policy Comment

We also understand that there are doubts whether Kings Hill will deliver in its

entirety during the Plan period. Helping push the delivery of our client’s scheme

will protect against the under delivery of other schemes.

5. 20

DS2 We support number 5 which is interlinked with previous comments over delivery.

6. 31 We would, as we expect you have found from the Rugby Local Plan, that they

are taking a fairly negative view on employment land. They are not building in

any margins or aspirational growth projections for areas such as Ansty Park.

7. 47 H2 We support the urban extension proposal at Keresley and the allocations

proposed under site reference H2:1. Our client has an interest in that site.

8.

We do challenge reference to the need to make sure that the development is in

accordance with a comprehensive Masterplan. Whilst this vision is to be

applauded, delivery of this could be extremely difficult with a significant number

of Landowners involved all with different views. Inevitably there will be major

discussions and probably disagreements in how the Masterplan is achieved. Our

client’s interest is in the land that is shown edged red on the attached plan. This

is bordered by roads/houses on three sites and affords an opportunity for an

immediate release of housing land securing delivery in the early stages of the

Plan period. Given its proximity to other facilities it is not likely to be a preferred

location for a Local Centre and the release of this area should not be interlinked

with others. It does provide a great opportunity for a standalone immediate

development outside the area which requires Masterplanning.

9. 51 H3

We support point 1 but we would point out that this not a Policy that is consistent

with what Rugby’s Development Plan proposes. A larger mixed use scheme at

Walsgrave Hill Farm/Hillfields Farm would help to deliver a high quality

residential environment creating a sustainable community and enhancing the

built environment. It accords with the principles of sustainable Planning and

prevents further burdens on the already overburdened infrastructure in the

Rugby area. They have failed to address the need to make sure that the growth

of Coventry does directly adjoin Coventry’s administrative boundary.

10. 51 H3 We would suggest a minor rewording here to suggest that ... new developments

should wherever reasonably possible be.

Some of the criteria are not always achievable so there needs to be a degree of

flexibility in the approach.

11. 57 H6 We would suggest this is reworded to make it clear, particularly in the context of

point 5, that this will boil down to the production of viability assessments. It

should be clear that this will be sufficient by reference to “robust evidence”.

Executive Director, Place Marlin Yardley Assistant Director for Planning Transport and Highways Colin Knight

Ref:

JJ Development Plan

jp Document (DPD)

mr “

Publication Stage

Coventry City Council Representation Form

(for official use)

Policy H2 Policies Map

Name of the Development Plan Document to which the representation relates: Local Plan

Please return to Coventry City Council by 29th February 2016

This form has two parts- Part A - Personal Details

Part B - Your representation/s. Please complete a separate sheet for each representation you wish to

make

PART B - Please use a separate sheet for each representation

3. To which

part of the

DPD does

this

representation relate? Paragraph

If you have entered NO to 4.2, please proceed to Q5. In all other circumstances, please proceed to Q6

5. Do you consider the Plan is unsound because it is not

a) 1. Justified ____________

b) 2. Effective _____ s

c) 3. Consistent with national policy _______________

d) 4. Positively prepared s

PART A 1. Personal Details 2. Agent Details (If applicable)

Title Mr Mr

First Name Edward Martin

Last Name Walpole Brown Herbert

Job Title (If relevant) Landowner/Shareholder Partner

Organisation (If relevant) c/o Brown & Co - see across Brown & Co

Address line 1 Granta Hall

Address line 2 Finkin Street

Address line 3 Grantham

Address line 4 Lincolnshire

Postcode NG31 6QZ

Telephone number 01476 514444

Email address martin.herbert(3>brown-co.com

4. Do you consider the Plan is:

4.1 Legally compliant YES

NO

4.2 Sound YES NO

6. Please give details of why you consider the Plan is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the Plan, please also use this box to set out your comments.

S:\Agency\Martin Herbert\Walpole-Br»v«nV2016\Coventry City Council - Response Forms\Response_form local_plan - H2.doc

See statement attached.

7. Please set out what change/s you consider necessary to make the Plan legally compliant or sound,

having regard to the test you have identified at 5 above, where this relates to soundness. You will need to

say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put

forward your suggested revised working of any policy or text. Please be as precise as possible.

By taking out reference to Masterplanning in point 2 in Policy H2 or to legislate separately for smaller

related schemes that can be delivered independent of the Masterplans. This will ensure sites are delivered

to meet the housing strategic targets.

Please note your representation should cover succinctly all the information, evidence and supporting

information necessary to support/justify the representation and the suggested change, as there will

not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage.

After this stage, further submissions will only be made at the request of the inspector, based

on the matters and issues he/she identifies for examination.

8. If your representation is seeking change, do you consider it necessary to participate at the oral part of

the examination?

9. If you wish to participate at the oral examination, please outline why you consider this to necessary

We are happy to join with others and/or stand down if others address the same issues. This will not be

known until we have seen all the other representations.

NO I do not wish to participate

at the oral examination

YES I wish to participate at the

oral examination

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have ind icated/ibBt/thev wish to participate in the oral part o the examination.

Signature Date 29th February 2016

Executive Director, Place Martin Yardley Assistant Director for Planning Transport and Highways Colin Knight

Ref:

JJ Development Plan

jp Document (DPD)

mr *

Publication Stage


(for official use)

1. Personal Details ______ 2. Agent Details (If applicable)

Mr Mr

Edward Marlin

Walpole Brown Herbert

Landowner/Shareholder Partner

c/o Brown & Co - see across Brown & Co

Granta Hall

Finkin Street

Grantham

Lincolnshire

NG31 6QZ 01476 514444 martin. herbert(3>brown-co.com






make

PART A

Title

First Name Last Name

Job Title (If relevant)

Organisation (If relevant)

Address line 1 Address

line 2 Address line 3

Address line 4 Postcode

Telephone number Email

address

PART B - Please use a

separate sheet for each

representation

3. To which

part of the

DPD does

this




a) 1. Justified ____________

b) 2. Effective S

c) 3. Consistent with national policy ________________

d) 4. Positively prepared | s



NO

4.2 Sound YES NO ✓


SAAgency'Martin Herbert\Walpole-Brown'2016\Cove*ftry City Council • Response Form5\Response_form locaLplan • H3.doc






By making the first line on point 4 read: new development should wherever reasonably possible be;





After this stage, further submissions will only be made at the request of the Inspector, based



the examination?



known until we have seen all the other representations.

NO I do not wish to participate v' at the oral examination


oral examination

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have ind icated that tttey wish to participate in the oral part o the examination.

Signature "Date 29th February 2016

Executive Director, Place Martin Yardley Assistant Director for Planning Transport and Highways Colin Knight

Ref:

JJ, Development Plan

jp Document (DPD)

mr "

Publication Stage


(for official use)






make

PART B - Please use a separate sheet for each representation

3. To which

part of the

DPD does

this




a) 1. Justified ____________

b) 2. Effective _____ S

c) 3. Consistent with national policy ________________

d) 4. Positively prepared s

1. Personal Details 2. Agent Details (If applicable)

Title Mr Mr

First Name Edward Martin

Last Name Walpole Brown Herbert

Job Title (If relevant) Landowner/Shareholder Partner

Organisation (If relevant) c/o Brown & Co - see across Brown & Co Address line 1 Granta Hall

Address line 2 Finkin Street

Address line 3 Grantham

Address line 4 Lincolnshire

Postcode NG31 6QZ

Telephone number

01476 514444

Email address martin.herbert(3).brown-co.com



NO

4.2 Sound YES NO ✓


SMgency'Martin Hertert\Watpole-Brown\2016\Coventry C y Council - Response Forms\Response form local Plan- H6.doc






The rewording of point 5 on the second line to read ...

Robust evidence in the form of a viability appraisal must be presented to justify a reduced or alternative.





After this stage, further submissions will only be made at the request of the Inspector, based



the examination?



known until we have seen all the other representations,

NO I do not wish to participate

at the oral examination


oral examination

Please note the Inspector drill determine the most appropriate procedure to adopt to hear those

who have inc icated thattfhe v wish to participate in the oral part o the examination.

Signature

zz

Date 29th February 2016

Manor Farm

Officer comments

Comments noted. We appreciate your comments in relation to Walsgrave Hill Farm proposals in

particular and the joint working that remains on-going with Rugby Borough Council. Both authorities

have undertaken continuous and effective working in relation to the duty to cooperate and potential

developments along the city's eastern boundary. We fully expect this to continue in accordance with

the ambitions of both authorities and the C&W LEP.


Representation ID Number: 342 - general

343 - housing

344 - employment

345 - city centre and retail

346 - communities

347 - green belt and green space

348 - tourism

349 - accessibility, transport and infrastructure

350 -

deliverability Representor Name: David Penn

Company: Coventry and Warwickshire Chamber of Commerce

y’-v2- -

Reference LB/DP/BT

Coventry & Warwickshire Chamber of Commerce The Ultimate Business Network

t 02476 654321 f 02476

450242 e info@cw-

chamber.co.uk w www.cw-

chamber.co.uk

Mark Andrews - Planning Policy Manager

Coventry City Council,

Tower Block,

Much Park Street,

Coventry CV1 2PY

25th February, 2016

CITY DEVELOPMENT

DIRECTORATE

2 9 FEB 2018

DEVELOPMENT

MANAGEMENT

RE: COVENTRY AND WARWICKSHIRE CHAMBER OF COMMERCE RESPONSE TO

COVENTRY CITY COUNCIL'S JANUARY 2016 LOCAL PLAN PUBLICATION DRAFT (and the City

Centre Action Plan which sits below it)

Dear Mr Andrews,

BACKGROUND AND CONTEXT

1) The Chamber sees itself as an important partner and "sounding board" to CCC, all the other Local

Authorities in Warwickshire, other partnership organisations ( such as C&WLEP ), Government

Agencies, etc. as well as Private Sector organisations and interests. As such the Chamber welcomes

the on-going opportunity (and responsibility) to contribute and be part of the area's strategic planning

processes.

2) The Chamber can often bring an objective, dispassionate and non-political viewpoint to these

important discussions and can act as a "Critical Friend" in challenging whether the ideas and

proposals in the Plan are likely to deliver what is needed for our city, and will indeed meet the

objectives, priorities and changes needed for Coventry to BOTH be a Top 10 City but also to achieve

PROSPERITY THROUGH GROWTH.

3) The Chamber had been involved in the many discussions that took place to develop the initial draft

Plan (of September, 2014) and had set up its own small working group to formally consider and

respond to that Consultation Draft. The Chamber's detailed response was submitted in late October,

2014. Whilst being strongly supportive of the main emphasis of the draft Plan, the Chamber wanted to

register that the final draft of the Plan that would subsequently emerge must go much further than just

the housing aspects and the Chamber raised the following "headline" issues that it said had to be

addressed:

-the final Development Plan must be based upon comprehensive, coherent and integrated

development-not just housing,

-our 20 year Plan cannot and must not dodge the important decisions the City needs to make about

its strategic infrastructure,

Chamber House | Innovation Village | Cheetah Road | Coventry CV1 2TL

Registered in England No. 2478695

INVESTORS \ Jf IN

PEOPLE

mailto:[email protected]

mailto:[email protected]

http://www.cw-chamber.co.uk/

http://www.cw-chamber.co.uk/

-"Greenbelt" isn't "Greenspace",

-recognising the value and opportunities of growth,

-recognising the scale of investment in the city that a 20 year house building programme alone could

generate,

-the Chamber believes that the city is fast running out of high-quality employment land,

-the Chamber has serious and on-going concerns about the credibility and deliverability of 16,500 new

homes on Brownfield and existing Greenspace sites, and

-"Aspirational" housing isn't just large, higher-cost housing.

4) The Chamber would want to put on record its appreciation that CCC has heard, acknowledged

and understood what the Chamber said back in October, 2014 in terms of the earlier draft of the Plan.

5) We are very positive and supportive in terms of the progress that has clearly been made in

responding to these and other issues, and we strongly support the key principals, objectives and

priorities set out in this (updated) Draft.

6) We also need to emphasise that we understand that Coventry's Draft Local Plan, which can refer

to Sub-regional spatial development but must restrict its strict geographic coverage to only the

administrative area of Coventry, DOES NOT GIVE US THE "TOTAL PICTURE" OF THE SCALE AND

DISTRIBUTION OF GROWTH AND NEW DEVELOPMENTS IN OUR OVERALL AREA. THIS IS TRUE FOR

EMPLOYMENT LAND, STRATEGIC INFRASTRUCTURE, ETC. AS WELL AS HOUSING, AND MUCH OF

COVENTRY'S ECONOMIC AND EMPLOYMENT LAND NEEDS ARE PROPOSED TO BE MET ON LAND

NEAR TO BUT OUTSIDE OF COVENTRY (e.g. Ansty, Ryton, Coventry and Warwickshire Gateway, etc.).

As a Chamber that operates on a Sub-regional basis we need to be able to see the wider and overall

"picture", so that we can understand and support the essential land planning, infrastructure, transport,

economic, housing, social and community, etc. requirements of the Sub-region and ensure a "joined-

up" approach is delivering what our area needs. As is summarised in different paragraphs below,

because we are only considering Coventry's Draft Plan in this response, we cannot be assured that all

the sub-region and cross-boundary elements that are essential if this Plan is to work are actually in

place especially in terms of employment land, and the strategic infrastructure needed to support

growth. We would hope that this "overviewing" and "essential connection" role is something that the

Sub-region's Political Leaders Group and C&WLEP (with ours and others support) could carry out, and

we look forward to seeing a Sub-regional development Plan (even if it has- at present- no formal

recognition within the Government's National Planning requirements).

7) In that context, the Chamber has also commented to Rugby Borough Council and recommended

that their 20 year Plan proposals should ensure that further growth opportunity at the Ansty R&D

Business Park should be recognised and protected. Warwick District Council has only very recently

publicised its amended 20 year Plan proposals. Whilst the Chamber has not been able to consider

these in depth before submitting this response to Coventry's Plan, the Chamber is pleased to see that

strategic proposals for rezoning Green Belt land for the Coventry and Warwickshire Gateway scheme

and major new housing and employment at Kingshill and Westwood Heath are now included in

Warwick's proposals, together with a clear recognition of the need for strategic new infrastructure for

the south-east, south and south-west of Coventry ( as is emphasised elsewhere in this Chamber

response).

8) With the Development Plan proposals now published for Coventry, Rugby and Warwick, the

Chamber is anxious to see how Nuneaton and Bedworth's and North Warwickshire's Plans can

similarly respond positively to the agreed needs of the Sub-region. This is particularly the case in

terms of the N&B Plan, since they are being asked to make a hugely important contribution to meeting

very important employment land and housing on a cross-boundary basis. As is indicated below, The

Chamber has particular concerns about providing significant new employment land, and -for obvious

reasons-strategic growth of Coventry's urban footprint in the north provides huge opportunity both to

provide more employment land (as part of a true mixed development) but also to bring more and more

employment and regeneration to the area most in need of it.

9) The Chamber's response to this January, 2016 Draft Plan to 2031 is therefore focussed upon:

-as a "Critical Friend" is there anything we want to highlight about the (up-dated) Draft Plan?

-are there practical issues and concerns that we wish to raise that might challenge the (up-dated) Plan

in terms of its "soundness", robustness, credibility and deliverability? and

-do we have any proposals/amendments that we believe need to be incorporated/changed in the final

Development Plan submitted for formal Public Examination by the Planning Inspector?

10) There is much to support and commend in this Publication Draft. Its vision, objectives and scale of

change proposed are all totally compatible with the Chamber's focus upon "Prosperity through Growth"

and our "Go for Growth" initiatives.

11) We believe this (up-dated) draft is much more comprehensive and complete in terms of a strategic

plan for the next 20 years than the September, 2014 draft (which we all recognise was based primarily

upon the challenging issue of housing needs, growth and distribution).

12) We are particularly encouraged by the honesty and reality of CCC's strategic plans- recognising the

not insubstantial challenges these bring in terms of democratic governance, political and community

engagement and Sub-regional cross-boundary working.

13) We also believe that the recently signed Memorandum of Understanding by all Local Authorities in

the Sub-region (bar N&B at this stage) shows how Local Authorities can plan and operate together - with

common accord and focus - to recognise that the communities they both lead and serve don't live their

lives in administrative "boxes" that are the boundaries set by public sector management needs.

14) We believe this demonstrates how potent and effective common sense Sub-regional working can be

in any discussions and programmes for regional devolution. Regions are made up of Sub- regions, which

more closely align to civic identity and a "sense of belonging", and both regions and sub-regions can

each play their part in the delivery of success.

15) Coventry is now recognised as the fastest growing English city outside of Greater London. The

Chamber strongly welcomes both the opportunities and challenges this brings. We appreciate that

A FOCUS UPON HOUSING

there remains sensitivity and challenge to what this rapid population growth means to Coventry (and

the sub-region) BUT THE GROWTH OF THE CITY IS SOMETHING TO BE GRASPED WITH BOTH

HANDS. Many people in Coventry still look back with nostalgia at Britain's Boom city where more and

more people wanted to live and industry wanted to prosper. We have that opportunity again. The city

has turned itself round, and whilst we all recognise there is still much to do, we are on a positive

trajectory and we shouldn't be blown off course. Coventry - and its people - doesn't have a God-given

right to a positive future. It's our future and we have to work hard to deliver it.

1) The Chamber is very supportive of the significant planned growth in HOUSING and the enlargement of

Coventry's urban footprint- both inside the city's boundaries and on a crossboundary basis. We recognise that

urban enlargement- in a city like ours - almost inevitably - requires a change to the historic (and largely

technically now out-dated) definition and application of Green Belt.

2) In our previous response to the September, 2014 Draft Plan, we strongly emphasised that "Greenbelt" isn't

Greenspace" and that the city should be planning its urban growth on the basis of a truly eco-led approach,

whereby as many people as possible should be able to benefit on a daily basis from living in an environment

that others might take for granted. We do not want to see the single-focussed sprawling housing estates of

the past century, and we want to promote quality mixed development to respond to people's overall needs.

3) We also believe that the scale of housing growth now proposed can be a major "driver" of economic and

employment growth as well as a necessary response to it. Coventry's present housing stock is 135,870. New

housing of 24,600 to 42,400 represents an 18 to 31% increase in our housing provision over the next 15/16

years. This scale of development gives us -and our economy- enormous challenges but also enormous

opportunities. (Even without including all the other costs of development embraced in this 20 year Plan, at an

average building cost of a house of £100,000, this implies £4.2 Bn of investment in the city, and this probably

represents only 25% of what is likely to be the full scale of investment that would be generated by the Plan

over the next 15/16 years).

4) In relative terms our population is young and our 2 universities and their R&D facilities and offshoots

attract intelligent and ambitious young people from across the world. To attract and then retain these people

and offer a quality and diversity of housing to our growing population, there needs to be a dramatic change in

our housing offer, and we are particularly keen to highlight our support to the significant focus upon larger houses. It has long

been recognised that Coventry has a dramatically different offer to its competitor cities - and indeed its nearby

neighbours - in terms of the make-up of our housing stock, and we are pleased that the (new) Draft Plan

finally and formally recognises this, and makes it a clear planning priority to change this. (71% of all Coventry

homes are within the 2 lowest Council Tax Bands (A and B) compared to N&B at 60% and the national

average of 44%. Likewise just 10% of Coventry's existing housing stock is detached, compared to 24% in

N&B and 22% nationally). The Plan proposes that 60 - 70 % of the total new housing required should be

the larger 3 and 4 bed family homes. This will dramatically improve Coventry's offer and appeal, and is long

overdue.

5) In similar context, our October, 2014 response to the previous Draft Plan emphasised that "Aspirational

housing isn't just large, higher-cost housing". Again, we are pleased that the different housing needs that

people have for their housing at different times in their lives, is now more forcefully reflected in this up-dated

Draft Plan. With the large-scale growth in our urban footprint we have the opportunity to deliver the breadth

and diversity of quality housing within a truly eco-led and mixed use approach, and to focus upon significantly

altering the balance and make-up of the nature of housing we can offer.

6) In that regard, the Chamber is pleased to see clarity about, and promotion of, self-build opportunities

within existing "ribbon" and/or rural locations. Coventry has always been short of such small, self-build

opportunities, and indeed our planning policies have tried to see any development in the "Green Belt" -

whether good or bad- as undesirable and unacceptable. We hope to see that the strategic decision to grow

within the existing Green Belt and the encouragement of self-build housing therein signals a more

comprehensive review of Green Belt policies and the better connection between urban and more rural living.

(See Policy H3, page 52).

7) The Chamber recognises that - to make best use of the land that is available for housing - it is necessary

to promote target densities for new developments. This is particularly the case when it comes to the scale of

new housing being proposed in the 2016 Plan. The Chamber would argue for common sense flexibility in the

application of housing density targets - especially if we are to achieve both the significant change in the

overall make-up of our future housing stock and in delivering new eco-led mixed developments and

communities.

8) The Chamber is pleased to recognise that the new Draft Plan proposes to amend existing planning

policies and requirements to respond better to the ability to deliver socially-affordable housing, and how such

necessary provision is financed within/by market-price housing. The new Plan identifies a need for a further

12,000 "affordable" houses within the overall housing targets.

The Chamber believes strongly that- in these days of significant reductions in public sector support to social and specialist housing-

merely transferring the financial burden from the public sector to the private sector will significantly undermine both the deliverability and

timescale for the 42,400 new homes required for Coventry. We would particularly and specifically ask that urgent

consideration is given to detailed discussions about how Social-Affordable Housing is delivered and what

approach Coventry will take to the forthcoming Community Infrastructure Levy (CIL) that is planned to

(largely) replace Section 106 agreements. This will be hugely important to raise and sustain credibility and

commitment within national and local housing companies and those institutions that provide them with their

finance. Coventry's ambitious housing plans will never be more than plans unless we can get the "housing

market" to want to be a key partner in our future. The scale of the need for new "affordable" housing, the

significant reduction in Government grants to support such housing, the destabilising effect Government

announcements have recently had on Housing Associations, the continued - and increasing- difficulties for 1st

time buyers to get into the housing market, etc. etc. all make it imperative that Government - at a National as

well as Local level - understands how radically Britain's "historic" and assumed patterns of housing tenure

have and are changing, and develop changed policies that respond to this. What is clear is that the Private

Rented Sector will have to take a much greater role in the future than it has in the past, indeed as it does in

many other countries.

9) The (new) Draft Plan begins this process of responding to the significant change that has and is

happening in the (historic) housing market. The obstacles and costs of home ownership, especially to our

young people and those on average earnings, means that the Private Rented Sector is likely to play a much

greater role in meeting housing needs than it has for perhaps 100 years. Historically- and relative to many

other advanced economies- Home Ownership, the cost of housing in Britain, and the amount of our national

wealth that we have tied up in home ownership, is significantly higher than countries such as Germany. Some

of this will be down to national characteristics and cultures, and what lies behind "an Englishman's home is his

castle". But this assumption and focus upon home-ownership-for-all is being significantly challenged -in

practice if not yet in principal - especially within our young people. The financial realities of today's housing

market means that the Private Rented Sector - in its many new manifestations and specialisms- needs to be

more fully understood in terms of delivering the scale and pace of new housing proposed for the city. The

Chamber believes the City Council needs to carry out a rigorous review to see what changes it needs to make to its planning,

development, housing and Section 106 and Social Housing Contributions policies if it is to deliver the scale of new housing proposed?

10) In terms of funding "Affordable" housing ( page 56 and then Policy H6 on page 58) the Council is

proposing that it will seek a developer contribution of 25% towards the provision of affordable housing on

developments of 25 dwellings or more, or over 1 ha in area. Whilst the (new) Plan seeks to be more flexible

than policy has been in the past with regard to the location and distribution of new "affordable" housing and

how developer contributions will be calculated - a changed approach the Chamber supports- and also

introduces and acknowledges that "affordable" housing will be made up of "Social/Affordable" and

"Intermediate" provision, the Chamber is anxious to emphasise that all and any developer contributions to

fund this sector of housing simply comes from higher prices charged for the new Build-for-Sale and Build-for-

Rent properties that are built by the commercial sector. In a city such as Coventry, with a huge and growing

demand for new housing and a commitment to significantly change the nature of its housing stock, the

"premiums" that have to be added to new house prices/rents will be significant, and could simply stifle our

aspirations for large-scale growth. Will this hold back the regeneration of Coventry that we all want to see, and where does the

significant new focus upon new build Housing -for-Rent figure within it when it comes to requiring a 25% contribution to "Affordable"

housing?

11) It is recognised that UK house building is still too slow. Recent National House Building Council figures

show that there were 156,140 registrations for new homes in 2015 - the most since 2007 and 75% higher than

during the depths of recession in 2009. But this is still well short of the 200,000-plus homes that need to be

built every year. In addition- and perhaps because of recent experience in the financial crisis and recession -

the UK's national housebuilders are taking a cautious rather than expansionary approach to their businesses.

Their profits and share values are rising, but rather than re-invest they are returning significant sums to their

shareholders and "cleaning up" their Balance Sheets and paying down debt. They seem comfortable merely

to operate at a pace of construction- and in areas and markets that they know - rather than respond positively

to the acknowledged and growing shortfall in the nation's housing provision. It is in this context - and because

the city now has a huge housing growth programme that it wants to promote and deliver- that the Chamber

wishes to raise the issues it has above and PARTICULARLY to raise the 2 interlocked issues in paragraphs

13 to 18 below.

12) There are some other aspects of housing we wish to comment upon:

-Student Housing. The Draft Plan (and the City Centre Action Plan which is a subsidiary document to it) rightly

recognises the importance of students to the life and economy of our city. New, quality student

accommodation - both to accommodate growing student numbers and their expectations AND to reduce the

pressure student lets have on the availability of our existing housing stock to nonstudents, especially young

families- is strongly supported. The Plan seems to focus predominantly upon Coventry University and

in/around the City Centre. There doesn't seem to be any recognised plan for where the new student

accommodation should go? The ( welcomed) new developments we've seen in the media over recent years

and months, seem to present a picture of "windfall" sites i.e. redundant or derelict sites, infills or

redevelopment of buildings previously in other use, rather than setting out preferable sites for new student

accommodation ( as we would normally do for new retail, employment or non-student housing). Of particular

concern to the Chamber is that - other than on the University of Warwick campus - there seems to be no

approach to promoting residential accommodation for Warwick students in Coventry. We are all aware that

there are large numbers of Warwick students who live in Canley, Cannon Park, Earlsdon, etc. but the great

majority of Warwick's "off-campus" students, post-graduates, researchers, etc. are still assumed to gravitate

to Leamington and- to a lesser extent - Kenilworth. This seems a huge loss to Coventry that the Development

Plan doesn't seem to consider. Shouldn't we be more proactively planning to incorporate student and

university buildings into the general fabric of our society and think more about how student accommodation

can contribute positively to the vibrancy and sustainability of local communities? In addition there does not

seem to be recognition that the make-up of today's students in our city is quite radically different from even

the recent past. The scale (and spending power) of our foreign students is something that isn't sufficiently

recognised. Foreign students, especially, come with the spending power and expectations for

accommodation, location, services and facilities that make them "scene-changers" in terms of what the city

needs to offer and what they are prepared/able to pay. Shouldn't our 20 year Plan be more proactive in terms of planning

for student and University-focussed accommodation (under and post-graduate) especially in the new Green Belt developments planned

for the south and west of the city, and in and around the city centre?

- ( Page 65 of the Plan) The City - for the first time in 50 years - is looking to plan very large-scale new mixed

sites on the edge of our existing urban footprint ( both within and outside Coventry's boundaries ) and is

seeking to further register, protect and benefit from true public Greenspace. We

wonder whether the ambitions of 5,15 and 20% of land (on sites in the city centre, on sites below 2 ha, and on the bigger sites above 2

ha, respectively) to be protected for Greenspace and the quality of our environment is ambitious enough for a city that wants to transform

its housing offer and fulfil the aspirations of a young, growing population?

13) In terms of the Housing section of the (new) Plan, the Chamber has 2 OUTSTANDING AND VERY SERIOUS

CONCERNS, which it is felt, could undermine the positive plans for housing (that the Chamber supports) unless

practical ways forward can be found. As such, these concerns impact upon the "soundness", credibility and

deliverability of the Plan.

14) In our October, 2014 response to the previous draft Plan we highlighted our concerns about the

credibility and deliverability of 16,500 new homes on Brown Field and existing Greenspace sites. Our

concerns were predominantly about the economics of particularly the smaller and more contaminated Brown

Field sites, or sites prejudicially affected by existing neighbouring usages. The (new) Plan recognises that in

excess of 90% of new homes in recent years have been built upon previously developed land - notably the

large, historic employment sites mentioned below. Whilst this is commendable redevelopment of derelict and

redundant old employment land, it also highlights that:

- There is therefore less land available for employment, and

-the bigger, and easier-to-develop and more economic Brownfield sites for housing are now nearly all gone.

It is not easy to see from the (new) Plan, what is the scale of Brownfield housing that is now proposed (as

compared with the 16,500 proposed in the recent past). The Chamber would want to understand the scale, nature and

location of the remaining Brownfield sites attributed to new housing, and to see how the City Council has evaluated the economics and

deliverability of these sites. Without these sites being deliverable in reality, then this only places more pressure upon further Green Belt

and cross-boundary land release.

15) Almost hidden within the wording of Page 48 of the Plan is the re-affirmation of "Brown Field First and then- and

only then- Green Field" (our inverted commas). The Plan recognises that

"...since 2001 in excess of 90% of all new houses in Coventry have been built on previously developed

land. The continuation of this trend will be challenging moving forward but will remain an important priority of

this plan. Through its monitoring process the Council will therefore seek to achieve a majority of annual

completions on brownfield sites. Should this fail to materialise for 2 consecutive monitoring years then the

Council will consider this a secondary trigger in the delivery of its "Supporting Housing Delivery Development

Plan Document" ".

16) The Chamber are concerned that whilst the City Council has demonstrated bold vision and determination to grow the city and face

up to the political and practical obstacles that would prevent that growth, the planning procedures and approaches in this Publication

Draft lag significantly behind the political momentum. The Chamber believes that we - collectively - must find a simple

and robust way to proactively manage the Brown Field/Green Belt release development challenge. Without

doing this the Chamber believes that this Plan will lack any credibility with the major external organisations

and bodies that need to "sign-up" and commit to this Plan. As such the "soundness" of the Plan - as a Plan

that will promote, produce and deliver the scale of change that is sought- will be in doubt. In the 15/16 years

to 2031, we are looking to build 42,400 new homes in and adjacent to Coventry, to create truly mixed

developments, to attract major new employment and investment, to provide significant new transport

infrastructure and all

the new public services and facilities a Top 10 city should provide ...... but we expect to be able to do

this by artificially restricting and "log-jamming" that which is the vital ingredient in this whole process i.e. commercial housebuilding.

17) Later in this response the Chamber is proposing that- in whatever form- Coventry City Council "breaks

the mould" ( as it has done many times in the past) and demonstrates how real change in thinking and

delivery can be made to happen. We believe that a Coventry Development Plan Partnership, involving all the key "players" and

partners necessary to deliver the City's ambitious 15 year "game-changing" plan , needs to be created. This Partnership will help

give credibility and certainty to the city's Development Plan, and ensure that land release, infrastructure

investment, social and community provision, etc. are all planned and brought together in a way that responds

proactively to the very tight and ambitious timetable the city has set itself.

18) The Chamber understands-that whilst not directly a planning policy matter- the scale of "new" monies

available to Local Authorities from "new" Council Tax and Business Rates, etc. is a key element of how

Councils can fund both existing services and the growth of their cities/towns, and this source of funding

becomes more and more important as historic levels of Central Government grants, etc. are reduced. Since

much of Coventry's planned growth will be on a cross-boundary basis, the Chamber recognises that important

discussions and agreements need to resolve how and where this "new" money is attributed and spent. Again,

historic Local Authority administrative boundaries do not always reflect the reality of how people live their

lives, and the growth of Coventry's urban footprint, especially where this involves cross-boundary growth,

necessitates common sense agreements between Local Authorities about how "new" services are to be

provided and financed.

A FOCUS UPON EMPLOYMENT LAND

1) In terms of LAND FOR EMPLOYMENT the Chamber has real and on-going concerns about the scale, nature, quality and diversity of

land for employment. Page 32 of the Plan says that recent research for C&WLEP indicates that the Sub-region

needs " between 500 and 660 ha of employment

land....up to 2031 .... to meet envisaged need" and "sites be identified that can achieve the higher

end of this range". The CCC Plan provides for a total of 101 ha of land for employment within the city's

administrative boundaries (including Friargate, Lyons Park and Whitley, with "new" employment land as part

of the planned Eastern Green development and the extension of Whitley Business Park sites, and 3 much

smaller sites on the north of the city).

2) As is indicated above, big employment sites (such as Massey Ferguson at Banner Lane, Peugeot Stoke,

GEC/Marconi at New Century Park and the old Courtaulds sites) have/are being redeveloped (predominantly)

for housing. Both U. of Warwick and Coventry University Science Parks are largely full; there is now limited

but restricted capacity at Whitley, Prologis Ryton and Keresley, Browns Lane/Lyons Park and Ansty. The

Coventry and Warwickshire Gateway scheme around Coventry Airport was "blocked" by the Secy, of State.

3) The Chamber is pushing for confirmation of further growth of the Ansty R&D Park and -it is hoped - new

land for employment could open up in the Draft Development Plans for North Warwickshire, N&B and

Warwick districts in terms of major cross-boundary mixed developments. There are other sites in the wider

Sub-region but these are much further away from Coventry and are likely to play only a minor part in meeting

the employment needs of a growing city. There are other sites, for

example near Toll Bar island where three local authority areas conjoin, that could also be brought forward for

beneficial use with cross-boundary co operational planning.

4) In terms of Ansty, it took several years of pressure from CCC and others to get AWM to "kick- start"

development of this strategic site for major R&D. The size, layout and "pulling power" of the site have been

hugely attractive and it contributes strongly to the much higher profile of R&D in the Sub-region. The

Infrastructure already developed for the site, and its direct connection to the M6 and M69, makes further

expansion of the site and its connection into areas to the east, south and west of the site both practical and

able to be delivered in the relatively short-term future. With the Highways Agency (finally) proposing that there

should be a changed junction and road layout that will connect into the University Hospital and planned new

housing on the west of the A46, and an extended Ansty and new "village" on the east of the A46, together

with the better opening-up and access arrangements to Coombe Country Park, we have at this location a

perfect opportunity to create the major new mixed-use cross-boundary development we hope for and

anticipate seeing in the north, south and north-west of the city's existing urban footprint ( when the N&B, North

Warwickshire and Warwick District Preferred Plans emerge).

5) The Chamber believes that the full scale of the proposed Coventry and Warwickshire Gateway site must be approved as quickly as

possible. It is very clear that the anticipated and essential growth in Coventry's economy and employment will

be very, very dependent upon the ready supply of quality employment land, and the Chamber believes the

city and Sub-region's credibility to Inward Investors and Indigenous Industry will be challenged if significantly

more land for employment is not created as part of the first large-scale growth in the city's urban footprint for

very many years.

6) Within this overall approach, the Chamber is anxious that the ( hugely important and growing) beneficial

impact of our 2 very successful Universities, especially in terms of their Science, Business and

Entrepreneurial units and off-shoots, and their potential and growth for the future, should not be restricted and

put at risk by an inadequate supply of land. After perhaps 25 years of hard work we are all now seeing how

the partnership work between our Universities and industry is bearing real fruit.

7) Whilst there is an understandable focus upon the larger employment sites for the bigger/more well-known

brands, the Chamber knows that there is a long-standing and unresolved demand for smaller business and

manufacturing sites, both to accommodate the "new" industries we want to encourage and support in our

changing city and to provide expansion for our smaller, specialised companies. Included within this grouping

are the very broad span of "creative" industries and services. These can contribute to the truly mixed-use

development of our city, and many of them want and need to be connected in to local neighbourhoods,

communities and facilities.

8) There are c. 35,000 people employed in the wider city centre, and Friargate is progressing as the city's

new Business District. It is anticipated that Friargate could support some 15,000 additional jobs, and more city

centre jobs could come from the South Side Retail developments and the continued growth of Coventry

University, but - in the context of Coventry needing to grow its overall "offer" if it really is to be the vibrant sub-

regional centre of a fast-growing and changing city- the Chamber continues to have concerns, that within a 20

year strategic planning horizon, more land needs to be identified for employment both within the city centre

and the city as a whole.

9) With the significant growth being planned in the city's urban footprint, the Chamber would ask that in

this strategic 20 year Development Plan, serious consideration and plans should be made to create a

new and dedicated "Recycling Business Park". As a city, we need to recognise the essential (and growing in

importance) nature of "recycling" industries, but they are often seen as "bad neighbour" industries and

their (historic) locations across the city and sub-region prejudices regeneration and development of the

areas within which they sit. We believe that CCC (and their partner Local Authorities) should be

planning for a major (c.200 acres) Recycling Business Park, that can be planned, located and managed

in ways that recognise the importance of the recycling industry (as we do for other major industries and

economic sectors) but is sited, accessed, configured with relevant topology, etc. to minimise its

negative impact upon the surrounding areas and maximise its economic and "green" potential.

10) The Chamber, and its Members, continues to be concerned about the shortage, lack of availability and "profile" of

employment land for SME's, for more "specialised" uses and -what is sometimes considered -"bad neighbour" but essential

industries. There is often a focus upon big sites, or for the needs of "big brands", but the Chamber needs to continue to "bang the

drum" for the small and medium-size industries and commercial operations as well as the large. The Chamber would

therefore want to see much greater recognition (and planning for) employment- in all of its

manifestations- and would be happy to work with the Council to promote and deliver this key aspect of

our economic future.

11) As we have indicated and proposed above, the Chamber believes that -collectively- we will only be

able to see that Coventry's (and the Sub-region's) needs are being adequately and effectively met in

terms of employment land (and the other major aspects of a 20 year strategic plan) when we've seen

the key spatial aspects of all the Sub-regional Development Plans brought together. This we believe is

a key role for our Sub-Regional Political Leaders Group and our C&WLEP.

12) We remain concerned that the Sub-regional employment land target (of 660 hectares) and Coventry's 101 hectares within it

may not be sufficient to meet what is a significantly changing and- now- fast-growing demand for quality employment land. The

Chamber therefore believes that a 2-tranche approach is needed, whereby we have a 1st tranche available for immediate and

short-term availability BUT WE ALSO HAVE A 2 ND TRANCHE THAT GIVES US CLARITY AND SECURITY THAT THE

ENORMOUS AMBITIONS WE NOW HAVE FOR OUR CITY AND SUB-REGION AREN'T THWARTED.

D) OTHER ECONOMIC-RELATED ASPECTS OF THE CONSULTATION PLAN, AND HOW IT IS TO

BE DELIVERED

In this last section of our response to the draft Plan and its policies, we will seek to focus upon the

economic aspects of the other Sections of the 169 page Plan

h 1) CITY CENTRE AND RETAIL (and the City Centre Action Plan). The Chamber made a considered and

detailed response to the initial Draft of the City Centre Action Plan back in April, 2015. Again, like the

overall 20 year Local Plan ( under which it sits) the Chamber is pleased to acknowledge that this

January, 2016 updated Publication Draft is cognisant of and responds to the contributions the Chamber

has already made.

2) We remain convinced that the predominant priority if we are to create the city centre that does justice to the city and its sub-

region, is to grow the employment base of the city centre. Whilst we welcome and support what the Council is

doing, especially in Friargate, we still believe that we are not being ambitious enough - relative to other

cities-in terms of our planned employment growth. The city centre supports c. 35,000 jobs at present.

We are advised that Friargate can accommodate a further 15,000. Major retail growth and the on-going

development of Coventry University should

advance this further ...... but will this be enough to create and sustain the dramatic change we all

know we need? Without in anyway undermining Friargate as the focus for immediate and shortterm

employment growth, the Chamber believes the Plan should demonstrate how the city centre could continue to grow its

employment base well beyond that now proposed.

3) Everyone now recognises that the Retail world is changing, and even the biggest and long-

established retail companies don't fully understand how best to respond to these on-going changes. The

Chamber is fully supportive of the long-standing need to significantly improve the city centre's retail

"offer", its scope, diversity and quality - especially compared to our nearby "competitors" most of whom

have seen major retail investment and change over the last 10 to 15 years.

4) In terms of the "functional" zoning that is proposed for the city centre, the Chamber acknowledges

and accepts that - like most other successful cities - different parts of the city centre inevitably focus

upon different uses, notably retail, culture, education, business, etc. The Chamber's primary concern is that all

parts of the city centre should be vibrant, welcoming and interesting to as many different people and interests as possible. The

best city centres in the world are a real mix, fusion and "cacophony" of people and activities. We believe that Coventry's historic

approach to "zoning" different areas of the city centre for different but prescribed uses is itself part of the city centre's problem.

This is apparent most especially in our central retail area which is "sterile" and unwelcoming after 6.00

pm. Since it sits at the centre of our pedestrian infrastructure, it also has a negative impact upon the

other areas around it. We need to bring more life and a diversity of usage into this central core, and historic planning policies

which might work against this must be changed. We also believe that the curtilage of the different zones should be more "porous"

than might be implied. So "zoning" should be about "predominant use" but not at the expense of interest and diversity of offer and

attraction of as many people as possible to all parts of the city centre. This should not be put at risk by simple lines on a map.

5) We are pleased to see that the (updated) Draft seeks to require that the redevelopment of the (old)

Civic Quarter should make an important, wider and more diverse contribution to the city centre than just

a further extension to the University Quarter, and we would hope that the City Council can work with the

University to "open up" the growing University area so that it feels like a true and welcoming part of the

city centre to everyone, not just students.

6) We welcome and support the Plan's emphasis upon better design, "identity", scaling, etc. of new

buildings, the creation of new "landmarks" that respect and re-inforce the location of the 3 historic

spires, etc. We believe that -if people are to believe the city centre is really changing for the better- then

new and redeveloped buildings, the spaces around them and how different areas of the city centre are

connected must manifest this real change. We believe Coventry needs new buildings and

building forms that celebrate and demonstrate that the city centre is changing ....and changing for the

better.

7) We recognise that-especially for Coventry - what is defined as the city centre will inevitably be

focussed upon the area within the Ring Road. As the Plan appreciates, the city centre will only grow if the

Ring Road is not a "corset" that constricts and limits true city centre activity. Much has been done to "bridge

over" the Ring Road, but -until relatively recently - very few buildings sought to present their "best face" to the

Ring Road. As the city centre changes and grows it needs to envelop and embrace the Ring Road rather than

be restricted by it. In this regard, whilst the proposed new City Centre Action Plan also considers some areas

outside the Ring Road, we find it strange that the Plan doesn't say something about the (old) British Gas

service and distribution centre opposite the Belgrade Plaza, or the "Lower Earlsdon" area from Queens

Road/the Butts/Old Technical college ere much development is going on/being planned.

3>j COMMUNITIES (PAGES 87 TO 92). With the significant reduction in Public Sector spending

comes a real challenge to our (historic) expectations of community-level public service provision.

Community arts, education, leisure, recreation, etc. facilities are fundamental to a good quality of life

offer and to caring and supportive neighbourhoods and communities. We recognise that major changes

are needed in the culture, management and operation of public buildings. Gone are the days when

single-use, restricted-hours municipal buildings could operate on our high streets, at local and

neighbourhood level.

9) Planning policy should be proactive in promoting the creation ( and redevelopment) of public

buildings that offer a multi-use, multi-benefit, 18 hour, 7 day operation AND the Private Sector should be

encouraged to bring forward proposals that re-use/redevelop these buildings to bring greater diversity

and employment at community level. Diverse/specialist shopping and local employment should be

promoted and the Council should use whatever powers it can to push for redevelopment of redundant

properties, whether public or private sector, that cast blight on local communities and areas, especially

at strategic local locations. Usage (under the different categories of Planning Permission) should be

reviewed and - as a means of promoting positive change - CCC's planning and land acquisition powers

should be used proactively to help revitalise and regenerate local areas.

10) Unfortunately, many of the Planning Policies (COl to C03) only seek to perpetuate the policies of the past and do not

recognise the realities of the present and future. As such, they are likely to promote the decline of neighbourhood and

communities centres rather than revitalise them. We

nk CCC should revisit their planning policies in terms of this whole Chapter.

JL1) GREEN BELT AND GREENSPACE. In a growing city largely confined by its own boundaries,

we believe CCC should be very positive and proactive about how the city and its people could benefit

from greater accessibility and day-to-day engagement and enjoyment of green space and the

environment.

12) As we've highlighted in the Housing section above, we are keen that CCC does not lose the

enormous opportunity to plan the growth in its urban footprint in true eco-suburb and mixed-usage

terms, where day-to-day access and engagement with a quality environment becomes a right of the

many, not just the few.

13) TOURISM. Tourism and the Hospitality Industry is a hugely important but often not high-profile part of

our local (and national) economy. With everything going on and planned in our city, we were surprised that the

Plan (page 42) only aims for a 10% growth in total visitor trips to Coventry by 2024 (up to 9M visitors pa) with a

corresponding 7% increase in annual visitor spend to £447M.The Chamber believes that the Plan needs to be much more

ambitious in terms of this important area ^of our economy and our external profile.

ACCESSIBILITY, TRANSPORT AND INFRASTRUCTURE. Section 10 of the Plan (pages 118 to

138) gives a very broad coverage to the different modes of transport, and there is little in here that the

Chamber wouldn't support.

15) In our response to the initial Draft Plan (in October, 2014) one of our "Headline" issues that we

raised with CCC in terms of developing the (final) draft Plan for Consultation was that "Our 20 year Plan

cannot and must not dodge the important decisions the city needs to make about its strategic

infrastructure".

16) We are therefore pleased to see a fairly comprehensive approach to how people travel into and within

the city. We particularly welcome the much greater focus upon how rail travel and new stations -

especially within the important NUCKLE north/south employment and travel-to-work corridor- can and

should make a much greater contribution to our transport and employment needs than rail travel does at

present.

17) Just considering CCC's Consultation Plan does not allow us- or others- to see " the bigger picture" or

how different things might fit together. This is particularly true in terms of meeting the city's and sub-

region's transport needs when the administrative boundaries between Local Authorities become largely

meaningless. So, in CCC's Plan, we see mention of a planned new Railway Station at Kingshill, on the

southern edge of the city, but without seeing what we anticipate is a major cross-boundary mixed-use

urban development in this area, we are not able to satisfy ourselves that a "bigger picture" actually exists.

(Warwick's Plan very recently released but not able to be fully understood in the preparation of this

response to Coventry).

18) This is also most important when it comes to all/any plans for major new roads infrastructure. Again,

in this Coventry Plan, there is reference to a major new road from the Coundon Wedge Road through the

lower end of Bennetts Lane and Keresley to meet up with Winding House Lane and the A444 to M6

Junction 3 ( as a key part of servicing the 3,100 new houses planned within the Coventry boundaries in

the Keresley area). There is suggestion that this new section of what is really Coventry's new "outer ring

road" will ultimately go direct to the M6 (somewhere near Corley Services?) but without seeing how North

Warwickshire and N&B propose to respond to the 540 and 4,020 new houses and new employment land

to be provided for in their area on cross-boundary developments to help meet Coventry's housing and

employment needs, then we cannot see how the road infrastructure will really be changed.

19) Coventry needs major changes in its "outer ring road" to both catch up with the significant

development that has happened over the last 20 years and the even more significant growth now being

planned for the next 15 years.

20) This is clearly the case for the south and south-west of the city as well as the north-west. With the huge (

and welcome ) growth in the U. of Warwick, the diversification of its academic, teaching and business-related

activities, the scale and nature of employment at Westwood Business Park, the likely line of HS2 and the (

anticipated) major mixed-use urban extension at Kingshill, then the City - and the thousands of people who

travel in and out of the city every day- needs a "new" outer ring road that connects the improved and widened

A45 and A46 ( from Tollbar and Whitley) through the A46 Stoneleigh/Gibbet Hill junction to a new road

constructed to the south of the University and connecting to the planned Eastern Green development and the

A45 near Allesley, from which it will then join the Coundon Wedge Road and its extension towards and

through the Keresley growth area towards the A444 and the M6.

21) It is this (a radically enlarged outer ring road) and other similar strategic additions/improvements to our

infrastructure that cannot and must not be "dodged" in Coventry and surrounding Districts'

20 year Plans.

22) The infrastructure to support the city's growth programme is key to its delivery. CCC has but a small,

direct role in ensuring infrastructure is delivered in a timely fashion. As such, Central Government, the

national Agencies of Government that cover key aspects such as Transport, the Environment, Education,

Economic Planning, Health, etc., Regional and Sub-regional bodies as well as all the Private Sector suppliers

of water, drainage, power, gas telecommunications, etc. all have to be both "active" players but also

"coordinated partners".

23) The plans and proposals for improved rail, strategic and local transport hubs, new railway stations, new

"trunk" highways, highway connectivity, rapid transit, etc. etc. are all supported by the Chamber, but we

remain concerned about the credibility and therefore "soundness" of these plans unless there is a much more

"joined-up" approach to their delivery. The 12 year fraught process to get even a minimum rail connection to the

Ricoh Arena and the 15 to 20 year delay (from when it was first planned) to up-grade Tollbar does not augur

well when it comes to the city being in control of its own destiny and sustainable growth.

24) Finally, in terms of this aspect, we are surprised and disappointed to see that very little mention and recognition is given to

the contribution Coventry Airport could and should make in our overall transport infrastructure and facilities. The only reference is to the

movement of freight by air. This cannot be right in a strategic 20 year Plan?

Ej~BtJT HOW WILL THIS AMBITIOUS GROWTH PLAN ACTUALLY BE DELIVERED?

1) JOINED-UP DELIVERY. The Chamber believes that if the scale and pace of these overall housing,

employment, infrastructure, etc. etc. plans are to be credible to a wider, national and international audience, to

inward and indigenous investors, to house builders, funders, Government Agencies, etc. then we ( collectively)

must build up a clear and coherent Delivery Plan.

2) What the CCC 20 year Plan proposes is a scale and timetable of growth, new buildings, strategic and local

infrastructure, public services, employment growth, etc. that has not been seen before.

THE CHAMBER STRONGLY SUPPORTS THIS BOLD AMBITION.

3) Historically, Coventry's population trebled over a 100 year period (106,431 in 1911 to 318,600 in 2011)

with a peak of population of 338,000 in 1971. Stabilising itself after the downturn and manufacturing collapse

of the late 1970's, 80's and early 90's, and then growing again from 2000 onwards, the city's population in 2015 at

337,400 is already back up to its peak in 1971, notwithstanding the almost seismic change in its economy. Coventry is

now the fastest growing city outside of Greater London and Central Government Population Projections see

Coventry's population exceeding 420,000 by 2031.

4) Whilst Coventry expanded dramatically in the first half of the 20th century, the complexity of "making things

actually happen in Britain" is now much greater than it was a 70 or 100 years ago.

5) Because of the nature of how strategic change and development is now planned and financed, what

processes and procedures have to be followed to turn ideas into reality in today's Britain, the need to secure

and maintain on-going external investment and funding, etc. the Chamber believes that a "STANDING

COMMISSION"-or similar- should quickly be formed between the key public and private sector partners and

organisations to take responsibility for identifying all the ingredients, timescales and priorities necessary to

deliver this ambitious and exciting Plan.

6) The Chamber would propose - perhaps through C&WLEP- that even while the Plan is progressing through

the next steps of the formal planning process, a Summit/Conference/set of Workshops or similar should be

organised to give clear direction and credibility to the Plan when it finally and formally is agreed. "We must hit the

ground running".

7) Without such a clear and coordinated manifestation of this "COMMITMENT TO DELIVER" the Chamber

believes these ambitious plans will not have the necessary credibility with the many external organisations

and agencies that have to be convinced and then involved. THIS ACTION PLANNING COULD BE AN IMPORTANT SUB-

REGIONAL CONTRIBUTION TO THE REGIONAL DEVOLUTION AGENDA.

8) The Chamber's final practical point about credibility and delivery of the Plan relates to the need for CCC to

have a serious reflection upon the many detailed planning policies that direct day-to-day planning discussions

and decisions (and many of these are shown in the different sections and Chapters of the Consultation Plan).

We are presented with a visionary, bold and exciting 20 year Plan for the city's future. We would ask that the

Council - and perhaps C&WLEP - should revisit detailed planning policies TO ENSURE ALL PLANNING POLICIES PROMOTE AND

SUPPORT BENEFICIAL CHANGE - NOT ACT (inadvertently or not) AS A CONSTRAINT UPON IT.

I hope these comments are useful and, once again, thank you for consulting with the business community via

your local Chamber of Commerce.

Yours sincerely

David Penn BA(Econ) BSC(Est Man) FRICS

Chair - Coventry Branch

Coventry & Warwickshire Chamber of Commerce

In terms of Green Belt land and opportunities for growth, these comments are noted.

1 - general

With regards the growth of the sub-region the city council is committed to on-going work with its

neighbouring authorities to deliver growth to Coventry and the sub-region. The city council is not

however able to allocate land within its own plan that sits within Warwickshire. The plan does however

highlight the importance of cross boundary developments and a commitment to supporting their on-

going development to the benefit of Coventry and the wider sub-region.

We recognise that this will be particularly important in terms of strategic infrastructure and will

continue to work jointly to ensure its delivery in an appropriate way.

2 - Housing

We recognise your concerns around the deliverability of affordable housing and the impact this may

have on wider housing delivery. The Plan is linked to a viability assessment of affordable housing

delivery however and its policies sit within what is shown to be viable. The delivery of affordable

housing (at all types and tenures) must be seen as a fundamental aspect of supporting mixed and

balanced communities and supporting the city's population at all levels of housing need.

In terms of sites for student housing these have been considered alongside sites for market housing.

The local plan has taken a flexible approach to site identification and delivery. The city centre is

recognised as the most sustainable location for student housing as is land adjacent and within the

Warwick University campus. These are the 2 specific locations that the local plan is looking to focus

new developments towards.

In terms of the SHLAA, the city council have a proud track record of brownfield delivery and urban

regeneration. All sites in the SHLAA have been assessed and identified as being developable over the

plan period. The Council believe this offers a robust assessment of its urban capacity. All the

brownfield sites identified are clearly set out in the SHLAA and have been assessed to test to their

deliverability and developability.

In terms of the brownfield first approach the approach is included to continue promoting brownfield

delivery and urban regeneration whilst also recognising the importance of greenfield sites coming on

line to deliver the city's housing needs. The trigger is a monitoring trigger which will be used and

considered as part of SHLAA reviews and annual monitoring reports.

3. employment

The local plan has taken a proactive approach to employment land delivery. In terms of aligning this to

housing delivery we have proactively planned for the loss of brownfield employment sites that may

come forward for housing over the plan period and looked to proactively reallocate this land within the

city and within sites adjacent to the city boundary. This will help support the growth of the city in a

sustainable and positive way, ensuring employment and housing needs are planned for up front and

that the city and sub-region can prosper moving forward.

The city council is committed to working jointly with its neighbours to ensure these sites are delivered

in a sustainable way.

4. city centre and retail

Comments noted. The Local Plan and AAP will work together to help regenerate the city centre and

draw more investment and visitors to the city centre.

5. Communities

Comments noted. The policies are set to provide a realistic and appropriate basis from which to plan

for community facilities. The Plan is positive and proactively encourages new provisions and looks to

protect existing facilities where they remain integral to local communities and viable in operation.

6. Green belt and green space Comments noted

7. Tourism

The local plan is very positive about maximising the benefits of tourism to Coventry and contains

specific policies to promote this.

8. Accessibility

We welcome your comments. The city council is and will continue to work very closely with its

neighbouring authorities to ensure strategic transport infrastructure is delivered in a timely manner to

support growth. The issue Coventry has is that mush of this delivery will be outside of its

administrative boundary and will be equally linked to developments adjacent to its boundaries but

within neighbouring authorities. As such there is only so far the Coventry plan can go in this regard.

Coventry airport sits within Warwick District, so it is difficult for the Coventry Plan to proactively make

proposals for it.

9. Deliverability

Comments noted. The city council is committed to the delivery of the local plan and recognises the

importance of continuing to work with its sub-regional colleagues, the LEP and other key stakeholders

to ensure the wider growth of the sub-region is realised. Policy DS2 is included to support and

demonstrate the city's continued commitment to this on-going work.


Representation ID Number: 368 (policy DS1), 369 (policy DS2), 370 (policyHl), 371 (policy H2), 372

(policy H4), 373 (policy H6)

Representor Name: John Fleming

Company: Gladman

Gladman Developments Ltd

Representations on Coventry City Council

Local Plan

Submission Version

February 2016

Coventry City Council Local Plan: Submission Version

CONTENTS

Executive Summary .............................................................................................................................................. 1

1 National Planning Policy and Guidance ........................................................................................................ 3

1.1 National Planning Policy Framework ............................................................................................................ 3

1.2 Planning Practice Guidance .......................................................................................................................... 4

2 Legal Compliance ......................................................................................................................................... 6

2.1 Duty to Cooperate ......................................................................................................................................... 6

22 Sustainability Appraisal ................................................................................................................................. 7

3 Objectively Assessed Housing Need ............................................................................................................ 8

3.1 Context .......................................................................................................................................................... 8

3.2 Coventry and Warwickshire SHMA ............................................................................................................. 10

3.3 Affordable Housing ..................................................................................................................................... 11

4 Coventry Local Plan Policies ....................................................................................................................... 12

4.1 Context ........................................................................................................................................................ 12

4.2 Policy DS1: Overall Development Needs .................................................................................................... 12

4.3 Policy DS2: The Duty to Cooperate ............................................................................................................ 12

4.4 Policy H1: Housing Land Requirements ..................................................................................................... 13

4.5 Policy H2: Housing Allocations ................................................................................................................... 13

4.6 Policy H4: Securing a Mix of Housing ......................................................................................................... 14

4.7 Policy H6: Affordable Housing .................................................................................................................... 14

5 Conclusion .................................................................................................................................................. 15

5.1 Summary ..................................................................................................................................................... 15


1

EXECUTIVE SUMMARY

i. Gladman Developments Ltd (Gladman) specialise in the promotion of strategic land for residential

development and associated community infrastructure. From this experience, we understand the need for the

planning system to deliver the homesjobs and thriving local places that the country needs. Every effort should

be made to objectively identify and meet the housing and economic needs of an area, whilst responding

positively to the wider opportunities for growth.

ii. These representations are made in response to the submission version of the Coventry Local Plan (CLP)

consultation. Through these representations Gladman seek to highlight a number of concerns that need to be

reviewed prior to the plan being submitted to the Secretary of State for Independent Examination.

iii. The National Planning Policy Framework sets out four tests that must be met for Local Plans to be considered

sound. To be consistent with national planning policy and provide an appropriate basis on which to plan for

Coventry City's housing needs, the Local Plan will need to be tested at Examination to ensure that it has been

prepared in accordance with the Duty to Cooperate, legal and procedural requirements, and whether it is

sound. The four tests which the Local Plan must meet should be considered in order to make the necessary

changes required to draft the Plan for the next stage of consultation. The four tests of soundness are as

follows:

- Positively prepared

- Justified

- Effective

- Consistent with national policy

iv. As currently presented, the Local Plan seeks to release significant land from the Green Belt to

meet 24,600 dwellings of its housing needs based on the Council's current land capacity. The

identified shortfall of 17,800 dwellings is to be distributed across the Coventry and Warwickshire blousing

Market Area (FIMA). However, it is considered that the Council's full Objectively Assessed Needs for housing is

significantly higher than what is currently being proposed. Gladman believe that the Council's ability to deliver its

full housing need will be difficult due its location within the

Green Belt. It is therefore likely that additional housing will be required across the HMA to meet Coventry's

unmet needs.

v. Gladman's submission on the Coventry Local Plan and its supporting evidence base are provided in full in the

main body of this response. To highlight a number of deficiencies of the Council's approach a summary of our

key concerns and conclusions as to the soundness of the Local Plan's policies is set out below in table 1.

These issues need to be addressed prior to the Local Plan being submitted for Examination.


2

vi. Gladman take this opportunity and request to be added to the Council's consultation database and be

notified of the Council's decision to submit the Local Plan for Examination. Gladman also request to

participate in the hearing session(s) of the Examination.

Policy Sound /

Unsound

Test of Soundness Reason Evidence

Policy

DS1

Unsound Positively prepared

Effective

The policy does not seek to deliver the full OAN. NPPF, PPG,

Policy

DS2

Unsound Positively prepared

Effective

It cannot be certain that the Council's housing needs

will be met in full.

NPPF, PPG.

Policy H1 Unsound Consistent with

national policy

The policy does not reflect the presumption in favour

of sustainable development advocated by national

policy.

NPPF.

Policy H2 Comment Further evidence needs to be made available

regarding the delivery assumptions for strategic

housing sites.

Policy H4 Unsound Positively prepared

Justified

This policy should be based on robust evidence at the

strategic level which Qualifying Body's preparing

neighbourhood plans should take account of.

PPG.

Policy H6 Unsound Positively prepared

Justified

The policy does not take account of viability or the

need to increase affordable housing numbers

through market led development.

NPPF, PPG

Table 1


3

1 NATIONAL PLANNING POLICY AND GUIDANCE

1.1 National Planning Policy Framework

1.1.1 The National Planning Policy Framework (the Framework) makes clear that the purpose of the

planning system is to contribute to the achievement of sustainable development and that Local Plans

should meet full objectively assessed needs (OAN) for housing.

1.1.2 The Framework has been with us now for over three years and the development industry has

experience with its application and the fundamental changes it has brought about in relation to the

way the planning system functions. Crucially, the Framework sets out the Government's commitment to

'significantly boosting the supply of housing' and how this should be reflected through the preparation of

Local Plans. It is imperative that the Coventry Local Plan is formulated on the basis of meeting this

requirement. In this regard, §47 of the Framework sets out specific guidance that local planning

authorities should take into account when identifying and meeting their objectively assessed housing

needs and states:

'To boost significantly the supply of housing, local planning authorities should:

- Use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs

for market and affordable housing in the housing market area, as far as is consistent with the

policies set out in this Framework, including identifying key sites which are critical to the delivery

of the housing strategy over the plan period;

- Identify and update annually a supply of specific deliverable sites sufficient to provide five years'

worth of housing against their housing requirements...

- Identify a supply of specific, developable sites or broad locations for growth, for years 6-10, and

where possible for years 11-15.'

1.1.3 The starting point of identifying objectively assessed housing needs is set out in §159 of the

Framework, which requires local planning authorities to prepare a Strategic Housing Market

Assessment, working with neighbouring authorities where housing market areas cross administrative

boundaries. It is clear from the Framework that the objective assessment of housing needs should

take full account of up-to-date and relevant evidence about the economic and social characteristics

and prospects for the area, with local planning authorities ensuring that their assessment of and

strategies for housing and employment are integrated and take full account of relevant market and

economic signals (§158).

1.1.4 Once a local planning authority has identified its objectively assessed needs for housing these needs

should be met in full, unless any adverse impacts would significantly and demonstrably outweigh the

benefits of doing so (§14). Local planning authorities should seek to achieve each of the economic,

social and environmental dimensions of sustainable development, resulting in net gains across all

three. Adverse impacts of any of these dimensions should be avoided. Where


4

adverse impacts are unavoidable, mitigation or compensatory measures may be appropriate (§152).

1.1.5 To be considered sound at Examination the CLP will need to meet all four of the soundness tests set

out in paragraph 182 of the Framework. Paragraph 182 states:

"A local planning authority should submit a Plan for Examination which they consider is 'sound' -

namely that it is:

• Positively prepared - the plan should be prepared based on a strategy which seeks to meet the

objectively assessed development and infrastructure requirements, including unmet

requirements from neighbouring authorities where it is reasonable to do so and consistent with

achieving sustainable development;

• Justified - the plan should be the most appropriate strategy, when considered against the

reasonable alternatives, based on proportionate evidence;

• Effective - the plan should be deliverable over its period and based on effectivejoint working on

cross boundary strategic priorities; and

• Consistent with national policy - the plan should enable the delivery of sustainable

development in accordance with policies in the Framework."

1.2 Planning Practice Guidance

1.2.1 As the Council will be aware the Government published its final suite of Planning Practice Guidance

(PPG) on 6th March 2014, clarifying how specific elements of the Framework should be interpreted

when preparing Local Plans. The PPG on Housing and Economic Development Needs in particular

provides a clear indication of how the Government expects local planning authorities to take account

the requirements of the Framework when identifying their objectively assessed housing needs. In

summary the Housing and Economic Development Needs chapter of the PPG states:

- Plan makers should not apply constraints to the overall assessment of need, such as limitations

imposed by the supply of land for new development, historic under performance, infrastructure or

environmental constraints.

- Household projections published by the Department for Communities and Local Government

should provide the starting point estimate of overall housing need.

- Household projection based estimates of housing need may need adjusting to reflect factors

affecting local demography and household formation rates which are not captured by past trends,

for example historic suppression by under supply and worsening affordability of housing. The

assessment will need to reflect the consequences of past under delivery and the extent to which

household formation rates have been constrained by supply.

- Where the supply of working age population that is economically active is less than the

projectedjob growth, this could result in unsustainable commuting patterns and could reduce the

resilience of local businesses. In such circumstances, plan makers will need to consider how

much the location of new housing or infrastructure development could help address these

problems.

If the historic rate of development shows that actual supply falls below planned supply, future


5

supply should be increased to reflect the likelihood of under-delivery of a plan.

Plan makers should take account of concealed households.

Housing needs indicated by household projections should be adjusted to reflect appropriate

market signals, as well as other market indicators of the balance between the demand for and

supply of dwellings. Appropriate comparisons of indicators (land prices, house prices etc.) should

be made - with longer term trends in the HMA, similar demographic and economic areas, and

nationally. Divergence under any of these circumstances will require upward adjustment to

planned housing numbers.

The more significant the affordability constraints (as reflected in rising prices and rents, and

worsening affordability ratio) and the stronger other indicators of high demand (e.g. the differential

between land prices), the larger the improvement in affordability needed, and the larger the

additional supply response should be.

Market signals are affected by a number of economic factors. Plan makers should increase

planned supply by an amount that, on reasonable assumptions and consistent with principles of

sustainable development, could be expected to improve affordability.


6

2 LEGAL COMPLIANCE

2.1 Duty to Cooperate

2.1.1 The Duty to Cooperate (DtC) is a legal requirement established through Section 33(A) of the Planning

and Compulsory Purchase Act 2003, as amended by Section 110 of the Localism Act. The DtC

requires local planning authorities to engage constructively, actively and on an ongoing basis with

neighbouring authorities on cross-boundary strategic issues through the process of Plan preparation.

The Council will be fully aware of the consequences of not fulfilling the DtC following the outcome of

the 2012 Coventry Core Strategy Examination. If the Council fails to satisfactorily discharge its DtC a

Planning Inspector must recommend non-adoption of the Plan. This cannot be rectified through

modifications.

2.1.2 Gladman recognise that the DtC is a process of ongoing engagement and collaboration1, as set out in

the PPG it is clear that the Duty is intended to produce effective policies on cross boundary strategic

matters. In this regard, the Council must be able to demonstrate that it has engaged and worked with

its neighbouring authorities, alongside their existing joint working arrangements, to satisfactorily

address cross boundary strategic issues, and the requirement to meet any unmet housing needs. This

is not simply an issue of consultation but a question of effective cooperation to ensure that the HMA's

housing needs are met in full.

2.1.3 The Council will need to effectively demonstrate what steps it has taken to engage with the wider HMA.

The Memorandum of Understanding (MoU) contained in the consultation documents states that

Nuneaton and Bedworth Borough Council (NBBC) will accommodate 2,060 dwellings to meet

Coventry's unmet housing needs. This position is not correct as N BBC have yet to sign the MoU and

the redistribution of Coventry's unmet needs across the wider HMA explained in the Coventry and

Warwickshire and South West Leicestershire Shadow Economic Prosperity Board Report (29th

September) which is notably absent from the Council's evidence. This evidence needs to be

included and submitted as part of the Examination.

2.1.4 With regards to the report mentioned above, the ability of NBBC to accommodate any of Coventry's

unmet needs is dependent on additional evidence base work that is currently being undertaken

and the outcome is still unknown. In the event that NBBC is unable to accommodate Coventry's

unmet housing needs the Council should seek to address this issue with the wider HMA area to

establish whether alternative authorities comprising the HMA will be capable of delivering this housing

shortfall.

2.1.5 It is important that the Council continues to publicise all accounts related to the DtC so that the

Inspector examining the Local Plan is able to make an informed judgement on whether the Council's

DtC requirements have been met. Failure to fulfil the DtC will likely result in the Inspector

arriving at the same conclusion as considered at the Coventry Core Strategy Examination particularly

given the complexity of the HMA and influences from neighbouring areas.

1 PPG Reference ID: 9-011-2014036


7

2.1.6 Furthermore, it should be noted that the Moll deals directly with the housing needs arising from the

Coventry and Warwickshire HMA, it does not address any of the significant shortfall arising from the

Greater Birmingham HMA. Given the significant unmet housing needs of Birmingham City Council, the

authorities contained in the Coventry and Warwickshire HMA who share clear linkages with

Birmingham City should seek to constructively engage with Birmingham to assess whether any of the

City's unmet housing need can be accommodated to ensure the national objective to significantly boost the

supply of housing to meet the Council's full OAN is delivered.

2.2 Sustainability Appraisal

2.2.1 In accordance with Section 19 of the Planning and Compulsory Purchase Act 2004, policies set out in

Local Plans must be subject to a Sustainability Appraisal (SA), and also incorporate the requirements

of the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA regulations).

2.2.2 T he SA/SEA is a systematic process that should be undertaken at each stage of the CLPs preparation,

assessing the effects of the Plan's proposals on sustainable development when judged against all

reasonable alternatives.

2.2.3 The Council should ensure that the future results of the SA clearly justify its policy choices. In meeting

the development needs of the area, it should be clear from the results of this assessment why some

policy options have progressed, and others have been rejected. This must be undertaken through a

comparative and equal assessment of each reasonable alternative, in the same level of

detail for both chosen and rejected alternatives. The Council's decision making and scoring should

be robust,justified and transparent.

2.2.4 At present, there is no evidence to demonstrate that the re-distribution of Coventry's unmet housing

need has been subject to any Sustainability Appraisal Testing. The Mol contained in the Council's

evidence base is in a draft form and is unsigned. Without the inclusion and testing of the proposed

redistribution of the City's unmet housing needs, there is no evidence as to how this distribution was

determined. Without further information there is no real certainty that the HMA will meet its full OAN.


8

3 OBJECTIVELY ASSESSED HOUSING NEED

3.1 Context

3.1.1 The process of undertaking an OAN is clearly set out in the Framework principally in §14, §47, §152

and §159 and should be undertaken in a systematic and transparent way to ensure that the plan is

based on a robust evidence base.

3.1.2 The starting point for this assessment requires local planning authorities to have a clear understanding

of housing needs in their area. This involves the preparation of a Strategic Housing Market Assessment

(SHMA) working with neighbouring authorities where housing market areas cross administrative areas

as detailed in §159 of the Framework. The Framework goes on to set out the factors that should be

included in a SHMA including identifying:

"The scale and mix of housing and the range of tenures that the local population is likely

to need over the plan period which:

• Meets household and population projections taking account of migration and

demographic change;

• Addresses the need for all types of housing including affordable housing and

the needs of different groups in the community (such as, but not limited to,

families with children, older people, people with disabilities, service families and

people wishing to build their own homes); and

• Caters for housing demand and the scale of housing supply necessary to meet this

demand."

3.1.3 Key points that are worth noting from the above is that the objective assessment should identify the full

need for housing before the Council consider undertaking any process of assessing the ability to

deliver this figure. In addition, §159 specifically relates to catering for both housing need and housing

demand within the authority area. It is worth pointing out that any assessment of housing need and

demand within a SHMA must also consider the following factors; falling household formation rates, net

inward migration, the need to address the under provision of housing from the previous local plan

period, the results of the Census 2011, housing vacancy rates including the need to factor in a 3%

housing vacancy rate for churn in the housing market, economic factors to ensure that the economic

forecasts for an area are supported by sufficient housing to deliver economic growth, off-setting a

falling working age population by providing enough housing to ensure retiring workers can be replaced

by incoming residents, addressing affordability and delivering the full need for affordable housing in an

area.

3.1.4 The need to identify the full OAN before considering any issues with the ability of a Local Planning

Authority to accommodate that level of development has been confirmed in the High Court. Most

notably in Solihull Metropolitan Borough Council v (!) Gallagher Homes Limited (2) Lioncourt Homes

Limited where it was considered that arriving at a housing requirement was a two stage process and


9

that first the unconstrained OAN must be arrived at. In thejudgement it was stated:

"The NPPF indeed effected a radical change. It consisted in the two-step approach

which paragraph 47 enjoined. The previous policy's methodology was essentially the

striking of

a balance. By contrast paragraph 47 required the OAN [objectively assessed need] to be

made first, and to be given effect in the Local Plan save only to the extent that that would

be inconsistent with other NPPF policies... The two-step approach is by no means

barren or technical. It means that housing need is clearly and cleanly ascertained. And

as the judge said at paragraph 94, "Here, numbers matter; because the larger the need,

the more pressure will or might be applied to infringe on other inconsistent policies".

3.1.5 Therefore following the exercise to identify the full OAN for housing in an area,

"Local planning authorities should seek opportunities to achieve each of the economic,

social and environmental dimensions ofsustainable development, and net gains across

all three. Significant adverse impacts on any of these dimensions should be avoided

and, wherever possible, alternative options which reduce or eliminate such impacts

should be pursued. Where adverse impacts are unavoidable, measures to mitigate the

impact should be considered. Where adequate mitigation measures are not possible,

compensatory measures may be appropriate." (NPPF §152)

3.1.6 This statement clearly sets out that local planning authorities should seek to deliver the full OAN and

that this should be tested through the evidence base. Only where the evidence shows that this is not

achievable should they then test other options to see if any significant adverse impacts could be

reduced or eliminated by pursuing these options. If this is not possible then they should test if the

significant adverse impacts could be mitigated and where this is not possible, where compensatory

measures may be appropriate.

3.1.7 The final stage of the process is outlined in §14 and involves a planning judgement as to whether,

following all of the stages of the process outlined above,

"Local Plans should meet OAN, with sufficient flexibility to adapt to rapid change, unless:

• any adverse impacts of doing so would significantly and demonstrably outweigh

the benefits, when assessed against the policies in this framework taken as a

whole; or

• specific policies in this Framework indicate developmen t should be restricted."

3.1.8 It is also worth noting that the final part of this sentence refers to footnote 9 of the Framework which

sets out the types of policies that the Government consider to be restrictive. These include:

"sites protected under the Birds and Habitat Directive (see paragraph 119) and/or

designated as Sites of Special Scientific Interest; land designated as Green Belt, Local

Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a


10

National Park

(or the Broads Authority); designated heritage assets; and locations at risk of flooding or

coastal erosion".

3.1.9 Although this list is not exhaustive it is clear that local landscape designations, intrinsic value of the

countryside, the character of areas, green gaps etc. are not specifically mentioned as constraints by

the Framework.

3.1.10 The PPG contains guidance to support local authorities in objectively assessing and evidencing

development needs for housing (both market and affordable) and economic development. This

document supports and provides further guidance on the process of undertaking such assessments, in

addition to what is set out in the Framework.

3.2 Coventry and Warwickshire SHMA

3.2.1 The Coventry and Warwickshire SHMA Update September 2015 identifies a total housing need of

85,440 dwellings equating to an annual average of 4,272 dwellings across the HMA. This study

identifies Coventry's housing needs as 2,120 dwellings per annum based on a demographic need of

2,099 dwellings per annum and a further 21 dwellings per annum to improve affordability. Gladman are

concerned that the adjustment of 21 dwellings per annum to improve affordability will not be sufficient to

meet the City's affordable housing needs given the clear evidence of affordability problems in the City. A

recent appeal decision2 demonstrates that a minor upward adjustment does not justify making a very

limited adjustment to the supply. In this decision the Inspector found that if this approach were followed

more widely, then the broader issues regarding affordability would remain unresolved. In light of the

above we consider greater consideration to need for market signals adjustment is required.

3.2.2 The Economic Prosperity Board on 6th July 2015 agreed to a process and timetable to develop a MoU

to ensure that the Coventry and Warwickshire HMA's housing needs is met in full. The Moll sets out how

the significant unmet housing needs arising from Coventry will be delivered across the HMA.

3.2.3 Gladman are concerned that the September 2015 OAN update does not represent the full objectively

assessed housing needs of the HMA. To fully accommodate forecast (policy off) economic growth and

to address worsening market signals across the HMA a further uplift to the OAN is required. The Barton

Willmore assessment of the HMA's full OAN continues to demonstrate a housing need of at least 5,000

dwellings per annum is required to be delivered across the HMA. Gladman consider that this figure

provides a more accurate assessment of the HMA's full housing needs and it should be this figure that the

Council should use to ensure its housing needs are met in full.

3.3 Affordable Housing

3.3.1 The PPG makes clear that the total amount of affordable housing that is required should be considered

in the context of its likely delivery as a proportion of mixed market and affordable housing

developments. Given the probable percentage of affordable housing to be delivered by market housing

led developments, an increase in the total housing figures included in the Local Plan should be

considered where it could help deliver the required number of affordable homes3. It is therefore clear

2 Appeal Reference: APP/B3030w153006252 3 Housing and Economic Development Needs Assessment Chapter PPG: Reference ID 2a-09-20140306


11

that where adverse market signals are apparent then there is an absolute and clear direction that an

upward adjustment to the housing numbers is required.

3.3.2 Gladman take this opportunity to make the Council aware of the recent Examination of the Canterbury

Local Plan, where an Inspector has applied a 20% uplift for Market Signals in line with evidence

prepared for the Council by NLP. It is our view that uplifts of this magnitude to the OAN

are the very minimum required in order to address the HMA's housing needs and address the

affordability crisis.

3.3.3 Gladman further note the recent High Court Judgement on a Judicial Review made on behalf of

Satnam Land Holdings against the adoption of the Warrington Local Plan4. This challenge succeeded

on two grounds; firstly that the assessment of housing needs had neglected to take account the

substantial need for affordable housing; and secondly that there had been substantial non-compliance

with SEA requirements. This judgment therefore ruled that the housing policies contained in the plan

were not sound and has resulted in further work being undertaken by the Council to meet its housing

needs.

4 COVENTRY LOCAL PLAN POLICIES

4.1 Context

4.1.1 This section of the representations are made in response to the policies that are currently being

promoted by the Council in the submission version of the CLP.

4.2 Policy DS1: Overall Development Needs

4.2.1 Policy DS1 sets out the overall development needs for Coventry City Council and seeks to deliver

24,600 additional homes i.e. 1,230 dwellings per annum. It is noted that the Council's full OAN for

the period 2011 to 2031 is 42,400 additional homes. The Council is not able to deliver this additional

land within the city boundary and therefore the unmet housing needs for the City will be delivered

across the Coventry and Warwickshire HMA.

4.2.2 Gladman reiterate the concerns highlighted within section 3.2 of these representations and the

flaws in the Council's housing needs evidence undertaken by GL Hearn. Gladman are of the view

that the housing needs for the HMA as a whole is significantly higher than what is being targeted

by the HMA. Whilst we support the Council's approach to identifying suitable and sustainable sites to be

released from the Green Belt to meet the City's housing needs, we are of the view that the Council has not

properly established its OAN which has therefore impacted on the housing requirement and what level

of growth should be accommodated elsewhere across the HMA.

4.2.3 In considering the overall numbers for the housing target of 24,600 dwellings the Council is heavily

reliant on a capacity based approach which identifies a shortfall of 17,800 dwellings across the plan

period. Whilst we acknowledged that the Council is affected by national designations notably Green

Belt and a tightly confined administrative boundary, should the OAN point to a significantly higher level

of need then there needs to be a clear direction of what level of growth each of the authorities within

4 Satnam Millennium Ltd v Warrington Borough Council [2015] EWHC 370


12

the HMA will need to accommodate in order to meet the HMA full housing needs.

4.3 Policy DS2: The Duty to Cooperate

4.3.1 As discussed in Section 2.1 of these representations, the DtC requires local planning authorities to

engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-

boundary strategic issues, such as unmet housing needs.

4.3.2 Policy DS2 states that CCC will work with neighbouring authorities within the HMA to support the

delivery of the development needs identified in Policy DS1 that originate from the city and will support

the preparation ofjoint strategic evidence to enable the successful delivery of regeneration and

economic growth across the sub region.

4.3.3 Whilst Gladman support the principle of this policy there is guarantee that it will ensure unmet housing

needs will be delivered. The pre-submission Nuneaton and Bedworth Local Plan as currently proposed

makes no allowance for the unmet needs arising from Coventry and therefore the full OAN for the

Coventry and Warwickshire HMA will not be delivered. It is therefore necessary to amend this policy to

ensure that effective cooperation continues between the Council and the neighbouring authorities

comprising of the HMA in order to sustain joint working arrangements. Gladman submit that this policy

needs to include a clear commitment across the HMA with concrete actions and outcomes should the

level of unmet housing need be significantly higher as outlined in section 3.2 or should a local planning

authority be unable to accommodate their proportion of Coventry's unmet housing needs (i.e. Nuneaton

and Bedworth Borough Council). This flexibility should show how this shortfall will be distributed

elsewhere within the HMA.

4.4 Policy H1: Housing Land Requirements

4.4.1 Policy H1 seeks to deliver a minimum of 24,600 additional dwellings between 2011 and 2031. T his

policy seeks to implement a phased housing requirement, in the first 5 years of the plan (2011 -2016)

the Council will seek to deliver 1,020 dwellings per annum and 1,300 dwellings per annum for the

remaining 15 years.

4.4.2 Gladman approve of the Council's decision to ensure that its housing requirement is considered as a

minimum. However, we do not support the Council's intention to apply a phased housing requirement

over the plan period. The result of this policy will act to restrict the delivery of

sustainable growth opportunities as a means to artificially reduce the Council's housing land supply.

The Framework makes clear its intention to significantly boost the supply of housing. This strategy is

further underlined by the buffers applied by §47 of the Framework, and the guidance contained in the

PPG that requires local authorities to meet its housing backlog within a five year period.

4.4.3 The CLP lacks robustjustification for the implementation of a policy which would act to 'backload' the

housing land supply and consequently reduce the Council's five year housing land supply. In

order to meet the tests of soundness Gladman submit that the Council should apply a flat annual

delivery rate rather than seeking to apply a stepped housing trajectory to ensure its housing needs are

met in full.


13

4.5 Policy H2: Housing Allocations

4.5.1 Gladman support the Council's decision to release land from the Green Belt to meet some of its identified

housing needs and particularly approve of the Council's decision to allocate H2:3 for residential development

given Rugby's commitment (at this time) to meet its share of Coventry's

unmet needs as an extension of this allocation within Rugby Borough's administrative boundary.

4.5.2 It should be noted that Policy H2 allocates a total 10,060 dwellings. This differs from table 4.1 which

states that the proposed Site Allocations (Local Plan) will deliver approximately 8,915 dwellings.

Further clarification on this matter is therefore required as the Council have stated that the figures in

table 4.1 inform the housing trajectory and where there is conflict, the figures in table 4.1 should be

used as this reflects on-going monitoring.

4.5.3 Gladman take this opportunity to stress the importance of applying realistic build out rates in the

housing trajectory going forward. It is noted that at present the housing trajectory contained at appendix

1 only applies the projected plan allocations and completions collectively over the plan period instead

of applying delivery assumptions for individual sites. It would be useful if the annual delivery data was

made available ahead of the Examination. Gladman therefore take this opportunity to stress the

importance of applying realistic build out rates in the housing trajectory going forward. If the Council

apply unrealistic delivery assumptions this will likely jeopardise the soundness of the plan and a

housing shortfall will soon arise.

4.5.4 Whilst the delivery of SUEs will enable the Council to deliver significant housing numbers and

numerous benefits associated with their delivery of these schemes i.e. public open space, new or

improved services and facilities etc. such schemes may not deliver at the anticipated rate or time scale

envisaged as a result of infrastructure requirements, long lead in times and extensive master planning

and negotiations between landowners. Gladman therefore suggest that a realistic annual delivery rate

is roughly 30 dwellings per annum, with one developer on site. Delivery would increase with multiple

outlets on sites, however there is unlikely to be more than three developers on site at any one time

(due to the increased competition) bringing the maximum annual delivery rate to in the region of 90

dwellings.

4.6 Policy H4: Securing a Mix of Housing

4.6.1 Policy H4 seeks to ensure a mix of housing in line with the latest Strategic Housing Market

Assessment. In assessing the housing mix in residential schemes Policy H4 allows the Council to take

into account circumstances where it may not be appropriate to provide the full range of housing types

and sizes in accordance with the latest Strategic Housing Market Assessment. In this regard, Gladman

does not approve of criteria (e) which enables the Council to take account a parish or neighbourhood

plan area assessment of local housing needs.

4.6.2 The reliance on such documents are unlikely to provide a robust and up-to-date piece of evidence that

would justify departure from the Strategic Housing Market Assessment, further there is no requirement

for neighbourhood plans or parish councils to prepare such evidence of local housing needs.


14

4.7 Policy H6: Affordable Housing

4.7.1 Policy H6 requires all residential schemes of 25 dwellings or more, or more than 1 ha, will provide 25%

of the total development proposed as affordable housing. The Council acknowledge an affordable

housing shortfall of approximately 1,150 dwellings over the last four years. Given the significant

shortfall that has already accumulated Gladman reiterate the comments made in response to section

3.3 of these representations and the need to increase the level of market housing led development in

the total housing figures included in the CLP to help deliver the required number of affordable homes. If

this cannot be achieved within the City then this should be accommodated within the wider HMA.

4.7.2 Further Policy H6 needs to be amended and include the wording 'subject to viability' to ensure that

it complies with §173 of the Framework so that it takes account of the normal cost of development and

mitigation and does not prevent the delivery of sustainable development proposals from stalling.

5 CONCLUSION

5.1 Summary

5.1.1 In order to meet the tests of soundness contained at §182 of the Framework, the emerging Local Plan

must be found to be positively prepared, effective, justified and consistent with national planning policy.

The Council must ensure that its housing requirement is based on a Framework and PPG compliant

assessment of housing needs by developing an unconstrained housing need figure which takes full

consideration of economic needs and market signals uplift.

5.1.2 It is evident that the Council are unable to meet its housing needs without releasing land from the

Green Belt due to the limited availability of available brownfield sites. Gladman approve of the

Council's decision to review its Green Belt boundaries and identifying a number of suitable and

sustainably located sites to meet a proportion of its housing needs.

5.1.3 In order for the Council to boost significantly the supply of housing and to meet its housing needs in full,

it is recognised that the Council is seeking to deliver its housing shortfall across the Coventry and

Warwickshire HMA. Effective discussions with neighbouring authorities on cross boundary issues, such

as significant unmet housing needs need to continue. It is still unknown what role Nuneaton and

Bedworth Borough Council will play in meeting Coventry's unmet needs and whether the GL Hearn

assessment provides an appropriate basis to plan for the City's housing needs.

5.1.4 The Council has made a positive approach to meeting a proportion of its housing needs. However, we

are of the view that the full OAN for the district is likely to be higher and therefore discussions

with the Coventry and Warwickshire HMA should be undertaken to ensure the Council's unmet

housing needs are met in full.

Officer Comments

General

• The C&W HMA continue to work very closely with the GBS HMA, indeed a degree of the GBS

HMA shortfall is already being planned for in SADC and acknowledged as requiring planning for

in NWBC. This is not an issue for CCC at this time. This is, in part at least, dealt with the through

the C&W MOU in housing requirements.

• The papers that support the MOU sEPB meeting included an initial high level SA type approach.

Notwithstanding the key time to consider the SA/SEA impacts of the redistribution is through the

planning of respective plans. It is not the role of CCC to SA/SEA the housing requirements or

capacity of its neighbouring authorities and vice versa. The CCC SA/SEA has considered

different housing capacities and requirements.

Policy DS1 - the Local Plan is founded on a robust assessment of OAN based on the most up to date

data from the ONS. It has been produced on a consistent platform for the HMA as a whole. The

council consider its OAN to be robust.

Policy DS2 - NBBC have already committed to reviewing their plan pre-submission to deal with the

Coventry overspill. The MOU includes an agreed review mechanism should NBBC not be able to

accommodate their identified contribution. In the context of the DTC and local plan preparation this is

considered a robust approach and a solid commitment to on-going cooperation and support.

Policy H1 - the phased approach reflects the short term constraints on housing land availability in CCC

and across the HMA as a whole. Green Belt is a recognised policy constraint that can only be released

through local plan making. Only once this plan is adopted can the Council look to significantly increase

the supply of housing land.

Policy H2 - the difference in figures in H2 and 4.1 are identified and flagged in the table. They reflect

the fact that some of the allocations are already benefiting from planning permission and are so

covered within a different row of the table. More individualised and indicative build out rates are shown

in the SHLAA appendices

Policy H4 - we know from our previous SHMA work in Coventry that sub-markets exist across the city.

If neighbourhood plans were to be produced that are founded on a more up to date evidence base and

more locally reflective than the strategic facing SHMA then the Council feel that this should reasonably

be considered as a material consideration in decision making.

Policy H6 - the local plan clearly sets out how affordable needs will be met over the plan period. Policy

H6 and its supporting text are clear that viability issues will be considered through the decision making

process.


Representation ID Number: 351 (policy DS1), 352 (policy DS2), 353 (policy H1), 354 (policy H2), 355

(policyDS3), 356 (policies EM1, EM2 and EM6)

Representor Name: Mr Chris May

Company: Pegasus Planning Group obo Lioncourt Homes

Officer Comments

Policy DS1

The OAN for Coventry has been informed by the 2015 update of the Coventry and Warwickshire

Joint SHMA. This includes figures for both Warwick and Stratford Districts. Indeed the work as

completed following recommendations at the initial Warwick hearings. The slight difference with

the Stratford EIP figures relate to a view on 10 year migration trends relative to 5 year trends and

the alignment of different studies that have considered purely 2012 based data and the 2012

based information updated by 2013 and 2014 midyear estimates (as has been utilised in the

JSHMA). The principle difference is to focus greater growth on Coventry.

In terms of the SHLAA, the city council have a proud track record of brownfield delivery and

urban regeneration. All sites in the SHLAA have been assessed and identified as being

developable over the plan period. The Council believe this offers a robust assessment of its

urban capacity.

Policy DS2

The information that supports the MOU is available alongside the report that was presented to

the Shadow Economic Prosperity Board in September 2015. Although the copy of the report

available does not contain signatures, the report has been formally endorsed by each council

(accept NBBC) through their respective council processes. This offers the MOU a strong degree

of weight.

Policy H1

The approach is included to continue promoting brownfield delivery and urban regeneration

whilst also recognising the importance of greenfield sites coming on line to deliver the city's

housing needs. The trigger is a monitoring trigger which will be used and considered as part of

SHLAA reviews and annual monitoring reports. The additional document referred to is also

mentioned elsewhere in the Plan as well as the updated LDS.

Policy H2 Comment noted

Policy DS3

The policy is considered to be in accordance with the NPPF and promotes sustainable

development across Coventry.

Policies EM1, EM2 and EM6

The policies have been drafted in a flexible and aspirational way to ensure the plan is able to

respond to changing environmental standards whilst continuing to seek better quality

development wherever possible and desirable.

The SPD reference din part 4 of EM2 commits to an update of an existing SPD, until such time

as the update is complete this SPD will continue to be of consideration.

Representor Link Number: 1011 Representation ID Number: 320 (Policy H2) Name: Mitchell Reid

To whom it may concern

RE: Eastern Green masterplan

Following my conversation with Chris Berry we would like to put forward our land (edged in red

on the plan) to be taken out of the green belt category and to form part of the plans going through

consultation for the development of green belt sites in Eastern Green. The first preference would

be for the whole site to be taken out of green belt status and be used for development. If this is

not possible then potentially a smaller development to the land along Pickford green lane (west)

removed from green belt status, so that a development of houses facing Pickford green lane to the

new development could be built and also clearing the existing buildings at church lane and

develop that site for housing (in the style of the most recent poachers pub development on

hockley lane and potentially facilities for the school such as parking as we are directly opposite.

If someone would like to come to site and review the options or advise of anything that may be

suitable we would appreciate that.

Look forward to your response

Yours faithfully

Mitchell Reid

Sent from my iPhone

Officer Comments

Policy H2

Likely to constitute urban sprawl and impact on wider Green Belt and Meriden Gap, particularly to the city’s western boundary.

representor link number: 1048 representation id number ... · document (dpd) mr “ publication...

Documents