Issue and Options 2023

2. The Site and the Opportunity 2.1 The Site is located within the administrative boundary of WDC on the border with Coventry City Council (CCC), which is formed by Westwood Heath Road. 2.2 The Site is situated immediately to the south of Westwood Heath Road, to the north of Westwood Heath Road is the Network Rail Training Centre and an existing residential area, beyond which is Westwood Business Park. 2.3 To the west is Bockenden Road (which becomes Crackley Lane and links to Kenilworth), beyond which is housing allocation H42 ‘Westwood Heath’ which is subject of a hybrid Planning Permission (W/17/2357) dated October 2018 for a total of 425 dwellings, a convenience store of up to 400m2 and associated infrastructure. The first phase of development (129 dwellings) formed the detailed aspect of that application, which Crest have now commenced. This was followed by the submission of a reserved matters application (ref. W/21/1280) in July 2021 for details of appearance, landscaping, layout and scale for the remaining phases 2, 3 and 4 (296 dwellings), which is currently awaiting determination. 2.4 Further west is the settlement of Burton Green, which has residential properties along Cromwell Lane. To the south is open countryside and the former railway line along which HS2 is to be constructed. To the east is open countryside, allotments, playing fields and further east, the University of Warwick campus. Background The Site and safeguarded land 2.5 The Site forms part of a wider area removed from the Green Belt and ‘safeguarded’ by Policy DS21 and allocation S1 (land south of Westwood Heath Road) in the adopted WDC Local Plan (September 2017). 2.6 Policy DS20 ‘Directions for Growth South of Coventry’ states that: “The area to which this policy relates will be subject to an early partial local plan review within five years of the date of adoption of the plan. This will allow the Council to address any additional evidence regarding the need and potential for development in this area and in particular to ascertain whether necessary infrastructure has become available to allow safeguarded land to be brought forward to meet local housing need, should additional housing be required.” 2.7 Appendix B “Vision for the Land South of Coventry” of the WDC Local Plan (2017) stated: “This area will be a thriving, available and sustainable driver for economic growth, based around its excellent links to the strategic highways network, represented by a new link road from the A46 around the southern edge of the city, improved rail and other public transport connections serving the University of Warwick and the provision of significant opportunities for cycling and walking through and between the new areas of growth” 2.8 Specifically of relevance to any future housing development in this area, the vision states: “New housing developments will have created flourishing communities with their own individual characters, catering to residents throughout their lives and providing a range of attractive and well-designed properties. Residential development improves the quality of life of its inhabitants. It offers healthy and high quality living environments and provides a balanced mix of housing, community facilities, services and employment opportunities that have created a viable and sustainable community. Public perceptions of well-being and security are high, with residential areas designed to promote the safety of pedestrians, cyclists and residents of all ages and degrees of physical capacity. Layouts have been designed to be easily accessible to emergency services and incorporate high degrees of natural surveillance. Development respects and reflects a high quality natural environment. The landscape and biodiversity value of the area has been enhanced and protected, with precious woodland forming the heart of a system of conjoined and interlocking wildlife and habitat links bringing the countryside into the urban fringe. New habitats have been created and where existing resources were impacted by development, they have been replaced locally. Access to the natural environment is easily and safely available, with the provision of parks, informal open space, play areas, leisure and sporting facilities an integral aspect of all forms of development.” 2.9 The Site is removed from the Green Belt and safeguarded, with the future allocation to be made in the context of the review of the Local Plan. 2.10 It is considered that the suitability of the Site for residential development has already been tested through the due process followed through the examination of the adopted WDC Local Plan (2017). We are envisaging that the Site will come forward for allocation within the South Warwickshire Local Plan (SWLP). 2.11 It is important to note that the Issues and Options document does not refer to the safeguarded land previously identified in the adopted WDC Local Plan. However, the table at Chapter 12 confirms that Policy DS21 “Safeguarded Land” will be addressed in the Part 1 plan due to it being considered a strategic policy for the SWLP. We discuss this further in section 3 of these representations. South Coventry Masterplan 2.12 At WDC’s Cabinet Meeting on 20 April 2022, Members agreed to the Council progressing the masterplanning work, alongside key partner organisations (CCC, WCC, and University of Warwick), for the area to the north of the District and immediately to the south of Coventry, the plan enclosed at Appendix 2 demonstrates the extent of the masterplan area. The South Coventry Masterplan would effectively see HS2 become the new Green Belt boundary. 2.13 The purpose of the masterplanning process will be kept under review by all the participants. However, as set out in the report to Cabinet, officers expect that it will continue to perform an important role as follows: • To map and understand the various planned and emerging developments in the area; • To explore how to maximise community benefits including through improvements to green and blue infrastructure and connectivity; • To assist partner organisations in preparing their own masterplans for specific sites and to reflect their aspirations in the wider planning of the area; • To understand how the climate emergencies declared by WDC, Warwickshire County Council (WCC), the West Midlands Combined Authority and the University of Warwick should inform the future planning of this area; • To provide a focus for considering how best to engage with HS2 in terms of how this project can bring improvements to the area (including by linking with the HS2 Context Integration Study); • To provide a context for considering travel and transport improvements in the area, which should prioritise active and sustainable travel but also consider the purpose, justification and business case for the A46 Strategic Link Road; • To provide a framework and rationale for future business cases and bids to deliver transport infrastructure projects (e.g., road, VLR, South of Coventry/University of Warwick Railway Station);and • To enable, subject to wider work on growth options across South Warwickshire and any agreement within the SWLP as to the development strategy, consideration of whether, where and how this area may be suitable for further growth as part of the Local Plan. 2.14 Given that the Site forms part of the wider masterplan area IM Land support this exercise and have confirmed that they would be willing to partake in any discussions at a suitable stage. 2.15 The ongoing masterplanning work is a clear indication that growth to the south of Coventry is supported by the Councils. Furthermore, IM Land have prepared a Wider Masterplan working with CEG to illustrate how the safeguarded land at Westwood Heath can be delivered as an allocation as part of the South Coventry Masterplan proposals, which is included within the Vision Document at Appendix 3 of these representations. We will continue to work with WDC and WCC, taking an active role as this workstream progresses. A46 Strategic Link Road – Engagement with WCC 2.16 As described above, part of Policy DS20 (Directions for Growth South of Coventry) refers to “proposals should take account of the potential for a new link road, which has been identified as an important means of mitigating increased traffic flows on the local and strategic road network; increasing existing strategic highway capacity; and providing an improved future strategic highway link to UK Central”. It also features in the Vision for land south of Coventry in Appendix B of the adopted Local Plan. 2.17 The A46 Strategic Link Road is being promoted by WCC along with CCC; WDC; Coventry and Warwickshire Local Enterprise Partnership; and, Department for Transport (DfT). 2.18 The Strategic Link Road aims to improve accessibility to the University of Warwick and the surrounding Business Parks and other employment areas through the provision of a new road linking the A46 at Stoneleigh Junction with Westwood Heath. It will also help reduce the inappropriate use of minor roads such as Crackley Lane for traffic wishing to access the University and surrounding area. 2.19 WCC previously consulted on the three main options for the Strategic Link Road from 30 November 2020 to 14 February 2021. Turley submitted representations on behalf of IM to this consultation setting out concerns that the three potential options for access onto Westwood Heath Road were all located on the Site – rather than being dispersed across the wider frontage of Westwood Heath Road. A copy of these representations is enclosed at Appendix 4. 2.20 Since submission of representations in February 2021, IM and CEG, have been in discussions to agree the most appropriate access point for the link road onto the Westwood Heath Road. he current iteration of this is shown on the Wider Masterplan within the Vision Document (Appendix 3). This plan has been shared with WDC and WCC. 2.21 The responses to the A46 Strategic Link Road consultation were analysed and considered at WCC’s Cabinet on 14 October 2021. The Cabinet report confirmed that feasibility works were ongoing and an Outline Business Case for the scheme was being compiled for submission to the DfT, which would make the case for the scheme and request continued support from the Government. 2.22 The Outline Business case was originally intended for submission to the DfT in Autumn 2021. However, CCC and WCC, in full consultation with Warwick and Stratford District Councils, took the decision to defer the application for the DfT’s Major Road Network (MRM) / Large Local Major (LLM) programme funding by two years. We understand that the Councils consider that a future MRN / LLM funding submission will feature the submission of a business case for investment in a wider transport package of measures, including the A46 Link Road as appropriate. It is anticipated that the South Coventry Masterplan will incorporate the wider package of measures, and help support the future business case. The Opportunity 2.23 A Vision Document for the Site is enclosed at Appendix 3 of these representations, which demonstrates the Site’s ability to deliver new homes in a sustainable location, within the early stages of the plan period, independent of the wider safeguarded site and wholly aligned to the five pillars of the SWLP. 2.24 The latest concept masterplan for the Site, included within the Vision Document, provides the following key design principles and development benefits: • The proposed development comprises 3.7ha of residential development, amounting to approximately 130 dwellings at a density of 35 dwellings per hectare (dph). • The development incorporates an area for the potential 2FE primary school site located predominantly within the adjacent land to the south forming part of the wider site area. • The proposed development retains existing hedgerows along the north, west and east site boundaries and includes enhanced new public open space with new trees and landscape planting. New public open space within the development includes a central green space as well as a landscaped western green edge. This will aid social interaction and integration. In addition, this increases exposure to green spaces, enhancing health and wellbeing. • The sustainable urban drainage strategy on the Site incorporates a new attenuation pond in the south west corner at the low point of the Site. This will also add an attractive feature to the public open space in this area. • The development has been designed to be incorporated within the potential wider masterplan for the area, with potential to make appropriate connections and increase permeability and accessibility. • The development includes a clear hierarchy of roads to create a legible street pattern, to assist in way finding. • The Site will be planned comprehensively as part of the overall safeguarded area, which will include the new A46 Link Road route and an additional access to the Site from the south. • There will be a 10% Biodiversity Net Gain provided across the safeguarded wider site area which the Site will contribute to. Sustainability Credentials 2.25 The sustainability credentials of the Site and the proposed development have been assessed, with full details included within the Vision Document at Appendix 3, and the Site will assist with the following policy aspirations: • Climate emergency – The development will endeavour to meet the Climate Emergency Action Programme released by WDC following the Council’s pledge to become net zero carbon by 2030. • Future Homes Standard – The development will align, as appropriate, with the interim Future Homes Standard (FHS) requiring a 31% reduction in CO2 emissions over Part L 2013 or the full FHS from 2025 requiring homes to achieve a 75-80% reduction in CO2 emissions. • NPPF – The development will meet the objectives of the NPPF: ‒ Building a Strong and Competitive Economy; ‒ Promoting Sustainable Transport; ‒ Delivering a Wide Choice of High Quality Homes; ‒ Requiring Good Design; ‒ Promoting Healthy Communities; ‒ Meeting the Challenge of Climate Change; ‒ Conserving and Enhancing the Natural Environment; and ‒ Sustainable Waste Management • SWLP – The development will endeavour to: ‒ Increase accessibility and reduce private car travel; ‒ Increase energy efficiency; ‒ Support renewable energy use; ‒ Design for climate change mitigation and adaptation; ‒ Mitigate flood risk; and ‒ Mitigate biodiversity loss & maximise opportunities for enhancement.

Yes

3.2 IM agrees with and supports the overall vision and strategic objectives for the SWLP. In order to meet the ambitious vision set out in the Issues and Options document, it will be important to ensure growth is located in the most sustainable locations and aligns with the vision as closely as possible. 3.3 The priority for such growth should be those sites which were safeguarded in the adopted WDC Local Plan (2017). Such sites have been determined through large scale public consultation, and by an examination by an Inspector, to be suitable for development and removed from the Green Belt.

3.4 IM agree that the approach to the Sustainability Appraisal is reasonable at this stage of the proposal. However, there is now a need to progress with the wider evidence base to ensure that sufficient mitigation can be considered in the next round of the Sustainability Appraisal, which should in turn demonstrate which is the most appropriate growth option. With the absence of consideration of mitigation, the Sustainability Appraisal in its current form does not help identify the most appropriate options. 3.5 With regards to the Site, the findings of the Sustainability Appraisal prepared in support of the adopted WDC Local Plan (2017), which were supported and resulted in the allocation of the Site as a safeguarded site within the plan, should be recognised and referenced through the updated evidence-based documents.

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Question I2: Option I2b: Focus on the strategic infrastructure relating specifically to the growth strategy 3.6 IM agree that the Local Plan, where appropriate, should set out the requirements for strategic infrastructure where it specifically supports the growth strategy. However, it is important that the need for infrastructure identified within the Local Plan is fully supported by the underlying evidence-based documents. 3.7 The Site, along with others located to the south of Coventry (as part of the south Coventry Masterplan), can support the case of the proposed A46 Link Road (promoted by WDC, WCC and CCC). Furthermore, due to the overall quantum of development that could be delivered as a direct result of the proposed Link Road, any new homes within this area can assist in supporting the funding. The south Coventry Masterplan will also form part of the outline business case in support of the link road, which will need to be submitted to the Department for Transport (DfT). 3.8 It should however be noted that the delivery of the Site is not reliant upon the Link Road coming forward. The Site remains a sustainable location for development adjacent to existing urban areas, where facilities and connections are already available. The emerging proposal for the Site, enclosed with the Vision Document at Appendix 3, demonstrate how the Site can be delivered ahead of the Link Road whilst not impeding its future delivery.

Yes

3.10 The delivery of the A46 Link Road should be safeguarded within the SWLP to ensure that, where reasonable, sufficient funding from the delivery of new homes can help support the overall costs of the road. It is anticipated that the Business Case will be submitted and approved by the DfT ahead of the adoption of the SWLP, therefore the SWLP should make sufficient provisions to ensure this key piece of infrastructure is safeguarded. 3.11 The Site will bring forward a new internal road as part of the development proposals, to support the delivery of new homes at this Site. The internal road will be designed to ensure it could be extended to connect to the A46 Link Road to support its delivery, as well as enhancing permeability.

3.12 It should be ensured that any policies set out within the SLWP in relation to infrastructure do not undermine the viability of development proposals.

Yes

3.15 IM generally support the initial findings of the settlement analysis; however, it is considered that the analysis purely assesses the existing position. The maps for ‘South Coventry Westwood Heath Road’ at Appendix 3 of the Settlement Analysis confirm the following: • Connectivity: Demonstrates that the Site currently has Grade B connectivity, with Grade A being ‘best connectivity’ and Grade E being ‘poor connectivity’. This is due to the proximity of primary streets and existing footpaths. • Landform Analysis: The ‘South Coventry Westwood Heath Road Landform Analysis’ confirms that there are no flooding, green infrastructure or topography constraints in delivering the Site. • Density Analysis: The Density analysis confirms that the Site is immediately adjacent to an existing outer suburb (20-40 dph) and a business park, demonstrating that the development of the Site would align with the densities of the surrounding areas. 3.16 Through the masterplanning exercise set out in the Vision Document (at Appendix 3 of these representations) IM have demonstrated that there will be opportunities to enhance the connectivity scoring to Grade A once suitable mitigation has been applied. It is considered that ahead of the Preferred Options stage of the SWLP, the settlement analysis should be reviewed to consider the impact on new development – with mitigation applied.

Question S4.1 3.13 IM support the growth of existing settlements as part of the overall strategy. 3.14 The area to the south of Coventry was identified as a location for growth through the adopted WDC Local Plan (2017). Therefore, safeguarded sites in this location should be amongst the first to come forward within the SWLP. Further growth to the south of Coventry is clearly supported through WCC and WDC’s work to create a masterplan for this area.

Question S7.2: 3.17 In relation to the growth options, IM consider that it would reasonable and logical to consider a range of growth options, specifically due to the quantum of development that is required throughout the plan period. 3.18 The Site that is the subject of these representations logically falls within Option 2 (Sustainable Travel) and Option 3 (Economy). It is considered that locating development adjacent to existing urban areas can ensure that growth is focused on the most sustainable locations, where facilities and connections are already available. Furthermore, such developments can then come forward within the early stages of the local plan to ensure a pipeline of housing sites. 3.19 As set out in our response to question S10, below, The Site has previously been determined by an inspector to be suitable for future sustainable development through the examination of the adopted WDC Local Plan (Adopted 2017), and subsequently removed from the Green Belt and safeguarded for development. Therefore, to support the growth options set out above, land that has been previously safeguarded for development should receive allocations within the SWLP, to be brought forward within the early stages of the plan period.