Issue and Options 2023

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Infrastructure requirements should be set out as fully as possible in the Part 1 Plan. One of the challenges faced by strategic development such as that being pursued at Coventry Airport is the uncertainty associated with the provision and funding of infrastructure required directly to support it, or required in part to support it, or which might in fact be associated more properly with a range of other proposals but nonetheless becomes drawn in to the consideration of major schemes. Clarity is required at the outset so that strategic development of the type envisaged by the Part 1 Plan can be brought forward with confidence and in an informed manner, whilst also ensuring that later proposals dealt with at the Part 2 stage can be delivered seamlessly and without being over or under burdened by infrastructure requirements. In circumstances where a zoned approach to CIL is possible in a single levy the benefit of having separate levies is perhaps marginal. However, it would more easily allow for differences in local conditions, which vary greatly within and between the two Districts, to be reflected in the approach to charging, and for the approach to charging to adapt more swiftly as circumstances change.

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The Issues and Options Consultation does not offer a specific opportunity to comment on issues around brownfield land. However, the Urban Capacity Study speaks to this issue and is considered in the section of the Issues and Options relating to the use of brownfield land and so these comments (which relate to brownfield development rather than the Urban Capacity Study per se) are presented here. The Issues and Options refers (page 40) to the fact that small parcels of brownfield land are most commonly found within existing built-up areas but also that, “sometimes large areas of rural brownfield land, such as airfields in the countryside, can become available.” In South Warwickshire it is also the case that a large area of brownfield land has become available immediately adjacent to the southern edge of Coventry, in the form of Coventry Airport. It is in a highly sustainable location, well integrated with the rest of the City, and presents an opportunity that is unique in South Warwickshire (indeed regionally) in terms of its ability to accommodate large scale development on previously developed land effectively as part of the urban area. It represents a development opportunity of strategic importance, and that should be recognised and promoted throughout the Plan. On a related matter, the Issues and Options Consultation similarly does not offer a specific opportunity to comment on issues connected with the Green Belt. This is understandable in circumstances where the technical work around Green Belt review has not yet been undertaken, and so the Issues and Options are blind to this matter. The Issues and Options give a clear indication that such work will be undertaken, and this is essential. It is of particular relevance to the Airport which remains, as an anomaly, within the Green Belt. The current Warwick Local Plan created a situation where the Airport was left as a residual finger of previously developed Green Belt land surrounded on three sides by existing or allocated development and performing no useful Green Belt function. The recent grant of planning permission here for a Gigafactory demonstrates how the Airport as a whole can successfully and sensitively be developed and make an important contribution to meeting development needs in South Warwickshire and indeed the wider region. Any Green Belt review should consider the Airport carefully, with the logical outcome being that it is removed from the Green Belt.

Inappropriate strategy

Inappropriate strategy

Appropriate strategy

Appropriate strategy

Inappropriate strategy

It is not clear how in the Spatial Growth Options the Existing Major Investment Sites are to be treated, how they have been considered in the formulation of the Growth Options, or what the implications will be of the continued advancement of those Sites for the Growth Options. As the preparation of the Plan progresses it will be essential to ensure that the selected Growth Option integrates properly with the significant role the Existing Major Investment Sites should be expected to play and to ensure there is consistency, including with other initiatives such as the Core Opportunity Area. Some disconnect in this regard is suggested later in the Issues and Options (page 89) in the discussion of the Major Investment Site South of Coventry. It is suggested that much of the land here without planning permission is in the Green Belt, and that growth in this area would need to understand this and the preferred option for growth. This appears to imply an existing and successful Major Investment Site being responsive to a yet to be decided growth strategy. It should instead be the case that the growth strategy reflects the potential and encourages the growth of this Major Investment Site, and the others. It might also be noted in this regard that a large part of the land in the South of Coventry Area with planning permission, at the Airport, is also within the Green Belt. As discussed elsewhere in these representations this is an anomaly. The Airport should be taken out of the Green Belt so that its full sustainable development potential can be realised.

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The HEDNA adopts an approach which triangulates different forecasting techniques. This immediately gives rise to a note of caution. Each forecasting technique is based on a particular rationale, with a logical basis for how results are to be generated. Moving to some position between techniques means that the outcome does not reflect any particular rationale or have a robust methodological integrity. The HEDNA includes assumptions which are not justified. For example, reference is made (paragraph 9.32) to sensitivity modelling with a 30% reduction in office needs to reflect home working. There is of course evidence of increased demand for home working reflected in a reduced requirement for office space, but the selection of 30% is not explained. It might be informed by data of the kind presented in Figure 9.1, but that would rely on a comparison between rates of working from home pre-pandemic (which would already be “baked in” to floorspace requirements) and those experienced and expected post pandemic. That exercise appears not to have been completed; it is certainly not reported. Equally, the use of an arbitrary division between non-strategic and strategic provision at 9,000 sq m is not justified in the report. This figure has been used in other settings and is referred to in the HEDNA as a “recognised definition” but its continued use without a clear explanation of why this value is selected and the implications of segmenting the market in this way in the analysis is inappropriate. At the very least it implies a division in the market that is not reflected in the real world, and that should be acknowledged or there is a risk of HEDNA results being misapplied when they are translated into policy and allocations. The reliance placed on past trends of floorspace and completions growth is flawed. Past growth does not reflect future need – it reflects what a planning constrained market was able to deliver in the past. Relying on it will act to perpetuate past failures fully to meet the requirement for employment land. Moreover, whilst some flexibility (a 5 year margin) is allowed for in calculating strategic warehousing need this is to support a choice of sites and allow for unforeseen delays, not to make up for past under delivery. An allowance must be included to make good pent up, unsatisfied, demand. Such pent up or “suppressed” demand that might have accrued over an extended period should be fully accounted for in any analysis of the requirement for employment land that is to be relied on in the emerging Plan. This should include land for industrial as well as logistics activity. It is often the case that employment land supply fails to keep up with demand, and economic growth, investment and job creation that would have taken place were this not the case is frustrated, delayed or lost. As such, there are real-world consequences in failing to grapple with the point. Where a shortfall arises and accrues it should be made good through planned for provision. Pent up demand may be accounted for in conventional studies by making a nominal allowance for flexibility in the stated requirement (although that does not appear to be the case here) and expressing that requirement as a minimum. However, such an approach does not properly, directly or accurately engage with and measure the issue. That “flexibility” or margin is additionally included to make an allowance for other considerations such as delays in delivery, or a buffer to account for uncertainties in forecasting. However, the extent to which the flexibility allowance in the HEDNA accounts sufficiently and accurately for these multiple purposes is not known, and it appears to make no attempt to account for suppressed demand. The uncertainty in this regard should be reduced by assessing properly suppressed demand and accounting for it in policy decisions in the emerging Plan. Such an exercise needs to be completed for South Warwickshire. The results from the HEDNA do not accommodate this issue and cannot be relied upon. Notwithstanding these shortcomings, the commentary in the HEDNA about the continued potential for established growth corridors to accommodate strategic B8 growth is supported. As recognised by the HEDNA the A45 / M45 is one such corridor with a continuing key role in this regard.

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