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Proposed Modifications January 2016

Representation ID: 69629

Received: 22/04/2016

Respondent: Kenilworth Rugby FC, Kenilworths Wardens C&FC, The Hibbered Family & The McDaid Trustees

Agent: Framptons

Representation Summary:

Need for enhanced sporting facilities for KRFC has been demonstrated in previous submissions. Enhancements now sought, increased by proposals for enlarged resident population.
Local Plan allocations establish principle of change of use of land in the Green Belt for the enhancement and potential relocation of sports pitches, on land that is primarily allocated for residential development to meet wider public interest. Provision of 'appropriate facilities' is a matter that can be addressed within development management, pursuant to national planning policy.

Full text:

See attached
Question 7

1. The LPA is fully aware that the McDaide family, the Hibbert family and KFRC, who hold the controlling land interests for Allocation H06, have from the commencement of the Local Plan preparation promoted the release of the site and its development for residential-led mixed use development on a comprehensive basis. In response to the Inspector's interim conclusions, the LPA has identified as a separate policy allocation - Policy H40 - a further substantial release of land from the Green Belt - for a similarly residential - led mixed use development. Policy DS15 applies to the development of Strategic Sites and states at c):

'Thickthorn and sites allocated to the east of Kenilworth.'

2. One of the key purposes of a development plan is to provide guidance as to how development allocations are to be brought forward. The submissions of proposals for sites H06 and H40 are of a scale that the applicants for planning permission will need to demonstrate a comprehensive approach to a wide range of planning requirements, through the Design and Access Statement, parameters plan and possible Environmental Assessment. Such submissions reasonably can have regard to the principles of development that are identified in the Local Plan for the adjoining allocation, and the impacts upon infrastructure, for example through a Transport Assessment. However, as noted at Explanation paragraph 2.66, the land holdings are in 'multiple ownerships.' There is an agreed understanding between the parties of how the land allocation under H06 can be brought forward promptly, following the adoption of the Local Plan, releasing the land from the Green Belt.

3. The intimation at paragraph 2.66 is that all landowners should set up some form of 'consortia or other formal means of co-ordinating joint-working.' Experience demonstrates that such an arrangement for an extensive parcel of land - across two mixed-use allocations may lead to avoidable delays in bringing the two land allocations forward within the development management process. The landowners for Thickthorn (H06) can bring forward the landholding promptly in response to the release of the site from the Green Belt. The landowners have received many interests from housebuilders to take forward the allocation through the development management process and deliver new homes on this site.

4. Clearly, as two committed allocations, the bringing forward of either allocation would have to have regard to the development of others, most likely through environmental assessment. The Transport Assessment and other technical assessments would ordinarily have regard to the implications of intended development on adjoining land.

5. Paragraph 2.68 of the Explanation provides sufficient guidance to the developers of strategic sites - in this particular case - H06 and H20, that development of either needs to take account of the other. Comprehensive development can be achieved for each site, having regard to the development implications of adjoining allocation, without requiring a 'formal means of co-ordinated joint working.' Informal joint working, including full participation of the LPA can achieve a high quality and integrated development across the two allocations east of Kenilworth.

Question 8

6. Identify land at Thickthorn (H06) and land at Crewe Lane, Southcrest Farm, Woodside Training Centre (H40) separately under the list of strategic sites under Policy DS15.
Question 7

1. The representation on behalf of the McDaide Family; The Hibbert Family and KRFC is that Policy DSNEW 4 is sound and consistent with national planning policy in allocating land for a change of use in the Green Belt for the provision for outdoor sport.

2. There is a substantial requirement for the provision of enhanced sporting facilities to meet the needs of KRFC, as has been demonstrated in the past submissions to the LPA within the emerging local plan process. These enhancements are sought now, and are increased by the proposals for an enlarged resident population within Kenilworth. The allocations in the Local Plan effectively establish the principle of a change of use of land in the Green Belt for the purposes of providing an opportunity for the enhancement and potential relocation of sports pitches, on land that is primarily allocated for residential development to meet the wider public interest. Properly, the provision of 'appropriate facilities' is a matter that can be addressed within the development management function, pursuant to national planning policy set out in the Framework (89).