DS11 Allocated Housing Sites

Object

Representation ID: 65727

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Considers inclusion of Land West of Europa Way as a strategic growth area for residential development is justified.
The principle of including a mix of uses to the West of Europa Way is deemed appropriate including provision of a medical centre, primary school, local centre and the principle for the expansion of Myton School. However the Local Plan approach to the development of Community Facilities is not considered to be positively prepared, justified, effective or in accordance with national policy and WCC has concerns about the uncertainty as to the amount of land required for the expansion of Myton School.
The inclusion of 8ha of employment land to the West of Europa Way is not deemed appropriate in market, quantum and location terms.

Object

Representation ID: 65740

Received: 23/06/2014

Respondent: Gregory Weston

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Already far too much traffic in Bremridge Close to point it is dangerous. Disabled find it worryingly unsafe to cross. Significant shortage of parking with people using pavements causing safety issues

Support

Representation ID: 65760

Received: 25/06/2014

Respondent: Mrs E Brown

Agent: Stansgate Planning

Observe the proposed allocation to be sound and appropriate, it will have the least impact on the wider landscape and the openess of the Green Belt. The site is sustainably located with nearby community facilities and potential highway capacity. The site has no constraints in terms of access, flooding and protected species, with a limited impact from noise. Overall the site is sustainable and can be developed without harm to the wider Green Belt.

Object

Representation ID: 65877

Received: 27/06/2014

Respondent: Centaur Homes

Agent: McLoughlin Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Object to this policy,in particular the allocated sites as follows primarily on the grounds of size and suitability:-
- H20 Barford Land south of Barford House.
- H24 Burton Green Burrow Hill Nursery
- H27 Hampton Magna south of Arras Boulevard
- H29 Kingswood Meadow House
- H31 South of the Stables
- H33 Kingswood West off Mill Lane
- H34,H35 & H36 Leek Wootton - should be one allocation
- H37 Car Park East of Hayes
- H27 Hampton Magna South of Arras Boulevard will contribute to coalescence of Hampton Magna with Warwick.

Object

Representation ID: 65987

Received: 27/06/2014

Respondent: Barwood Development Securities Ltd

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The assumption that all the urban brownfield sites, along with the small SHLAA sites, will yield 1,330 units with no allowance for non-implementation or slippage is
questionable.

To reflect the uncertainties connected to the deliverability of a number of the urban brownfield sites, Barwood recommends that a 10% reduction is applied to the number of dwellings which could be delivered on urban brownfield sites.

The identification of Bishop's Tachbrook as a 'Growth Village' is supported, as it is truly capable of accommodating growth.

It is considered however the Plan is currently unsound as it identifies some 20 villages within this category some of which will only bring forward 10 or fewer units.

Barwood strongly disagrees with the identification of only a single allocated site in Bishop's Tachbrook,when the location is capable of accommodating greater levels of growth than those currently proposed.

Land to the South of Mallory Road is a site which is better placed to accommodate residential development than the site to the south of the Primary School. Barwood strongly disagrees with the decision not to allocate this land for residential development.

Barwood consider that the approach taken by the Council in allocating housing sites within Growth Villages is not sound as it is not consistent with the Framework. The policy approach does not allow for a sufficient choice and range of dwellings.

Object

Representation ID: 66026

Received: 27/06/2014

Respondent: Barratt Homes

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst the approach chosen by Warwick District Council to allocating development by disbursing housing growth across the district is considered justified. The process of apportioning housing allocations to the villages in the Green Belt is not considered justified given the lack of a robust evidence base.

The identification of Hampton Magna as the highest scoring village in the District in the Settlement Hierarchy Report (Draft) is considered to be justified on account of the range of services and facilities within the village, the proximity of the village to Warwick and the connectivity of the village to good local, regional and national public transport links.

Currently the growth of some of the District's villages, such as Hampton Magna, are constrained by the location of these villages in the Green Belt.

The apportionment of housing between the villages, as listed in the Local Plan Publication Draft consultation document at Policy DS11, is not considered to either represent the most appropriate strategy or be justified by a robust evidence base or achieve the spirit of NPPF paragraph 109 with respect to the protection and enhancement of the most valued landscapes.

With respect to housing numbers, there does not appear to be a consistent and transparent approach taken to deriving the apportionment of housing numbers to the villages. it is certainly not clear whether the 100 dwelling housing allocation for Hampton Magna shown in policy DS11 has been robustly derived.

Barratt Homes queries why WDC has chosen to restrict the housing apportionment for Hampton Magna to 100 dwellings. The evidence base calculations do not appear to justify this restriction.

The rejection of land west of Stanks Farm, based purely on the connectivity of the site with the settlement is not considered justified. Whilst the land west of Stanks Farm is not as directly accessible to the majority of key facilities as the proposed site, there is not a significant difference in accessibility and indeed the land west of Stanks Farm achieves better accessibility to public transport than is achieved by the proposed allocation site (H27).

Notwithstanding this, the evidence base does not even test the potential for the land west of Stanks Farm to be developed in addition to another site at Hampton Magna (eg H27) in order for the full development potential of the very sustainable Hampton Magna to be optimised, realised and expanded beyond the dwelling capacity constraint of 100 dwellings imposed on Hampton Magna by the single proposed allocation H27.There is no justification for the restriction to 100 dwellings and we therefore consider
this level of housing to be arbitrary.

The Green Belt allocations, particularly around Hampton Magna should accordingly be reviewed, for the Local Plan to be found 'sound'.

Object

Representation ID: 66108

Received: 27/06/2014

Respondent: CALA Homes (mids) Ltd

Agent: Cerda Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Objections are raised to the arbitrary restriction in the amount of development on each allocation. The NPPF seeks to boost significantly the supply of housing and to make good use of land.

No evidence has been provided from the Council to reason why the various sites have been restricted to the number they have. The figures should at the very least be expressed as a minimum in order to satisfy the requirements of the NPPF.

It is important to make best use of land when developing, particularly in villages which may only see this level of growth within any given plan period.

Object

Representation ID: 66117

Received: 27/06/2014

Respondent: Mr and Mrs Martin

Agent: Cerda Planning Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The 2009 Green Belt review is considered dated and in need of review to properly inform the Council's Local Plan. It fails to consider sustainable sites in well placed locations such as the land west of Old Budbrooke Road.The review methodology is considered flawed and has resulted in sustainable sites that should have been considered for release being missed.

The 2012 review which although followed the NPPF,only focused on several sites and did not seek to remedy the issues outlined above. Without an up to date and thorough review, the evidence base relating to the Green Belt is considered flawed.

The land west of Old Budbrooke Road, has good transport links and is served by a number of nearby amenities.With regard to the quality of the environment, the land is not open as one would expect the Green Belt to be, it has become urbanised through developments including housing, employment and transport infrastructure.Therefore the Green Belt in this location no longer serves the purpose of the Green Belt, as set out in the NPPF, and its protection in this area is no longer considered critical when assessed against those objectives.Furthermore initial technical work has been undertaken which indicates that there are no environmental or physical constraints to development.

The site should be considered for allocation now and within this plan-period. Its proximity to the strategic and local highway network and its connections to Birmingham and Coventry are such that the site can make a significant positive contribution in assisting Warwick District Council in satisfying its duty to cooperate.

Object

Representation ID: 66144

Received: 27/06/2014

Respondent: Mr Daryl Hunter

Agent: Framptons

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Council recognises that meeting the development needs of the District cannot be fulfilled without releasing some land from the greenbelt. It is submitted that land at Bamburgh Grove (edged red in the accompanying plan) is released from the green belt to provide for in the region of 35 to 40 dwellings. This would not affect the fundamental purpose of the green belt. The site is not reliant upon adjoining land for access and services, it can be accessed via Bamburgh Grove and is not of high environmental value. It is enclosed by substantial hedgerows.

Object

Representation ID: 66152

Received: 27/06/2014

Respondent: Hatton Estate

Agent: RPS

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We consider that Hatton Station should be moved into Growth Village category on the basis of the station, which makes the settlement highly accessible to higher order services and facilities in the main towns, and accordingly there should be an allocation for residential development within the settlement. In the Local Plan it is currently designated as a Limited Infill Village. On this basis, we believe that Policies DS11 and H1 of the Local Plan are unsound as they fail the tests in respect to being positively prepared, justified, effective and consistent with national policy.

Object

Representation ID: 66178

Received: 27/06/2014

Respondent: Hallam Land Management and William Davis

Agent: Marrons Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

This representation relates to the omission from Policy DS11 of the site, on land south of Gallows Hill from the list of sites allocated in the policy for residential development.

Application W/13/1434 was prepared and submitted on the basis of the Council's clear indication in the RDS of 2013 that the site formed an integral and necessary component of the strategic development proposals south of Warwick, Leamington Spa and Whitnash.

The land to the south of Gallows Hill no longer forms a part of the proposals set out in the Publication Draft Plan, due to matters of heritage concerns.

Our clients conclude that subject to the heritage concerns being "resolved" there are no technical or other sustainable development reasons that would inhibit the allocation of this site in the Local Plan.

Object

Representation ID: 66239

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Crest object to this policy which does not allocate land within their control at Lodge farm , Westward Heath Road, Coventry. These representations should be read in conjunction with those on duty to Co-operate and Policy DS6- Level of Housing Growth, Policy DS7 - Meeting Housing Requirements and DS1O Broad Location tor Development. As stated in our objection to the level of proposed development (Policy DS6) as well as Duty to Co-operate) there is a recognised and identified need for additional housing within the District not just to meet the District's housing needs but probably also those of adjoining districts such as Coventry. The Local Plan should and must provide the necessary certainty that those needs will be met. This can only be achieved if additional land is identified for housing development.

The Joint Green BElt Study (2009) concluded that the land is one of the least constrained parcels to the south of Coventry and potentially suitable to be released from the green belt.

The suitability of the site for development was identified within the SHLAA (May 2013). The site is available, suitable and deliverable.

It has been demonstrated that both the existing road network and schools have capacity to cope with the proposed development.

Object

Representation ID: 66253

Received: 27/06/2014

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Plan and its evidence base suggest that as a consequence of these developments significant additional traffic will be generated and pass through the historic town of Warwick.

Phase 4 Strategic Transport Assessment suggests few traffic management measures are required to accommodate such an increase in traffic and would conserve the significance of the historic environment as a consequence.

It remains unclear, a) how the historic environment was considered, as STA4 makes little or no reference to the historic environment, and b) what are the implications of the additional traffic on levels of congestion and as a consequence the character and setting of the town.

An increasing demand to travel through the town provides an opportunity to enhance the public realm and streets in the town consistent with NPPF para 137, 156 and part of the Plans positive strategy for the conservation of the historic environment (NPPF para 126).

Object

Representation ID: 66256

Received: 26/06/2014

Respondent: Taylor Wimpey UK Ltd (Andrew Taylor)

Agent: Framptons

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

There is no reasonable prospect of land at Opus 40 being used for employment within B1. The assumptions made in the 2013 Employment Land Review are flawed. Market signals and relative need for residential land in sustainable locations which is readily deliverable cries out for this site to be allocated for residential purposes.

Object

Representation ID: 66269

Received: 27/07/2014

Respondent: Mr. Paul Hodge

Legally compliant? No

Sound? No

Duty to co-operate? No

The housing provision proposed to the south of Warwick is excessive. The New Local Plan diregards green belt yet does not pursue with sufficient vigour brownfield sites. Brownfield site are preferable yet appropriate Green belt would be a far better option to distribute the development, rather than inappropriate green field sites.

The plan is not justified because it crams so much of the new development into the already congested south part of the district.The pressure on schools and the road system is already immense. The road network between Myton Road and Europa Way will not cope with the development and then the massive associated increase in school traffic.

The plan is not justified because it is creating more car-dependent suburbs, with thousands more car journeys each day.

The plan is unsound because it will contribute to the already illegal air quality in central Warwick. This problem has been in existence long before the Preferred Options were set out and remains in breach of these regulations today. I object to the increased public health risk which adding more cars to the centre of Warwick at peak times will certainly contribute to.

Object

Representation ID: 66271

Received: 27/06/2014

Respondent: Lands Improvement Holdings (LIH) and Kenilworth Golf Club (KGC)

Agent: Indigo Planning Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Based on our assessment in Section 2, we consider that a proportion of the District wide housing requirement should be directed to Kenilworth. As a minimum, the Local Plan should direct 2,122 new dwellings to Kenilworth.

The level of housing growth for Kenilworth falls significantly short of the minimum 2,122 dwellings that we consider to be required to meet local housing need in the town.This is a shortfall of 892 dwellings. However, applying a more robust District-wide total (13,896) the shortfall will be 1,063 dwellings.

This creates a clear requirement to identify additional suitable locations for housing development in Kenilworth. In accordance with the NPPF requirement to plan positively and to meet for the needs of the area, WDC should aim to accommodate higher levels of housing growth in Kenilworth.

There are limited housing sites within the built up area of Kenilworth, other suitable sites need to be allocated in or around the town.

Kenilworth Golf Club (KGC) has already been identified by WDC as a potentially suitable site to accommodate housing growth in the town.In order to address the shortfall in housing provision in Kenilworth, KGC should be allocated
for housing. The site can accommodate 700 - 1,000 new dwellings, together with a mix of supporting community uses and high-quality formal and informal open space.

It should be noted that the Green Belt function of the site will be eroded by the route of HS2 as it will no longer form a cohesive part of the wider Green Belt or the countryside area. The site, therefore, offers
an opportunity to accommodate significant housing growth in addition to the sites already identified to meet the housing needs of Kenilworth.

On this basis, the KGC site should be released from the Green Belt and allocated for housing.

Object

Representation ID: 66439

Received: 30/06/2014

Respondent: Mrs Luisa Hodge

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The Local Plan after emotive pressure from North Leamington protestors disregards green belt yet does not pursue with sufficient vigour preferable brownfield sites. The area of restraint between Myton Road and Europa Way is a case in point. It is high grade agricultural land full of wildlife, ancient trees and hedgerows. Since 2000 Warwick has undergone a large increase in population (12%) which is approximately twice the rate of Warwickshire and the national average and three times the increase for West Midlands. The plan is not justified as it crams so much of the new development into the already congested south part of the district. This is because of pressure from developers who wish to build in the areas which afford them most profit. Roads and schools in this area are already under pressure.
The plan is creating more car dependant suburbs. Recent development at Warwick Gates has not justified bus services. It will also contribute to the already illegal air quality in central Warwick.

Object

Representation ID: 66467

Received: 27/06/2014

Respondent: Gladman Developments

Agent: Stansgate Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Consistent with the proposed spatial strategy policy, identifies sites within and on the edge of the main urban areas of Warwick, Leamington Spa, Whitnash and Kenilworth and allocations for the district's identified Growth Villages. The Policy also makes provision for a site to be allocated on the edge of Coventry.
Council previously consulted on its proposed site allocations in the district's Growth Villages through the LP: Village Housing Options and Settlement Boundaries Consultation in November 2013. Through this consultation and with particular regard to Radford Semele, Council identified Land to the East of Church Lane as their preferred option to provide a housing site in the village. However, citing comments received to the LP: Village Housing Options and Settlement Boundaries Consultation and further work that has now been undertaken on landscape quality and sensitivity, the preferred allocation in the village has been amended to Land North of Southam Road.
Policy Analysis
Previously made clear strong support for the Council's decision to promote Land to the East of Church Lane, Radford Semele, as preferred locations for a future allocation within the village. Alongside site-specific representations prepared, we submitted that this represented a wholly sustainable and suitable location for further residential development to accommodate a proposal of up to 130 homes. Highlighted that there were no significant constraints to bringing site forward that could not be overcome through an appropriately planned scheme.
In light of our previous representations therefore strongly object to decision to withdraw Land to the East of Church Lane as preferred location for further development in the village. Whilst we are aware of the further work undertaken to assess landscape quality/sensitivity around Radford Semele, we object to the results of this assessment in relation to development on Land to the East of Church Lane, which indicates only a small portion could be developed. Clearly demonstrated through a number of technical studies prepared for our recent planning application for the site, a scheme of up to 130 dwellings can come forward in this location whilst still respecting the setting and views of St Nicholas Church and the landscape character of the site. Submit that Land to the East of Church Lane, Radford Semele, should now be reallocated for a development of up to 130 dwellings, to meet the authority's housing needs.
Site represents wholly sustainable location and is available/achievable now. Submit there are no justifiable reasons why could not contribute to district's housing needs.
Further details for this site have been prepared. These representations further demonstrate the suitability of site for residential development and should be read alongside this submission.
Conclusions on Soundness
Object to Council's decision to withdraw Land to the East of Church Lane as their preferred location for an allocation in Radford Semele. Demonstrated this site represents a wholly sustainable and suitable location for further development to meet the authority's housing needs. In the process of preparing a planning application for the site, have prepared number of technical studies which clearly demonstrate that there are no significant constraints that would preclude a development of
up to 130 dwellings on the site. Strongly question findings of Council's landscape quality and sensitivity assessments for the site.

Object

Representation ID: 66576

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The greenfield and in some cases Green Belt allocations in Policy DS11 are not justified and the Green Belt locations would be contrary to national policy. A housing requirement of approximately 8,000 dwellings would not require any significant greenfield land to be used, and housing in Green Belt could be limited to 1-2 houses on sites within washed-over villages (Policy H11).

Object

Representation ID: 66610

Received: 27/06/2014

Respondent: Richborough Estates Ltd

Agent: Strutt & Parker

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The allocation of 760 new homes on land east of Kenilworth as set out in Policy DS11 (Greenfield Site Ref. H06) is supported in principle. However, as submitted through these representations, there is a significant degree of uncertainty associated with the comprehensive delivery of the site. This is because a major landowner - KRC who control approximately 20% of the overall allocation site area, one third (255 dwellings) of the total housing proposed (760 dwellings) - will need to be relocated.

Object

Representation ID: 66618

Received: 27/06/2014

Respondent: Mr Michael Kinson OBE

Legally compliant? No

Sound? No

Duty to co-operate? No

The land north of Kenilworth and South of Coventry (Kings Hill) should be allocated to meet the housing needs of both Warwick and Coventry. Especially as the recent studies suggest that Coventry require a significantly higher housing figure. This housing would be located nearer to employment opportunities are and will be in the future.

Support

Representation ID: 66697

Received: 27/06/2014

Respondent: Mrs Ann Kelsey

The plan distributes development whilst making the best use of existing infrastructure and supporting local businesses. The retention of the green belt to the north of Leamington is supported.

Object

Representation ID: 66705

Received: 27/06/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The assumption that all the urban brownfield sites, along with the small SHLAA sites, will yield 1,330 units with no allowance for non-implementation or slippage is
questionable.

To reflect the uncertainties connected to the deliverability of a number of the urban brownfield sites, Barwood recommends that a 10% reduction is applied to the number of dwellings which could be delivered on urban brownfield sites.

Further to the removal of both The Asps and Land South of Gallows Hill from the Local Plan, the Council has produced two draft evidence base documents entitled 'The Setting of Heritage Assets', one of which relates to The Asps and one related to Land South of Gallows Hill. Both documents are stated to be in draft and, to our knowledge, have not been subject to consultation or scrutiny.

Barwood's consultant team have previously, in our response to the Revised Development Strategy, provided a detailed and thorough response to the RMA work and English Heritage's commentary. The soundly based technical Heritage Setting Assessment prepared by EDP and submitted in support of The Asps planning application demonstrates the suitability of The Asps to accommodate a significant amount of development with (following mitigation) no harmful impacts on the landscape which is adjacent to it, or indeed to the historic setting of the town, the Castle Park and other relevant heritage assets.

Support

Representation ID: 66713

Received: 27/06/2014

Respondent: Gleeson Developments

Agent: Savills (L&P) Ltd

Gleeson supports the general allocations set out in Policy DS11 (Allocated Housing Sites), including site H09, Kenilworth School and H12 Kenilworth VI Form College.

Object

Representation ID: 66737

Received: 27/06/2014

Respondent: The Rosconn Group

Agent: Miss Donna Savage

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Objects to the omission of Hatton Station as a Growth Village. Hatton Station has a railway station which offers an alternative means of transport but has been overlooked for development whereas villages with no choice of transportation but having a couple of shops have been given greater weight.

Object

Representation ID: 66744

Received: 27/06/2014

Respondent: Mr Richard Brookes

Legally compliant? No

Sound? No

Duty to co-operate? Yes

The level of growth is too high. Since the publication of this Draft new ONS projections show that population growth between 2011 and 2029 is 15,300 compared with the joint SHMA figure of 23,800.
This error is compounded by the Joint SHMA using a Household Headship Ratio of 1.66 people per dwelling. If the ratios and sizes of affordable and market homes are taken into account this ratio should be 2.12. If this is applied to the new population projection this gives a housing requirement of 7,700. If the ratio of 1.66 is used this gives a requirement of 9,300.

Support

Representation ID: 66764

Received: 27/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

Throughout previous consultation stages of the Local Plan the settlement of Hampton Magna has been identified as being capable of accommodating between 100 and 150 new homes. Informed by the findings of a green belt review, in 'Village Housing Options and Settlement Boundaries Consultation' (November 2013) the District Council identified land held by the Trust as the preferred site for new housing in the village. We support this recommendation and the Council's decision to allocate the site for development under Policy DS11 in the Draft Local Plan; site reference H27 'Hampton Magna - South of Arras Boulevard'.
It is the Trust's considered view that not only is Hampton Magna a suitable location for additional growth, we strongly believe that the village can benefit greatly from well planned development of an appropriate scale. Measuring approximately 6 hectares the allocated site has the capacity to comfortably deliver 100 dwellings in a location which would not undermine the stated purposes of the Green Belt. As equally important, given the site's size, sufficient land is available to accommodate new tree planting to help screen the development and create a well defined edge to the southern part of the village without compromising the overall scheme by forcing up densities.
Furthermore from our own Green Belt appraisal and baseline assessment of the site's development potential, we consider that land South of Arras Boulevard is not only a logical location for new development at Hampton Magna but the best site based on the following factors:
 Least impact on the Green Belt
 Least landscape and visual impact
 Physically well connected to the village, with good vehicular access
 Physically well located to the primary school and existing local facilities
 Physically set back from the A46 and the railway line - sources of visual and noise
 impact
 No known physical or environmental constraints to development
The Trust can also confirm that not only does the site offer a suitable location for development now, but it is also viable and achievable, with a realistic prospect that housing will be delivered on site within five years.
Finally, the King Henry VIII Endowed Trust has well established strong links with the local community and is keen to bring forward development that is built to a high standard of design and environmental performance, which the Charity, Hampton Magna and the District Council can be proud.

Object

Representation ID: 66782

Received: 27/06/2014

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

This does not take account of previous years oversupply; completions to date; sites under construction; vacant dwellings already returned; permissions not started; further permission between April and December 2013; offices to residences approved; windfall sites for the plan period; small urban sites on SHLAA sites and consolidation of existing employment areas and canal side development. This means that if the housing numbers identified as needed by a revised approach on population numbers and the conversion method to number of dwellings then no further applications need to be granted to meet the plan as there is already a surplus provision.

If the maximum figure for the reduced population projection figure of 9,217 is considered to be necessary, then to this list can be added allocated urban brownfield sites definites only; 2 greenfield sites in urban locations; 4 sites accepted in villages and 6 sites granted since January 2014 can be added giving 9,601 dwelling sites.

The reduced population projection and the related reduction in the number of houses required now means that the use of any further greenfield sites cannot be demonstrated to be necessary and those should be removed from DS11.

Grove Farm at 200 dwellings, future vacant dwellings return and a list of 543 C2 homes for the elderly can also be counted in the supply. With these it would not be necessary to keep the sensitive urban brownfield and sensitive greenfield in DS11.

Object

Representation ID: 66796

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is necessary for the authority to allocate additional sites to make up the housing shortfall in order to meet objectively assessed housing need. Land identified as South of Gallows Hill should be allocated for this purpose for 450 dwellings with associated green infrastructure. The site is available now, offers a suitable location for development now and there is every prospect that a number of houses can be delivered within five years. The site has sustainability benefits similar to land South of Harbury lane and the sole reason why the site is not allocated for development is due to the heritage settings assessment. Technical work undertaken by Turley Associates raises concerns regarding the robustness of the Council's evidence base and draws very different conclusions in terms of the acceptability of development on the site. This reaches the conclusion that only a very limited degree of harm would arise from development south of Gallows Hill. In the context of the NPPF, paragraph 134 this constitutes less than substantial harm where the harm is to be weighed against the public benefits of the proposal. Indeed this approach is advocated in proposed Policy HE4 of the Draft Local Plan. It is not the case, as advanced in the Council's evidence base and SA, that because there is harm, no matter how limited that is, that a site should not be developed. Such an interpretation is not consistent with the NPPF, is not justified and is unsound. This would be in the public benefit consistent with paragraph 134, NPPF as it would deliver sustainable development in a location that would not require further incursions into the statutory Green Belt.

Support

Representation ID: 66823

Received: 27/06/2014

Respondent: A C Lloyd Homes Ltd and Northern Trust

Agent: Framptons

Support the broad allocation of allocated housing sites particularly urban brownfield site H02 Former Sewage Works, south of Harbury Lane and greenfield site H02 land south of Harbury Lane on the edge of Wariwck and Leamington.