Mod 17
Object
Proposed Modifications January 2016
Representation ID: 68387
Received: 22/04/2016
Respondent: Cryfield Land (Kenilworth) Ltd
Agent: Mr Niall Crabb
Legally compliant? No
Sound? No
Duty to co-operate? Yes
Whilst not objecting to the proposed modification wording, there is an associated concern that, at various other sections e.g. DS New 1, it is stated and/or implied that other known issues will be resolved by way of an additional Masterplan and/or Plan Review relating to an undefined area south of Coventry.
If the issue is known about it should be resolved NOW and certainly as part of the current Examination of the Plan, including its soundness.
Whilst not objecting to the proposed modification wording, there is an associated concern that, at various other sections e.g. DS New 1, it is stated and/or implied that other known issues will be resolved by way of an additional Masterplan and/or Plan Review relating to an undefined area south of Coventry.
If the issue is known about it should be resolved NOW and certainly as part of the current Examination of the Plan, including its soundness.
Object
Proposed Modifications January 2016
Representation ID: 68555
Received: 22/04/2016
Respondent: The Richborough Estates Partnership LLP
Agent: Star Planning and Development
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Richborough Estates Partnership LLP welcome the commitment to reviewing the Local Plan if there is a material change in circumstance. It would, however, be more appropriate for MOD17 and MOD18 to be consolidated and simplified.
Further, the criterion concerning up-dated household and population projections should be clarified to make is clear that the Local Plan will be reviewed where:
(f) Updating of the population and household forecasts which indicate that there is potential for a meaningful change to objectively assessed housing need used as the basis for the preparation of this Local Plan.
The Richborough Estates Partnership LLP welcome the commitment to reviewing the Local Plan if there is a material change in circumstance. It would, however, be more appropriate for MOD17 and MOD18 to be consolidated and simplified.
Further, the criterion concerning up-dated household and population projections should be clarified to make is clear that the Local Plan will be reviewed where:
(f) Updating of the population and household forecasts which indicate that there is potential for a meaningful change to objectively assessed housing need used as the basis for the preparation of this Local Plan.
Object
Proposed Modifications January 2016
Representation ID: 68570
Received: 22/04/2016
Respondent: Mr JOHN BOILEAU
Legally compliant? No
Sound? No
Duty to co-operate? No
The Duty to Co-operate does not require WDC to volunteer to help a neighbouring authority to the extend that WDC takes reponsibility for solving a problem on that other authoity's behalf. It requires WDC only to cooperate to help that other authority meet proven needs once that authority has exhausted other areas of exploration.
The Duty to Co-operate does not require WDC to volunteer to help a neighbouring authority to the extend that WDC takes reponsibility for solving a problem on that other authoity's behalf. It requires WDC only to cooperate to help that other authority meet proven needs once that authority has exhausted other areas of exploration.
Object
Proposed Modifications January 2016
Representation ID: 69029
Received: 22/04/2016
Respondent: CEG Steel/Pittaway
Agent: Nexus Planning
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Policy DS20 identifies a Local Plan review mechanism that will be triggered if a range of circumstances arise, generally relating to issues that would affect the District as a whole and are not necessarily unique to Warwick, i.e. changes in national planning policy.
WDC should require the preparation of an Area Action Plan (AAP) for the wider area south of Coventry, rather than dealing with it through a partial review of the Local Plan.
Policy DS20 "Review of the Local Plan" is not „justified‟ by failing to be the most appropriate strategy for the District.
see attached
Object
Proposed Modifications January 2016
Representation ID: 69034
Received: 12/04/2016
Respondent: Baginton Parish Council
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Object to removal of green belt status from village - will allow inappropriate development to take place
Object to removal of Rosswood Farm site from green belt
Object to removal of green belt from Map 8 for sub-regional employment - contrary to green belt review and subject to dismissal at appeal
See attached
Object
Proposed Modifications January 2016
Representation ID: 69217
Received: 22/04/2016
Respondent: Barwood Development Securities Ltd
Agent: HOW Planning LLP
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Should Nuneaton and Bedworth remain removed from the MOU, and the HMA distribution of development remain as set out at Table 1, then on adoption the Local Plan would immediately trigger an early review.
It would be beneficial if the policy contained a trigger mechanism, specifically in respect of the monitoring of housing delivery, to ensure that the policy is not ambiguous.
As drafted, Clause (D) is not meaningful and should be reviewed in order to provide a clear policy.
see attached
Object
Proposed Modifications January 2016
Representation ID: 69511
Received: 22/04/2016
Respondent: Home Builders Federation Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
This is a serious failing of co-operation between the C&W HMA authorities which has consequences for the soundness of individual Local Plans. Therefore the question remains whether or not the proposed Modifications 17 & 18 to Policy DS20 which set out triggers to action a review of the Warwick Local Plan adequately deal with and resolve the strategic matter of unmet housing needs arising in the C&W HMA.
It is also uncertain whether Modifications 17 to Policy DS20 cover the relationship between the C&W HMA and adjacent HMAs in which unmet housing needs are also arising, for example in Birmingham.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69599
Received: 21/04/2016
Respondent: Lenco Investments
Agent: RPS Planning & Development
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Welcome the objective behind this policy, though the mechanism for implementation needs to be adjusted.
New evidence could be presented not long after adoption that would leave the Council rethinking its approach and potentially be left with a document that is out of date. Preferable to include provisions within the policy that introduces additional flexibility e.g. as undertaken in Stratford recently.
Council should seek to include a similar approach as part of the Local Plan, which would be consistent with paragraph 182 of the NPPF, introducing an effective and positively prepared strategy.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69799
Received: 22/04/2016
Respondent: Bubbenhall Parish Council
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The proposal that Warwick district should take the largest share of Coventry's unmet housing need is unsound, given the Green Belt status of a large part. The NPPF requires that unmet needs from neighbouring authorities should only be accommodated 'when it reasonable to do so and consistent with achieving sustainable development'. Para 14 footnote 9 specifically excludes land in Green Belt.
Insufficient attention has been paid to infrastructure, and pressure on local roads. The proposed development at King's Hill and the proposed sub-regional employment site (DS16) and 80 houses at Rosswood Farm in Baginton (H19) will generate intolerable amounts of traffic through the villages of Stoneleigh, Baginton and Bubbenhall.
The policy has not paid sufficient attention to the Joint Green Belt Study 2015.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69839
Received: 22/04/2016
Respondent: Bishop's Tachbrook Parish Council
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
DS20 should also make provision for the need to relate the plan to reduction as well as growth if the need for housing is reduced by forthcoming household projections. Growth relates to economic growth not physical growth that cannot be sustained.
Suggested amendments to para a) are included in the full text
See attached
Object
Proposed Modifications January 2016
Representation ID: 69905
Received: 22/04/2016
Respondent: Hatton Estate
Agent: Barton Willmore
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Council intends to schedule a partial Plan Review within five years of the adoption date of this Plan. However, response to this new Policy is consistent with the view of the Inspector's interim response to the Stratford Core Strategy, in that a reserve housing policy would provide the Plan with flexibility to rapidly respond to changing circumstances which would be less resource intensive than a Plan review.
see attached
Object
Proposed Modifications January 2016
Representation ID: 69931
Received: 22/04/2016
Respondent: Gladman Developments
Legally compliant? No
Sound? No
Duty to co-operate? No
Gladman have concerns therefore that the Local Plan is not fully dealing with the issue of unmet need. In that context we
question the soundness of the current mechanism for plan review, which in theory could trigger an immediate review of the Local Plan. It would seem sensible to deal with these issues now.
see attached
Object
Proposed Modifications January 2016
Representation ID: 69944
Received: 22/04/2016
Respondent: Taylor Wimpey
Agent: Cerda Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Modification 17 notes that there would be a full or partial review of the Plan if changing circumstances could not be accommodated within the existing strategy.
Accordingly, the Plan is not considered sound in so far as there is insufficient flexibility to cater for either i) sites not coming forward for development or ii) greater than anticipated
levels of demand
see attached
Support
Proposed Modifications January 2016
Representation ID: 69957
Received: 21/04/2016
Respondent: University of Warwick
Agent: Turley
The University notes that one of the new criteria for reviewing the Local Plan is "development and growth pressures arising from the specific circumstances in the area to the south of Coventry". This again is a cross reference to Policy DS NEW1 and the University strongly supports a consistent long term view being taken of the need to facilitate its growth including infrastructure improvements.
See attached
Support
Proposed Modifications January 2016
Representation ID: 69971
Received: 22/04/2016
Respondent: Sharba Homes
Agent: Barton Willmore
RADFORD SEMELE - Support the revised wording to this Policy which details the review (partial or whole) of the Local Plan. It is considered important to review the Plan particularly if it transpires through monitoring that the overall development strategy is not being met.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69975
Received: 22/04/2016
Respondent: Gallagher Estates
Agent: Pegasus Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
We reserve out position as to whether the proposed triggers set out within Proposed
Modification 17 and 18 will adequately deal with and resolves the strategic matter of unmet housing need arising in the Coventry and Warwickshire HMA given the current level of uncertainty surrounding whether Nuneaton and Bedworth will assist in meeting the needs of C&W HMA and what likely impact this may have on the soundness of the Warwick Local Plan.
See attached
Object
Proposed Modifications January 2016
Representation ID: 69979
Received: 22/04/2016
Respondent: Grevayne Properties Ltd
Agent: Cerda Planning Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Mod 17 states that there would be a full or partial review of the plan if changing circumstances could not be accommodated within the existing strategy. The current
strategy to provide a 4.5% buffer would therefore only be sufficient to deal with minor changes to the in demand or supply restrictions and as such
See attached
Object
Proposed Modifications January 2016
Representation ID: 69996
Received: 22/04/2016
Respondent: Richard & Janel, Vince & Caroline Hill & McCullagh
Agent: Turley Associates
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Our client supports the Council's acknowledgement that the plan will be reviewed prior to the end of the Plan Period
if a number of events are triggered. In particular our client notes that one of the new criteria for reviewing the Local Plan is "development and growth pressures arising from the specific circumstances in the area to the south of
Coventry (as identified in Policy DS New 1)". However, our part (C) is not sufficiently precise. It should be amended to clarify how "not delivery" is defined. Our client considers that in order to ensure that either a full or partial review of the Plan is not required early in the
Plan Period the Council should allocate sufficient land within the Plan to ensure that the Council can meet both its
own full objectively assessed housing needs and that of other local authorities if demonstrated as necessary.
In order to help achieve this, the Council should remove our client's site from the Green Belt in order that it can be brought forward for development in order to assist the Council in meeting its own housing need and that of other
authorities.
See attached
Support
Proposed Modifications January 2016
Representation ID: 70013
Received: 22/04/2016
Respondent: Sharba Homes
Agent: Barton Willmore
BISHOPS TACHBROOK
Support revised wording to Policy which details the review (partial or whole) of the Local Plan. It is considered important to review the Plan particularly if it transpires through monitoring that the overall development strategy is not being met.
See attached
Object
Proposed Modifications January 2016
Representation ID: 70166
Received: 22/04/2016
Respondent: Commercial Estates Group
Agent: Nexus Planning
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Specific set of circumstances exist in the area south of Coventry that could warrant a review of the Local Plan. No other part of the District is under similar pressures or likely to experience such transformational change.
Suggest joint allocation of H42 and S1.
WDC should require an Area Action Plan for wider area south of Coventry rather than partial review of plan.
To establish a "policy hook‟ and to give landowners and developers greater certainly and confidence, the broad area could be referenced in the Local Plan with the exact extent determined through the preparation of the AAP itself.
See attached