Issue and Options 2023

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With regard to how and where best housing shortfalls should be accommodated in South Warwickshire, HLM consider that settlements or areas with the strongest sustainable transport connections to the conurbations where unmet housing needs are arising should be prioritised. In the case of Coventry’s unmet needs, this should include the Warwick and Leamington urban area.

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3. HLM consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and HLM consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. 4. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Housing Market Area and therefore should not be excluded.

5. The following three comments are made in respect of the SA. 6. Firstly, as a general comment, it is noted from the Introduction and description of the SWLP area that the SA has focussed on what is inside the boundary administered by the two authorities. But the SA should also recognise what is beyond the boundary, and notably Coventry as a major City on its borders that has a significant influence over the area should be recognised in the description of the area. 7. Secondly, the Appraisal has only assessed South Coventry for 50-500 homes as a reasonable alternative Small Settlement Location (SSLs) alongside a number of villages. South Coventry has a level of infrastructure, jobs, and services (not least a World Class University) which dwarfs the other SSLs and therefore is out of place in this list. 8. South Coventry is clearly more akin to the Main Settlements, and therefore Broad Locations (BL) should be appraised for up to 2,000 homes as reasonable alternatives. South Coventry as an area is sufficiently large that it could have three or more BLs in accordance with paragraph 3.6.1 of the SA. Further, having regard to Figure 3.3 of the SA, the area around South Coventry is within 800m of service provision that is either existing (e.g. bus interchange at the University, Woodfield Primary School, GP and retail facilities at the University, Tocil Wood Nature Reserve, Wainbody Wood, Crackley Woods Nature Reserve) or planned as part of the Kings Hill SUE or Coventry South Rail Station and Public Transport Interchange. 9. Finally, land has been put forward through the call for sites process in 2021 (including the HLM site 103) which could accommodate a scale of growth up to 2,000 homes in this location, so this is a ‘realistic option’ having regard to Paragraph: 018 Reference ID: 11-018-20140306 of the NPPG. 10. It is not clear from the SA on what basis the HLM site has not been assessed in the SA, with only one site south of Coventry having been assessed as an SSL (C.17). 11. Having regard to Figure 3.3 of the SA, the entire HLM site falls within 800m of the existing Woodfield Primary School, and the planned Primary School which is part of Phase 1 of the Kings Hill SUE to the immediate north of the site (illustrated within the Vision Document). Whilst it is acknowledged that Woodfield Primary School is a special education school, and that the primary school at Kings Hill SUE is yet to be built, it will be within the next 5 years based on the Council’s Housing Trajectory. 12. Further, the Transport Authorities for the area have consulted on a new train and bus station/interchange within the HLM site, and are planning for its delivery during the early part of the Plan period (as illustrated within the Vision Document). 13. In respect of GP surgery and local shop, all of these facilities will be provided within the Kings Hill SUE to the north of the site. This is likely to be slightly beyond 800m, however, the HLM site is of a scale such that it has capacity to accommodate a GP surgery and local shop within a local centre as illustrated within the Vision Document. 14. In respect of publicly accessible greenspace, the majority of the site is within 800m of Wainbody Wood to the north as acknowledged within the Landforms Analysis in the Settlement Design Analysis. 15. The HLM site does therefore satisfy the criteria within Figure 3.3 for primary schools and publicly accessible greenspace, and can satisfy the criteria in respect of all other elements during the Plan Period. As only one criteria needs to be satisfied, the HLM site is therefore a BL and should be assessed as a reasonable alternative. 16. An overly rigid application within the SA of Figure 3.3 that ignores planned service provision that is to be delivered early in the Plan period, and ignores potential service provision that can be delivered within the site, will result in missed opportunities to contribute sustainably towards growth up to 2050. 17. It is worth remembering that paragraph 73. a) requires Councils to consider the opportunities presented by existing or planned investment in infrastructure when deciding the location of new development. The SA should therefore take into account the planned facilities at Kings Hill SUE. 18. The HLM site 103 is well placed to achieve the 20 minute neighbourhood principle for all services listed in Figure 3.3, and is therefore a BL reasonable alternative which HLM would request be assessed as part of the next iteration of the SA. 19. Failure of the SA to appraise realistic growth options south of Coventry as a reasonable alternative could result in the Plan not demonstrating that its proposals are ‘appropriate’ and ‘justified’.

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20. Yes, HLM consider a policy should be included that safeguards specific infrastructure. This should include the Coventry South Rail Station and Public Transport Interchange, Track widening of the Leamington to Coventry Rail Line, Coventry’s Very Light Rail Track Proposals, and the A46 Strategic Link Road as illustrated within the Vision Document. Any designation on the Proposals Map will need to identify a zone to allow flexibility at the detailed design stage.

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Option S2-C: Intensification 21. Intensification is a way to optimise brownfield land and realise its effectiveness. However, HLM consider that this matter should be dealt with by the SWLP Part 2 Local Plan or Neighbourhood Plans if relevant, so that the implications of applying an intensification policy to a particular area can be assessed in terms of character and deliverability, which are key factors to consider. 22. Intensification is challenging and requires evidence around viability and deliverability before it can be considered to form part of the supply, and as such any intensification potential in the windfall allowance should be avoided.

23. The production of an Urban Capacity Study (UCS, October 2022) to support identification of brownfield land to help deliver the growth needs of South Warwickshire is in accordance with the NPPF1. The following points are made in relation to how the UCS considers housing supply in the urban areas. However, it should be noted that the UCS also discusses the SWLP housing requirement and representations are made on those points under Q-H1-1 & 2. 24. In relation to housing allocations from the adopted Local Plans, HLM consider that a comprehensive review of all outstanding allocations without planning permission is required to ensure that such sites still meet the definition of developable as set out in the NPPF2. In particular, evidence will be required to demonstrate why the UCS suggests the capacity of some of the allocations will increase beyond what is included within the adopted Local Plan. That review and evidence must be published prior to the next iteration of the Plan to demonstrate the capacity from the allocations can be relied upon to meet the housing need. 25. The UCS also includes within the supply 795 dwellings on sites which have been submitted to the SWLP Call for Sites process in the urban areas, and are considered to be potentially suitable. As no formal assessment of these submissions has taken place, their inclusion will need to be reviewed once the Housing and Economic Land Availability Assessment (HELAA) is published. Any allowance for such sites must be deducted from the windfall allowance. 26. The UCS identifies an additional five sites on vacant land in the urban areas which have not yet been submitted to the Call for Sites process, but are considered potentially suitable for 328 dwellings. There is no certainty around the availability and deliverability of these sites to include them at this stage. Further, on assessment of these sites there are some serious concerns around their suitability in any case. The UCS also identifies two additional sites on brownfield land within the urban areas, at Talisman Square, Kenilworth (65 dwellings) and Westgate House, Warwick (39 dwellings). As above, these sites have not yet been submitted to the Call for Sites process and so there is no certainty around delivery. 27. Finally, the UCS includes an assessment of the potential windfall supply with reference to the level of windfall delivery across South Warwickshire in the period 2011/12 to 2020/21. However, it is considered that this assessment is limited as it does not detail the sources of windfall supply, nor consider how the planning policy landscape in South Warwickshire may impact future windfall delivery. Whilst a windfall allowance is likely to be acceptable in principle in the SWLP, it should be calculated on the basis of compelling evidence as required by the NPPF 3. 1 Paragraph 119 of the National Planning Policy Framework (July 2021) 2 Glossary of the National Planning Policy Framework (July 2021) 3 Paragraph 71 of the National Planning Policy Framework (July 2021)

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Q-S4.2: Settlement Analysis 29. The following comments are made in respect of HLM’s site reference 103, which is referenced as Area 7 and 8 within the South of Coventry Area. 30. In respect of Connectivity, it is noted the only barriers listed are the railway between Areas 7 and 8, and HS2 to the south. The Transport Authorities for the area have consulted on a new A46 Strategic Link Road within the HLM site that would provide a new crossing over the railway. Connectivity across the railway can be overcome and is envisaged by the Transport Authorities. HS2 to the south is not a barrier to connectivity to the South of Coventry, and therefore not considered relevant. Importantly, there are no barriers between the site 103 and the urban area of South Coventry. 31. In respect of Landforms, no account is taken in the assessment of the planned services at Kings Hill SUE. Unless there is evidence this development which has planning permission is not to be delivered, then it should be taken into consideration when assessing sites otherwise opportunities will be missed to locate development near to planned infrastructure and facilities. 32. Paragraph 73. a) requires Councils to consider the opportunities presented by existing or planned investment in infrastructure when deciding the location of new development. The assessment should therefore be amended to take into account the planned facilities at Kings Hill SUE. 33. A comment is made in the Connectivity Section that the area would erode the separation between Coventry and Kenilworth at its narrowest point. This comment does not appear to be relevant to the Connectivity Assessment, and in any event is inaccurate as the narrowest point would not be eroded. 34. It is noted the Councils are to undertake a review of the Green Belt to assess whether there are areas which no longer meet all five of the Green Belt purposes and could be removed. HLM have submitted with these representations an assessment of its site against the five purposes of the Green Belt, and it is requested this is taken into account when the Councils undertake their assessment. 35. In summary, the extent to which site 103 contributes to the purposes of the Green Belt and preventing neighbouring towns merging is diminished by the construction of HS2, the planned construction of the A46 Strategic Link Road, and the planned woodland belt that will be planted along these two infrastructure corridors. These works will create a sizeable and strong defensible boundary between the settlements of Coventry and Kenilworth, and the narrowest part of the gap between the two will not be eroded as illustrated within the assessment provided by HLM. 36. It is important also that any assessment has regard to paragraph 142 of the NPPF, and the need to give first consideration to previously developed land and/or land well served by public transport, and also to take into consideration the ability to offset any removal through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. HLM’s proposals as illustrated within the Vision Document for site 104 show how compensatory improvements are proposed to the environmental quality of land north of Kenilworth in the form of flood mitigation and ecological enhancement works. 37. The Councils will be aware of the Transport Authorities plans to provide a new rail station/public transport interchange within the HLM site, that is to be connected by Very Light Rail to Coventry running through the site. When completed, this site will be one of the best served sites in South Warwickshire for public transport.

Q-S4.1: Growth of Existing Settlements 28. Yes, growth of existing settlements in South Warwickshire (and on the edge of South Warwickshire) is imperative to deliver the overall growth targets, and achieve the Vision and overarching principles. The need for housing, affordable and specialist housing, jobs, green infrastructure, improved facilities and infrastructure are all generated within the existing settlements. Those needs are best met sustainably adjacent to the settlements, rather than in new settlements.

Q-S7.2: Refined Spatial Growth Options 38. HLM consider a mixture of options will be required to best deliver the growth needs of South Warwickshire for the reasons as set out below. 39. Firstly, the results of the high level testing of the five growth options in the supporting Sustainability Appraisal demonstrates that the options perform differently in different areas, with no one option standing out as the best performing option across all areas. 40. Secondly, it is important to remember that the assessment set out in the SA is provided at a high level, subject to several caveats, and without consideration of mitigation or deliverability. Options which score less favourably in the SA could therefore actually deliver more sustainable growth on closer examination. 41. Finally, given the significant level of growth the SWLP will need to accommodate (see response to Issues H1 and H4 below) this is unlikely to be able to be met sustainably through a single growth strategy. 42. HLM also have the following comments on the Options. 43. HLM query why growth South of Coventry appears to be limited to the Kings Hill SUE for the Rail Corridors (1), Sustainable Travel (2) and Sustainable Travel and Economy (4) Options. The consultation document recognises that infrastructure thresholds for new railway stations are 6,000 homes (Table 3). As Kings Hill is only 4,000 homes, an additional 2,000 homes would be necessary to support the viability of a new station. The HLM site would make a logical extension to Kings Hill SUE, connecting this SUE with a new Coventry South Railway Station as proposed by the Transport Authorities, and delivering around 1,300 additional homes that contributes to its viability and delivery. HLM therefore request these options (1, 2, and 4) are amended to include at least an additional 2,000 homes at South of Coventry. 44. HLM also make the following specific comment in relation to the Sustainable Travel Option (2). Reference is made to bus corridors, but no reference is made to Very Light Rail which Coventry City Council are proposing to develop into Warwick District within the Plan period at Kings Hill SUE and the HLM site (see below). It is noted in Issue T2 that people responded to the previous consultation by commenting that focus should be on encouraging the use of very light rail. The Sustainable Travel Option should have regard to the Very Light Rail proposals, and therefore include growth options along its route (namely the HLM site). 45. HLM also make the following specific comment in relation to the Economy Option (3) and Dispersed Option (5). These options include a significant urban extension south of Westwood Heath and Warwick University. It is acknowledged this is an indicative location for growth, however any major development in this location south of Westwood Heath could not be commenced until the A46 Strategic Link Road has been completed, which goes through the HLM site. Given the proximity of the HLM site to the University and surrounding employment areas, and the planned active and sustainable travel infrastructure for this area, the best solution for the Economy and Dispersed Options would be to spread growth across the area South of Coventry to ensure the best use is made of planned infrastructure and connections to jobs. Q-S10: Other Development Strategy Issues 46. More generally, HLM wish to make the point that the South Warwickshire Local Plan clearly must have regard to Coventry City and its proposals for the City. This is not just in terms of housing and jobs, but also transport, services, green infrastructure, etc. Having regard to the City’s ambitions for its City Centre, homes, jobs, and infrastructure, the South Warwickshire Local Plan must play its part and therefore South Coventry must inevitably be a focus for growth within the Plan period to 2050 to support the regeneration and transformation of the City to a modern 21st Century City with an expanded World-Class University, Very Light Rail, City fibre, high quality residential areas, and an innovative economy. 47. Both Warwick and Coventry Councils shared a Vision for land south of Coventry in its adopted Local Plan (Appendix B). That Vision should be refreshed and updated to reflect what has happened since 2017, and to look forward to how this area might be in 2050 with sustainable and active travel infrastructure at its core, with attractive residential communities nestled within green and blue infrastructure. 48. HLM have set out a Vision for its site which shows how development could help achieve the five overarching principles of the Plan. This includes a commitment to designing the development to drive down emissions and be more climate responsive. This Vision can sit within and inform a wider Vision for the area, and HLM would be happy to meet to discuss this further with the Councils and Transport Authorities.