Revised Development Strategy

Object

Representation ID: 55407

Received: 29/07/2013

Respondent: Mr Armitage, Mrs Grimes and Richborough Estates

Agent: Strutt & Parker

Concern is raised that the spatial strategy does not appropriately convey the Strategic Vision as set out. Whilst the Strategic Vision is ambitious, the spatial strategy set out within the RDS is too restrictive. The Strategic Vision and the spatial strategy need to be more closely aligned.

Object

Representation ID: 57023

Received: 29/07/2013

Respondent: Mr Armitage, Mrs Grimes and Richborough Estates

Agent: Strutt & Parker

Paragraphs 4.1.2 to 4.1.10 in the RDS set out the Council's justification for the proposed interim level of housing growth, although no credible explanation can be found.

Nor has the Council adequately demonstrated why the higher housing requirement (e.g. 14,300 dwellings) would not be appropriate. It is accepted that the evidence base is in the process of being updated and clearly the findings of the Joint SHMA will be critical to the soundness of the Plan.

Nevertheless departures from 'objectively assessed' evidence need to be clearly and concisely justified.

Objects to the proposed level of housing growth as set out within the RDS as it does not provide an appropriate level of growth in line with the evidence base underpinning the RDS. For the RDS to be found sound, it must first be positively prepared. This means that the Plan must meet objectively assessed development requirements (paragraph 182 of the Framework). Presently, there is no credible evidence base to justify the interim level of housing growth.

As such the Plan has not been positively prepared, it cannot be justified or effective and neither is it consistent with national policy.

With the abolition of the Regional Spatial Strategies and the withdrawal of Coventry's 2012 Core Strategy, the planning policy context has changed substantially.

New cross boundary issues will arise specifically in respect of housing numbers. Based on the evidence currently available to both Warwick and Coventry, it is inevitable that Warwick will be required to meet a proportion of Coventry's housing need.

Seeking to meet such need is part of the soundness test of a Plan being positively prepared.

The evidence base underpinning the RDS indicates that Warwick will experience a growth in employment of 9,500 over the identified Plan period with the Gateway development scheme providing a further opportunity to boost workplace employment in Warwick District - delivering up to 9,500 additional jobs within the District's boundaries.

Consequentially, the impact of this means that the objectively assessed need currently underpinning the NLP equates to 726 - 772 dwellings per annum.

Furthermore, the 2012 SHMA completed by GL Hearn on behalf of the Council, identifies a net affordable housing need within the District of 698 units per annum - over and above the need for new market housing.

Whilst it is acknowledged that this is significantly above both likely and/or realistic levels of housing delivery, conclusions can be drawn that the Council has an acute need for more affordable housing.

It is clearly evident from the evidence base that the level of housing growth set out within the RDS falls short of the objectively assessed need for both open market and affordable housing.

Object

Representation ID: 57024

Received: 29/07/2013

Respondent: Mr Armitage, Mrs Grimes and Richborough Estates

Agent: Strutt & Parker

Flexibility:

Over the past two years (2011 to 2013) the District has delivered 447 new dwellings - see Table 2 in the RDS - leaving the District some 919 dwellings short of their target for housing delivery early in the Plan period.

It is accepted that the current economic climate and access to development and mortgage finance has been difficult, but an important contributory reason for the historic under-provision has been the lack of a supply of deliverable housing sites.

It is unrealistic to expect the entire District's housing needs to be met at the later stages of the Plan period.

A failure to allocate sufficient land for development puts the Plan at considerable risk of being found unsound. It is better in terms of soundness to address this shortfall now.

By allocating sufficient land in sustainable locations around the principal urban areas of the District, the Council will be able to maintain a rolling five-year supply (plus buffer) of deliverable housing sites.

It is acknowledged that a Green Belt Review has already been carried out, but this was carried at a strategic, sub-regional level but believe that a localised Green Belt Review should be carried out around the most sustainable boundaries to identify sites on an individual basis suitable for release from the Green Belt.

Kenilworth is one of the most sustainable and desirable locations for housing within the District and should accommodate a larger proportion of new housing, particularly given its proximity to Coventry and the role it plays in the cross boundary Housing Market Area.

The RDS allocates some 700 new dwellings to Kenilworth all of which are to be accommodated on the proposed Strategic Urban Extension at Thickthorn.

This scale of growth is equivalent to approximately 10.5% of the total housing growth proposed within the District and would increase the size of the settlement by 7%.

There is no technical evidence to suggest that Kenilworth could not accommodate an increase of say 10 or 12% growth.

To be consistent with national planning policy, which seeks to boost significantly housing land supply, it is submitted that Kenilworth is suitable for a greater scale of housing growth, depending upon environmental and technical considerations.

There are no non Green Belt options available to Kenilworth for accommodating its future growth, which is a fact acknowledged by the Council in its emerging strategy for the town.

Object

Representation ID: 57025

Received: 29/07/2013

Respondent: Mr Armitage, Mrs Grimes and Richborough Estates

Agent: Strutt & Parker

Paragraph 5.4.24 of the RDS requires the successful relocation of both sports clubs to suitable sites in the Kenilworth area before development takes place

The existing sports grounds comprise 12.64 hectares, or some 27% of the total allocation (46.7 hectares). Paragraph 177 of the Framework states that in 'plan-making' it is important to ensure that there are reasonable prospects that development will be delivered.

Until alternative locations are found the delivery of housing on this site cannot proceed.

The deliverability of the allocation and the ability to deliver 700 new dwellings in a single location, is questioned on account that sites in multiple ownership require effective collaboration which is in not in place.

Any shortfall in delivery will need to be made up on site(s) at Kenilworth - not elsewhere within the District especially given the role that the town can play in helping to meet any residual housing requirement generated by Coventry. It is therefore submitted that land at Warwick Road is a wholly suitable site to meet any shortfall in housing delivery.

The Merits of Land at Warwick Road, Kenilworth:
Client's land at Warwick Road was considered as part of a much large parcel of land (K6) to the south of Kenilworth in the Joint Green Belt Review carried out by SSR Planning in 2009.

Client's land extends to just over 5hectares, a small proportion of the total area of land parcel'K6'.

The Joint Green Belt Review concluded that land parcel 'K6':-

* Contributed to preventing sprawl south of Kenilworth;
* There would be no potential for coalescence south of Kenilworth;
* Assisted in safeguarding the countryside from encroachment south of Kenilworth;
* Contributed to preserving the setting and special character of Kenilworth; and
* That retention as green belt would encourage recycling of derelict and other urban land.

The Land at Warwick Road:

* is visually well contained for the most part with topography and vegetation combing to restrict views from longer distances;

* would provide a logical urban extension to Kenilworth in order to remedy existing and foreseen shortfalls in housing delivery;

* its development will result in a relatively small section of Green Belt being lost to residential development;

* it will provide - through landscaping - a robust and a more defensible edge to the town, thus preserving the Green Belt in the long term.

* Will provide opportunities for land to be brought forward within the control of client for sports and recreation use.

* will not lead (as a result of release from Green belt) to the unrestricted sprawl of a large built up area. (Kenilworth is not a large built up area for the purposes of the West Midlands Green Belt which contains the spread of the conurbation).

* Its development will not adversely impact upon the setting and special character of Kenilworth as a historic town.

* The release of the site will not undermine urban regeneration within the settlement.

* would help meet the need for more housing within the District in a sustainable location.

It is acknowledged that the release of the land would necessarily result in the encroachment of undeveloped agricultural land. This is almost inevitable with development on greenfield land surrounding an existing settlement.

However, by identifying the land at Warwick Road the treatment of the edge of the urban extension could be better planned to result in a more defensible and long term barrier, built with an appropriate design to complement the transition from urban area to Green Belt and open countryside, building at a lower density and result in a viable development.