Revised Development Strategy

Object

Representation ID: 55421

Received: 13/08/2013

Respondent: Catseby Estates Ltd

Agent: Framptons

Interim Housing Figure:
The Revised Strategy is adopting an interim figure of 12,300 homes over a plan period extending to 2029.

This may be revised pending the findings of the Joint SMA and the resulting co-operation between authorities.'

It should not be assumed that the potential revision may be required only in response to the outcome of the Joint SMA.

The RDS contains no robust evidence as to how the proposed interim level of housing satisfies the requirements of paragraph 47 of the Framework, especially when the Government is 'committed to securing economic growth in order to create jobs, and prosperity, building upon the country's inherent strengths, and to meeting the twin challenge of global competition and of a low carbon future' (Framework para 18).

It is submitted that the RDS would, if submitted for Examination, fail all tests of soundness set out at paragraph 182 of the Framework.

Housing provision arising from the housing needs of Coventry

Following the Inspectors comments on the recent Coventry Core Strategy Examination regarding the soundness of the City's housing target, a Joint SHMA is being undertaken.

The outcome of the SHMA prepared pursuant to the guidance at paras 178 - 181 of the Framework may be a requirement for a spatial response from within Warwick District to address the shortfalls within Coventry City to meet its housing requirements quantitatively and qualitatively.

Coventry City has recognised for some period of time that it is not able to provide sufficient housing choice in location of housing land, particularly in the form of 'aspirational housing' to support the drive for inward investment and economic growth in the city.

Kenilworth is well placed to accommodate some of this additional housing need, particularly in view of its proximity to Coventry, and transportation connections - road and shortly rail.

It is understood that the rail station at Kenilworth should be open by the end of 2016 (Patrick McLoughin, Secretary of State for Transport 3rd June 2016).

If it is assumed that an adopted Local Plan is achieved by the end of 2014, the Kenilworth station might reasonably be anticipated to be operational within 12 months of new homes being provided on this site.

In conclusion it is submitted that this site could usefully provide a contribution to housing requirements arising from the needs of Coventry which cannot be met within the administrative area of the city.

Additional housing provision at Kenilworth would also be well related to the now committed development at Coventry and Warwickshire Gateway.

. 4) The provision of land to meet possible future development needs beyond the plan period (Safeguarded Land) Paragraph 85 of the Framework states (second bullet point): 'When defining boundaries, local planning authorities should: * not include land which it is unnecessary to keep permanently open.' In that it is evident the strategy of the emerging Local Plan requires the release of land from the Green Belt to achieve sustainable patterns of development, it is almost inconceivable that a future strategy will not similarly require further releases of land from the Green Belt. In order to make provision for longer term development needs, this Local Plan should identify 'Safeguarded Land'. If contrary to the submissions that have been made above, it is concluded that this site is not required to meet housing needs arising from within the plan period, then it is submitted that the site should be excluded from the Green Belt to meet possible future development requirements beyond the Plan period.

Object

Representation ID: 60190

Received: 13/08/2013

Respondent: Catseby Estates Ltd

Agent: Framptons

The provision of land to meet possible future development needs beyond the plan period (Safeguarded Land):

In that it is evident the strategy of the emerging Local Plan requires the release of land from the Green Belt to achieve sustainable patterns of development, it is almost inconceivable that a future strategy will not similarly require further releases of land from the Green Belt.

In order to make provision for longer term development needs, this Local Plan should identify 'Safeguarded Land'.

If contrary to the submissions that have been made above, it is concluded that this site is not required to meet housing needs arising from within the plan period, then it is submitted that the site should be excluded from the Green Belt to meet possible future development requirements beyond the Plan period.

Object

Representation ID: 60192

Received: 13/08/2013

Respondent: Catseby Estates Ltd

Agent: Framptons

Submissions made on behalf of Catesby Estates Ltd in respect of the land edged red, at Oak Farm, Rouncil Lane, Kenilworth.

The RDS does not satisfy the tests of soundness in that it has not been (NPPF para 182):
* Positively prepared
* Justified
* Effective
* Consistent with national policy

The revocation of the regional strategies has brought a responsibility for local planning authorities when preparing development plans to make adequate provision for housing (and other development) needs.

Para 47 of the NPPF requires LPAs to [inter alia]:

* rapidly address the problems of housing delivery in view of the adverse social and economic effects that are brought about where inadequate land for housing is provided; and
* increase the buffer to 20% (moved forward from later in the plan period) (emphasis added) to provide a realistic prospect of achieving the planned supply and to ensure choice and competition in the market for land (Where there has been a record of persistent under delivery of housing)

In order to significantly boost housing land supply the Plan should identify a broader range of housing sites, which are free from technical and environmental constraints, and where house builders are keen to build new homes early in the plan period.

The land identified off Rouncil Lane is free of constraints that might preclude the early delivery of new homes, other than the policy constraint imposed by the Green Belt.

It is evident that the housing strategy for the number of houses presently proposed in the Local Plan relies upon some provision of land from the Green Belt.

As such the exclusion of this site from the Green Belt does not raise a fundamental matter of principle, whether land from the Green Belt is required.

Rather the issue is the amount of land that should be released from the Green Belt in order to ensure that the housing policies in the Local Plan are sound and predicated upon a robust evidence base.

It is submitted that the release of this site is justified in order to contribute to the housing needs of the District in the early part of the plan period.

It is acknowledged that development would result in 'an encroachment into the countryside'.

However in order to meet development needs which cannot be satisfied from an existing urban area such as Kenilworth, this consequence has to be accepted.

It is submitted that the release of this site from the Green Belt would not harm any other purpose for the inclusion of land within the Green Belt (Framework para 80).

A sustainable pattern of development would be achieved that is consistent with the guidance set out at paragraph 84 of the Framework.

The extended edge of the urban area would become the defining boundary of the redrawn Green Belt, and clearly recognizable. 'Permanence' will be provided by the application of Green Belt policy for the surrounding land.