Publication Draft

Object

Representation ID: 66195

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The land at Baginton offers an exceptional opportunity to link housing to the employment growth proposed at the Warwick Gateway site and located on the periphery of Coventry City/CWLEP North South Corridor.

The site at Baginton/Coventry Gateway should be recognised by the Council as a sustainable site adjacent to the urban area and large-scale employment. It could accommodate a significant proportion of housing that would contribute towards the growth of Coventry and support the Gateway scheme, ensuring compliance with the NPPF in relation to the duty to cooperate, and should be allocated within the Local Plan.

Extensive technical assessments have been undertaken for
the site in relation to flood risk, noise, ecology, conservation and heritage and landscape, which have previously been submitted to the Council. These reports demonstrate that the site is suitable for a significant residential-led development either in isolation or in connection with proposals for the wider area.

While it is acknowledged that the site is within the Green Belt, the site contains no constraints that preclude development on the site.

The 2014 SHLAA maintains that there are noise and odour constraints, however, the Council has never presented RPS with any evidence that these exist. Conversely, RPS has provided evidence that they do not exist.

It is therefore concluded that the site is entirely suitable as defined for development in the promotional document appended.

Object

Representation ID: 66250

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? No

Sound? Not specified

Duty to co-operate? Not specified

RPS objects to the Council's approach in selecting strategic sites for development. It is not compliant with the requirement of the Strategic Environmental Assessment Directive or that of the Environmental Assessment of Plans and Programmes Regulations 2004.

The Council's reasoning for excluding Land at Baginton from previous consultations has been based upon assumptions for which the Council held no evidence. It is long established that all reasonable alternatives should be considered within the development plan and SEA/SA process, and that failure to do so is a matter of serious concern which can deem the Plan unlawful.

RPS contests that the Council has appropriately appraised this site and that no reason has been provided in any Environmental Assessment on why the land south of Coventry promoted by RPS has been excluded.

RPS therefore presents evidence that the Council has failed in its SEA/SA process to appraise Lenco Investments land south of Coventry as a strategic alternative alongside other reasonable alternatives, as well as a part of a smaller local village allocation. It has failed on two counts.

Object

Representation ID: 66251

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Council's proposals are woefully short on the number of homes required and fail to balance the level of housing and jobs provided within the strategy of the plan, or the core Objectives of it.

A key component of the above Objective and the Plan's Strategy is the Council's reference to balancing economic and housing growth. This is specifically referred to(paragraph 2.4 refers) in respect of balancing the number of jobs in the District and the working age population to boost economic development, and the supply of jobs. RPS fully supports this approach and the objective set out above as it is reflective of the NPPF.

However, having set out all of the above, the plan then fundamentally fails to deliver on the Strategy and Objectives it has set out.

The proposals in the plan fail to provide for the objectively assessed need for housing, but more importantly fail to balance the provision of homes and jobs as advocated by the authority as being a fundamental component of the Plan's strategy and policy framework. It
is therefore ineffective and unjustified.

Object

Representation ID: 66252

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

RPS objects to the Council's development strategy proposals set out in Section 2 of the Draft Plan, and principally how they are delivered through Policy DS1 Supporting Prosperity and Policy DS2 Providing the Homes the District Needs.

The Council's proposals are woefully short on the number of homes required and fail to balance the level of housing and jobs provided within the strategy of the plan, or the core Objectives of it.

Policy DS2 logically follows Policy DS1 which sets out that the authority will meet its full objectively assessed needs. RPS supports the general thrust and compatibility of these two policies.

The plan seeks to present a logical relationship between
balancing local housing and employment need, and gives the impression that these are in harmony. Yet Policy DS16 identifies employment land at the Gateway Site of sub-regional significance which is over and above its local employment requirements. RPS's objection is that the plan fails when considering the commensurate level of housing required, as no account of this major sub-regional employment location is taken in respect of the balance between of jobs and homes.

The proposals in the plan fail to provide for the objectively assessed need for housing, but more importantly fail to balance the provision of homes and jobs as advocated by the authority as being a fundamental component of the Plan's strategy and policy framework. It
is therefore ineffective and unjustified.