Publication Draft

Object

Representation ID: 65654

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Objects to the approach to approach to duty to co-operate. The Council should be looking to meet all of its objectively assessed housing needs now and that includes any unmel need frorn adjoining Districts.

The approach adopted by the Council is in conflict with the NPPF and recent case law which requires the objectively assessed need to be met immediately and not deferred for another Plan period. To adopt such an approach is not planning positively as required by the NPPF.

Object

Representation ID: 66226

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

We support this policy in principle which seeks to provide in full the objectively assessed housing need for the District as well as any other housing needs for adjoining Districts etc. However, the Local Plan does not carry through this objective and does not meet its full objectively assessed housing need either for the District or indeed adjoining Districts.

Object

Representation ID: 66227

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to this policy which seeks to prioritise allocations to previously developed land before green field sites. We consider that as a basic principle the Local Plan should strive towards the most sustainable strategy that is available. This could entail the use of green field sites or even sites within the green belt, before previously developed land. At present it has not been demonstrated that this is the case as alternative strategies have not been thoroughly tested.

Object

Representation ID: 66228

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy DS6 is unsound because it is not based on the most up to date evidence and the housing requirement should be increased.

The Joint SHMA indicates that the annual housing needs for the District is between 660 houses per annum to 772 houses per annum. A mid range figure has been arrived at albeit it is unclear what justification exists for this figure.

The Council has provided no reasoned justification for selecting 718 dwellings per annum, especially as its housing requirement is considerably higher than this figure i.e. up to 900 dwellings per annum.
An increase in the overall housing provision would assist in meeting the high level of affordable housing need identified in the report. G L Hearn consultants recommend the provision of 268 dwellings per annum in supporting the stronger delivery of affordable housing.

The SHMA also does not identify un-met need in other housing market areas.

It is vitally important to consider inter relationships between neighbouring authorities and HMAs when formulating housing and development policie, in particular the housing needs of Coventry identified in the joint SHMA and that of Birmingham City Council's needs.

Object

Representation ID: 66231

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The objections to this policy should be read in conjunction with our objection to Policy DS6 'Level of Housing Growth'. The objection to Policy DS6 was on the basis that insufficient housing provision had been made to meet the housing needs of the District including adjoining districts. It must therefore follow that objections are made to this policy on the basis that the overall housing provision is too low. Furthermore, in meeting the housing requirement calculation it is important that the advice both in the NPPF and NPPG in respect of identifying the availability and deliverability of sites is followed. Whilst we reserve the right to comment on the detail of the calculation it is apparent that:

1. No allowance for the shortfall in housing provision pre 2011 is made;
2. The windfall allowance is excessive and not justified;
3. Potential double counting exists between windfall sites and small urban sites; and
4. Ensure that allocated sites are available and deliverable.

Object

Representation ID: 66236

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

There is a recognised and identified need for additional housing within the District not just to meet the District's housing needs but probably also those of adjoining Districts such as Coventry.

The Local Plan should and must provide the necessary certainty that those needs will be met. This can only be achieved if additional land is identified for housing development.

It is considered that in meeting the actual housing needs for the District (and perhaps those of adjoining Districts) that land currently within the green belt and particularly to the south of Coventry needs to be released.

Object

Representation ID: 66239

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Crest object to this policy which does not allocate land within their control at Lodge farm , Westward Heath Road, Coventry. These representations should be read in conjunction with those on duty to Co-operate and Policy DS6- Level of Housing Growth, Policy DS7 - Meeting Housing Requirements and DS1O Broad Location tor Development. As stated in our objection to the level of proposed development (Policy DS6) as well as Duty to Co-operate) there is a recognised and identified need for additional housing within the District not just to meet the District's housing needs but probably also those of adjoining districts such as Coventry. The Local Plan should and must provide the necessary certainty that those needs will be met. This can only be achieved if additional land is identified for housing development.

The Joint Green BElt Study (2009) concluded that the land is one of the least constrained parcels to the south of Coventry and potentially suitable to be released from the green belt.

The suitability of the site for development was identified within the SHLAA (May 2013). The site is available, suitable and deliverable.

It has been demonstrated that both the existing road network and schools have capacity to cope with the proposed development.

Object

Representation ID: 66240

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to this policy which does not remove land at Lodge Farm, Westward Heath Road from the green belt and allocate, the site for a housing led development in accordance with the Garden Towns principles.

These objections should be read in conjunction with those made in respect of Policy DS6 Level of Housing Growth and DS7 Meeting the Housing Requirement. As part of the preparation of the Local Plan, the Planning Authority has unde1taken a green belt review. The details of this are set out in the Coventry Joint Green belt Review (January 2009). The land in question was identified as site C14C (see attached). It was reviewed in relation o the 5 green belt functions identified in PPGJ 'Green Belts' (now paragraph 80 of the NPPF). This assessment concluded that the land is one of the least constrained parcels south of Coventry and potentially suitable to be released from the green belt.

Our representations in respect of the Policies identified above have concluded that the housing provision for the distric1 needs to be substantially increased. The Local Plan accepts in Policy DS 19 that land currently located within the green belt needs to be released to assist in meeting the housing requirement. Furthermore, this does not take into account land which needs to be released to meet the housing needs from adjoining Districts e.g. Coventry. We are firmly of the view that as the housing provision needs to be substantially increased and accordingly land within the green belt needs to be released as it is accepted within the Local Plan that there are insufficient brownfield sites or unconstrained green belt sites to meet the housing requirement. Accordingly, this site is ideally placed to be released for green belt. In accordance with our objections to Policy DS 11 that the site is available, suitable and deliverable in line with the SHLAA.

Object

Representation ID: 66242

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

This objection should be read conjunction with our objections to the 'Duty to Co-operate' . The NPPF requires that the Local Plan be positively prepared and to meet the fully objectively assessed housing needs not only for the District but also any unmet housing need from adjoining Districts. It is apparent that the Council anticipates that it will have to meet unmet housing needs from adjoining Districts (probably Coventry) in the future. In such circumstances, the Local Plan should be planning for this eventuality now and not to delay until a Local Plan review. Such an approach is contrary to the advice in the NPPF which seeks that Local Plans are 'positively prepared ' and ensure that Local Plan ' boost the supply of housing'.

Object

Representation ID: 66244

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

This objection should be read in conjunction with our representations on Policies DS2 -Providing the Houses the District Needs and DS6 level of Housing Growth.

Crest support the principle of this policy which indicates that the Local Plan will meet in fully for the objectively assessed need for housing in the District.

The unfortunate position is that the Local Plan fails in meeting this basic principal in that the objectively assessed needs are not met and accordingly the Local Plan does not comply with the NPPF's advice.