Publication Draft

Object

Representation ID: 66245

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Crest object to the proposed hierarchy in that it does not consider how unmet development needs from adjoining Districts can and should be met. It is highly likely that the District will have to accommodate some of the unmet housing needs from Coventry City. The Local Plan should consider how best such housing needs can be accommodated in a sustainable way.

It is concluded that these housing needs me best accommodated on land currently within the green belt to the south of Coventry. Where it has been recognised previously that Coventry's housing needs could not be met land to the south of Coventry partly in the green belt have been identified for release. Crest control land at Lodge Farm, which is immediately available to accommodate additional housing development the Joint Strategic Green Belt Study confirmed that the land had potential to be released from the green belt.

Object

Representation ID: 66246

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Objections are lodged to the proposed 40% affordable housing provision. This is contrary to the evidence which concludes that 35% affordable housing is a viable level. The purpose of the Plan led system is to provide certainty to developers, landowners etc. If the Council ignore their own evidence and adopt a higher threshold for affordable housing, there will be no guarantee that they would adopt a flexible approach once the 40% threshold was adopted.

This approach is totally contrary to the guidance in the NPPF which requires that viability of affordable housing and other policy requirements of the plan are deliverable and to ensure that these do not render development unsuitable and thus that plans undeliverable. The onus should not be placed on the developer to provide viability but for the Council to ensure that viability has been assessed when arriving at the initial figure for affordable housing within policy. This is in line with the NPPF but also the decision in Blyth Valley DC v Persimmon Homes (North East) limited (2008).

Concerns are also expressed at the content of the viability assessment which underpins the affordable housing policy. It considered that either a number of costs have not been taken into account e.g. biodiversity offsetting, flood mitigation etc or that the figures included within the viability assessment are too low e.g. planning contributions.

Object

Representation ID: 66247

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

It would appear that the justification for this site is to better connect the village. However, it is unclear how this will be achieved with the proposed HS2 railway line running to the north of this site and thus segregating the settlement. In such circumstances, the justification for this allocation is flawed.

It is noted that the Crest site was discounted due to high landscape impact concerns and potential access difficulties (i.e. *-Appendix 6 Site Appraisal matrix). Both of these objections are incorrect. As stated in previous representations: -(see Summary of Findings)

i) Access can be achieved to the requisite standard to service the site. Furthermore, the County Council previously assessed the potential traffic impact in their Traffic Flow Model System. That work included that there would be no problems in terms of traffic impact from a residential development of 880 dwellings.

ii) With regard landscape impact the SHLAA concluded that with satisfactory mitigation the site could be developed within no adverse impacts.

Crest therefore strongly object to the conclusions reached in respect of their land at Lodge Farm which are incorrect and do not take into account the actual evidence.