Proposed Modifications January 2016

Object

Representation ID: 69596

Received: 21/04/2016

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Clear from Council's own assessment that adjustment for affordability not applied correctly. FOAN for Warwick district cannot be relied upon until this component of housing need is re-evaluated.
Council has not correctly accounted for the figures within this document and as a consequence, will not be able to meet need from within the District in addition to unmet needs from Coventry.
Council's approach applies 18 year plan period to 20 year need from Coventry, reducing figure from 6,640 to 5,976. This presents a shortfall of 664 dwellings that will not be met outside of Warwick, thus leaving Coventry's needs unmet.

Object

Representation ID: 69598

Received: 21/04/2016

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Two urban extensions for Coventry not justified or supported by work undertaken
No certainty of delivery within plan period
Strategic sites proposed do not appear to bear any relation to the strategic employment growth proposed as part of the Coventry Gateway site.
Number of constraints for both of the identified sites
Land ownership around Kings Hill not represented by consortium.
Issues around access and highways, including need for new link road
Areas subject to flood risk

Object

Representation ID: 69599

Received: 21/04/2016

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Welcome the objective behind this policy, though the mechanism for implementation needs to be adjusted.
New evidence could be presented not long after adoption that would leave the Council rethinking its approach and potentially be left with a document that is out of date. Preferable to include provisions within the policy that introduces additional flexibility e.g. as undertaken in Stratford recently.
Council should seek to include a similar approach as part of the Local Plan, which would be consistent with paragraph 182 of the NPPF, introducing an effective and positively prepared strategy.

Object

Representation ID: 69601

Received: 21/04/2016

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Unconvinced that the Council has correctly identified the quantum of land required around south Coventry, or identified the sites to support such a policy approach.
Efficacy of this policy is contingent on the land that is earmarked to be removed from the Green Belt. The strategy is not positively prepared, justified or effective against the provisions of paragraph 182 of the NPPF.
Additional sites are required around Coventry, in order to pursue the most appropriate strategy for growth and to give certainty that the Green Belt, as amended, will endure beyond the plan period.

Object

Representation ID: 69603

Received: 21/04/2016

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Makes little change to overall spatial strategy for District, amending it to indicate a preference for greenfield sites that are on the edge of 'built up' areas, instead of 'urban areas'.
Council's strategy doesn't address significant changes to the strategy proposed in modifications, the shift to accommodate unmet need from Coventry.
Council have subsequently agreed an MoU on meeting unmet Coventry Need - this results in substantial figure that should contribute to discussions on distribution.

Object

Representation ID: 69604

Received: 21/04/2016

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Any additional need identified for Coventry should in the first instance be met in locations which are well located to Coventry and options for growth tested on this basis.
Council has not proposed any additional changes to its spatial strategy other than minor amendments to the text. This does not respond to the requirements of Paragraph 182 of the NPPF, which requires that the strategy for growth is justified and effective and capable of delivering sustainable growth. It is considered that as currently drafted, the strategy is unsound