Proposed Modifications January 2016

Object

Representation ID: 69803

Received: 22/04/2016

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Suggested rewording is too general and 'outside the district' can mean anywhere

Object

Representation ID: 69804

Received: 22/04/2016

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Not sound

Object

Representation ID: 69806

Received: 22/04/2016

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

See proposed changes to text in original 'full text' for details

Object

Representation ID: 69807

Received: 22/04/2016

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

New table proposed regarding the level of housing growth and distribution - see original text

Object

Representation ID: 69810

Received: 22/04/2016

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The proposed replacement paragraph fails to explain, clearly or otherwise how the proposed level of housing was arrived at.
By what strategy does the asserted unmet need in Coventry robustly establish why that needs to be increased by 332 dwellings or 55.33%, the highest contribution to Coventry's unmet need in any of the shire districts.
The Shadow Economic Prosperity Board misinterpreted the GL Hearn report when setting the total housing need for the HMA that should have been 4,277 dpa but which became, for no explained reason to be 4,408.
There is nothing in the Memorandum of agreement that sets out a formal strategy. This is a very important matter as it results in 2,538 additional sites to be found in Warwick District on what was already a very high figure.

The original text contains suggested amendments to the figures to reflect an overall reduced need including for Coventry.

Object

Representation ID: 69820

Received: 22/04/2016

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The table to the policy is more than 12 months out of date as it only records completions between April 2011 and March 2015.
BTPC has been keeping an updated record of all compliant planning approvals given and building regulations data that has been deposited and recorded starts and completions. These include applications that do not need planning approval as they are permitted developments but nevertheless need to comply with building regulations and that produce additional dwellings (a copy is attached).
Rather than 1,483 completions, at least 2,200 completions are known to have occurred since 1st April 2011 to date. This compares with the DCLG household projection for mid-2016 that was 2,599 completions may be required and the actual number of completions required to meet the 2013 and 2014 mid-year population estimates converted to completions of 2,050 by mid-2016.

The original full text includes tables to illustrate.

The final numbers show that even if the maximum figure of 16,776 goes ahead, there are 1,281 sites more than needed to provide for both Warwick District and Coventry's unmet need.
Within the modified plan there are many references to providing sites for Coventry's unmet need immediately adjacent to Coventry. Without any further planning grants there are already 9,418 sites, either not started, started or complete to meet Warwick's FOAN of 10,800 sites.
The conclusion is that since all the Warwick FOAN is fully planned and available and there are sufficient sites around Coventry and the north of the District to meet Coventry's unmet need, then there is no further need to include any more sites than the 5,415 sites south of the towns.

Object

Representation ID: 69823

Received: 22/04/2016

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The reference to the spatial strategy does not correctly reflect the sites that are allocated in the plan of 9369.

The original text explains suggested changes needed to the figures.

The trajectory in Appendix A seems very optimistic. It shows housing completions of 1800 dpa in 2021, which since the modified local plan won't be approved until 2017.
It would be sensible to have 2 trajectories, one for Warwick and one for Coventry.
Also a separate 5 year housing land supply because if combined, Warwick will never have a 5 year supply and there will be no control over speculative applications. It means that Coventry will find it has become easier to meet its 5 year housing land supply having exported a large part of its problem to neighbours.

Object

Representation ID: 69824

Received: 22/04/2016

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Revise table

Object

Representation ID: 69830

Received: 22/04/2016

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The land south of Warwick. Leamington and Whitnash has provided 5,415 sites to the total needed for the Warwick OAN of 10,800 already, and
given the acceptance in various parts of the modified local plan proposals that housing needed by Coventry residents should be located adjacent to the city or as close as possible, and
there is overprovision in the plan of between 3646 and 1288 sites whilst still meeting the FOAN of the HMA there is no case to support the loss of further rural/countryside, south of Harbury Lane/Gallows Hill.
The following sites should be removed in both the draft local plan and modification additions as they are not necessary, environmentally sustainable nor consistent with NPPF protection and enhancement of valued landscapes.
1. H02(part) Former sewage works, south of Harbury Lane..
1. the site is immediately adjacent to the proposed country park, and the country Park was reduced in size in January last year from the original proposals; and
2. the retention of this site in the housing programme is no longer needed as the required housing has or is being provided elsewhere,
The best use for this site is to add it to the country park.
2. H13 Soans site, Sydenham Drive.
Note that the planning application granted was for 143 dwellings not 147.
3. H02(part) Land south of Harbury Lane (Excluding former sewage works)
Described as 620 (plus 985 included in commitments). This description is out of date as the commitments are - Lower Heathcote 785, Grove Farm 1 for 200 and Grove Farm 2 for 520 giving a total of 1505. The proposal is for 1605, increasing the housing by 100. It appears that this is to be added to Lower Heathcote, not Grove Farm by omitting the playing field area and building 100 houses on the land. However, these are no longer needed.
4. H46A Gallows Hill
This is allocated for 630 dwellings. The appeal allowed by the Secretary of State was for 450 dwellings, but it seems the District Council is not prepared to set a plan that limits development to that which is needed. The plan does not show the line of the site that has been allowed on the map. The Asps development was careful to keep away from Banbury Road by retaining fields as part of the special entrance to the Historic Town of Warwick. The same philosophy should apply here.
H49 Bishops Tachbrook Seven Acre Close.
5.1 This site has been allocated for 30 dwellings without any reference to the Parish council or cognisance for the draft Neighbourhood Plan that has gone through the consultation processes and is now to go to the examiner.
5.2 The District Council approved the Village Housing Options and Settlement Boundary Consultation report in November 2013. This site was considered in the sites review for Bishop's Tachbrook but was discounted in favour of H23, which could be enlarged from 75 to 150. The Neighbourhood Plan Team found that the village had a deficit in recreational land and this site should be considered for recreational community space.
The community would expect that these matters would be given considerable weight given the progress now achieved with the Neighbourhood Plan.
5.3 An outline application for 125 dwellings on Land south of Mallory Road was refused by the District Council on 26/02/2014 and a subsequent appeal was dismissed by the planning Inspector.
6. These 4 sites are to provide 525 dwellings. As has been shown in the table in Mod 6, there is overprovision for combined Warwick/Coventry if the Hearn update report is adopted and more if Coventry can produce more within its boundary. The omission of these 4 sites from the plan would not jeopardise the soundness of the plan but would mean that sites are provided in the right place to meet identified needs.

Object

Representation ID: 69831

Received: 22/04/2016

Respondent: Bishop's Tachbrook Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Correct 147 dwellings to 143
2.46 Omit in the light of our representations in Mod 10.
2.49 Revise in the light of our representations in Mod 10.