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Briefing Note on West Midlands RSS Phase Two Revision Panel Report

This briefing note has been prepared to advise on the Panel Report into the West Midlands Regional Spatial Strategy (RSS) Phase Two Revision.

The Government Office for the West Midlands has published the Report of the Examination in Public that was held earlier this year into the draft West Midlands Regional Spatial Strategy (RSS) Phase Two Revision. The Report sets out the findings and recommendations of the Panel of Inspectors who were appointed by the Government to chair the examination of the draft RSS and its proposed strategy for distributing and managing development in the region for the period up to 2026. This report is not being consulted on and the Council are not invited to make any comments on the report. It is there to inform the Government’s response to the draft RSS which it aims to publish by the end of the year. Their response and any proposed changes to the draft RSS will be the subject of public consultation for 12 weeks, likely to be early next year. A summary of the key issues arising from the Panel Report affecting Warwick District are as follows: The Panel have recommended that Warwick District should make provision for 11,000 dwellings for the period 2006 to 2026. This is marginally greater than the figure of 10,800 dwellings within the draft RSS and has been referred to by the Panel as a “rounding-up” of the figure. The Panel have not supported the views submitted to the examination by the Government Office for the West Midlands/Nathaniel Lichfield and Partners for an additional 10,000 homes to be found within the District. In addition, the Panel recommend that around 3,500 dwellings be within Warwick District adjacent to the City boundary to the south in the vicinity of Gibbet Hill/Finham. This potential “overspill” from Coventry was acknowledged within the draft RSS within the sub-regional strategy but was not defined in terms of its size or location. The draft RSS did, however, acknowledge that any “overspill” would be a “last resort” following urban extensions within the City Council administrative area, and phased later in the plan period. The Panel have given a lot of consideration to the issue of phasing within their report but have not entirely endorsed the strict approach of the draft RSS. They cite the need to ensure delivery of housing numbers, the long lead-in times for major urban extensions in terms of infrastructure provision (approvals and funding), and the need for commitment at an early stage if they are to deliver during the plan period. They do, however, acknowledge that growth around Coventry should be carefully managed to avoid undermining delivery of urban sites, and that sites north of Coventry (within Nuneaton) would be preferable for the first half of the plan period as it would relate better to the rail enhancement programme for that area of the north-south corridor, with growth to the south being more appropriate for the latter part of the plan period. The total recommendation therefore is 14,500 dwellings within Warwick District.The Panel’s specific findings and rationale is set out in Appendix One. The Panel have recommended that Warwick District should have a 30ha rolling five-year reservoir of employment land and an indicative long-term requirement of 120ha.It has also recommended the deletion of reference to 50% of the University of Warwick expansion contributing towards the five-year reservoir. However, it has also recommended that Core Strategy DPDs only need to identify a 10 year requirement (i.e. 60ha for Warwick District) and broad indications for longer term needs if necessary. These recommendations represent an increase of 30ha on the draft RSS long-term requirement. However, this figure is only indicative and the Employment Land Review undertaken for the Council identified a much lower requirement (circa. 80ha). The Panel have endorsed Warwick/Leamington as a Settlement of Significant Development, Leamington Spa town centre as a strategic sub-regional centre, and the indicative figures for comparison retail and office floorspace development within or adjoining that centre. The Panel have recommended updating of the policy for Coventry Airport in light of the recent planning refusals (paragraph 7.17 of their report). The Panel have also recommended the land for expansion of Warwick University be removed from the Green Belt (see Appendix One). The full report can be found at www.gos.gov.uk/gowm www.gos.gov.uk/gowm As noted above, Members are not being asked to comment on the Report.The next opportunity for the Council to engage in the RSS process will be in response to the Government’s Proposed Changes (likely to be early next year). Gary Stephens Planning Policy Team Leader September 2009 The Panel have commented as follows, firstly in relation to development south of Coventry and at Warwick University (paragraph 8.36 onwards): “Considering Coventry first as the MUA core of the sub-region, the housing provision figure of 33,500 was not challenged in an upward direction as it had been significantly increased during the preparation of the RSS Preferred Option when Coventry was accorded NGP Status. Moreover, the RSS acknowledges that the provision figure is likely to exceed the physical capacity of the City over the plan period necessitating cross-boundary development to the north in Nuneaton & Bedworth Borough and to the south in Warwick District. The Provision figure is 16,700 over the NHPAU suggested distribution of their upper range figure and 11,900 over the latest CCHPR need figure. Even allowing for the prospective cross-boundary provision it is clear therefore that Coventry taken in isolation would be providing a reservoir of capacity to meet the shortfall in the core of the West Midlands Conurbation and/or elsewhere in the CSW sub-region. Perhaps unsurprisingly NLP did not suggest any additional provision. In terms of the scale and distribution of any cross-boundary provision it was immensely helpful that there was clear agreement between the three local planning authorities that there should be 3,500 dwellings to serve Coventry immediately to the north of its boundary in Nuneaton & Bedworth district and 3,500 to serve Coventry immediately to the south of its boundary in Warwick District. Although there were issues raised over the release or non-release of Green Belt land within Coventry itself, we can see no reason to dissent from this agreed distribution and will recommend accordingly. CPRE argued that the Coventry figure should be reduced if the City is not capable of meeting its needs without recourse to cross-boundary development or indeed to Green Belt release within the City limits which was contrasted with the strategy applied to the central MUA core. Development interests also highlighted this difference in strategy but with essentially the opposite intent of seeking to justify urban extensions to the central core. We probed the justification for the difference and concluded that it was based upon the differential nature of the regeneration sought in Coventry and Nuneaton & Bedworth where many of the areas of PDL are peripheral as a consequence of recent mining and manufacturing history, and the bespoke strategy of seeking growth at least in the northern part of the sub-region on a north-south axis. On the southern edge of the City, Warwick District Council canvassed three prospective locations for the Coventry-related requirement at their Core Strategy Issues and Options stage, one to the southwest in the vicinity of Kirby Corner in the Westwood Heath area, another to the south-east in the vicinity of Baginton and finally one in the Gibbet Hill/King’s Hill/Finham area. We received representations from the University of Warwick, which is located in the general vicinity of the first of these options, that land for its expansion should be withdrawn from the Green Belt, a point agreed by the planning authorities. It is therefore perhaps unsurprising that additional general housing development in that locality did not make its way into the Preferred Option of the Warwick Core Strategy. Development interests canvassed the merits of land in the vicinity of Baginton, but the particular area explicitly highlighted (455/2) is very close to the Public Safety Zone at the south-west end of Coventry Airport’s runway. Again we can understand, given the controversies over the environmental impact of that airport, why the Baginton locality has not been taken forward. This leaves the central Gibbet Hill/Finham area. It was strongly opposed at the EiP by the Finham Residents Association but, we can see the strategic value in development in this locality on the north-south axis where it can be served by the upgraded Coventry-Kenilworth-Leamington rail line and would be well placed in relation to the University. Like the Keresley controversy, the detail of any such development should be for consideration in the relevant Core Strategy DPD.” In relation to phasing, the Panel commented that (paragraph 8.42)“The second point is in relation to phasing. We can appreciate the logic of seeking to develop PDL in advance of greenfield sites as a general principle and therefore why there are such references in the CSW section of sub-regional text. However, this is a general point applicable throughout the region, and is covered in Chapter 4 in our recommended approach to Policy CF4 and CF10. We are concerned that to elevate such phasing to sub-regional policy would be too rigid. The urban extensions should be linked to relevant infrastructure provision. Such provision often requires long-lead times both to carry through relevant consent procedures and to secure hybrid sources of funding. Thus, commitment to such extensions cannot necessarily be held back long into the plan period if the extensions are to contribute delivery at all in the plan period. Moreover, given the strategy for growth on a north-south axis, it is by no means obvious that any urban extensions wholly within Coventry will be more sustainable, and therefore deserving of higher priority, than those involving cross-boundary development. As we see it, a northern urban extension into Nuneaton and Bedworth would relate well in the first half of the plan period to the first phase of the rail enhancement programme with its new stations at Ricoh and Bermuda, while that to the south might fit well with later implementation of the second phase of those works with new stations at Gibbet Hill and Kenilworth in the second half of the plan period.” In relation to Warwick District’s provision, the Panel commented (Paragraph 8.49 onwards):we now turn to Warwick District. We have already addressed the issue of the cross-boundary 3,500 dwellings to be located south of the City in the Gibbet Hill/Finham locality and the need to make provision for the further development of the key economic asset of Warwick University by withdrawing the land for its expansion from the Green Belt. Textual amendments are also recommended in Chapter 5 to remove the inference that the development would be for business purposes rather than institutional development. With regard to the District’s own provision, this is the first authority in Warwickshire where a significant shortfall in proposed provision in the Preferred Option is indicated. The provision figure of 10,800 is 7,400 below the latest 2006 based CCHPR need figure. It is only half the NHPAU upper range suggested distribution figure. Perhaps unsurprisingly NLP recommended a substantial increase of some 5-10,000 dwellings and GOWM suggested an urban extension on the southern edge of Coventry. In effect the latter has been accepted by the authorities in the location proposed for 3,500 dwellings of the Coventry provision so that the Preferred Option would in fact be making provision for 14,300 dwellings in Warwick District. Development interests supported increases in provision arguing that the buoyant economy of the area warranted higher provision. In some instances they sought support from the SQW and Arup studies for AWM. We pressed AWM to explain the benefit in GVA terms indicated in the Arup study from higher housing provision in the south of the region, a point of even greater significance for Stratford-on-Avon District and some Districts further west. It seemed to us that all that the analysis was saying is that if you assume that future residents will have similar employment profiles to existing residents then these benefits will accrue. Large-scale employers were not necessarily being indicated that might be inhibited as a result of labour shortages. In the case of Warwick District there are specific high tech employment spin-offs from the University of Warwick and other sites on the fringes of Coventry and related to main towns. For the most part, however, AWM confirmed that in the southern Districts it is the residence of economically active persons who either commute long-distances or the home base of people in roles that may be nationwide or even worldwide that forms the basis for the assumed benefits. Such households are attracted by the environment and accessibility of these Districts and are not necessarily related to local employment. For Warwick District, the conclusion is that economic factors as well as past trends would indicate an upward pressure on provision and probably one of a significant degree. Conversely, however, the bespoke strategy of the CSW sub-region as well as the overall urban renaissance objective of the spatial strategy embodies a desired step-change in direction to accommodate more of Warwickshire’s requirements to the north of the County in and around Coventry. In the view of WMRA, CSW and the Council this justifies a lower provision in Warwick District than might otherwise have been anticipated in the light of past trends and economic buoyancy. With the University of Warwick straddling the Coventry City boundary and the Stoneleigh facilities near Kenilworth, it is evident that significant sources of the economic buoyancy of the locality do have roots towards the north of the District so that the strategy is not without a rationale over and above the desirability of securing renewal and renaissance of the urban fabric of Coventry and the more northerly towns. The journey to work pattern shows a complexity of movements, particularly into and out of Coventry. The District Council has taken its Core Strategy DPD work through to publication of a Preferred Option that would accommodate the RSS Phase 2 Preferred Option provision in addition to the 3,500 agreed provision for Coventry adjacent to its boundary that has already been detailed. The options considered elsewhere in the District included urban extensions south of Kenilworth as well as to its east within the Green Belt and options for urban extensions on almost all sides of Warwick/Leamington, a designated SSD under the Phase 2 strategy. Some of these, including land north of Milverton, would also be in the Green Belt, though most would be to its south. We received strong representations at the EiP from the Kenilworth Town Council against its outward expansion into the Green Belt as this would tend towards coalescence either with Coventry as proposed to be extended to the north or with Warwick/Leamington. Likewise we received representations from Warwick Society and Bishop’s Tachbrook Parish Council over the need to avoid swamping the historic town of Warwick and to avoid coalescence with nearby villages. The merits of various urban extensions to Warwick and Leamington were canvassed including those of land north of Milverton by Taylor Wimpey and land at Gallows Hill and more generally to the south of Leamington on behalf of clients of DLP, Barton Willmore and RPS. In total, the options that the Council canvassed would have provided for a higher total than sought under the Phase 2 Preferred Option. However, we would be cautious about the desirability of seeking to take all the option capacity into the RSS provision. The reasons given by the Council for discounting some sites in the Green Belt to avoid coalescence on the north-south axis of development and for not seeking the maximum possible from PDL within Warwick/Leamington in order to safeguard good quality employment land (in accordance with the views of AWM and as embodied in Policy PA6B) appear rational and not easy to disregard. Consequently, we recommend simply rounding up the required provision to 11,000 for the same reasons as at Nuneaton & Bedworth and Rugby. It needs to be remembered that this means that the actual provision required in the District would be 14,500, inclusive of the 3,500 for Coventry. We further recommend endorsing the requirement for Green Belt review to provide for the 3,500 dwellings adjacent to Coventry and for the expansion of the University of Warwick and indicating that further review of the Green Belt may be appropriate to enable the most sustainable form of development to be considered at Kenilworth and Warwick/Leamington in the Core Strategy DPD. The HA indicated that with the current improvement works at the M40 Longbridge Junction (15) and the possibility of junction improvements at other M40 and A46 junctions, such levels of development ought to be capable of realisation provided that local planning is appropriate and public transport improvements are carried through as proposed.”