Homes England Whitley Pumping Station, Coventry Planning ......Land at Whitley Pumping Station Planning Statement 1 1.0 Introduction 1.1 Application Overview 1.1.1 WYG has been instructed

Birmingham 3rd Floor, 54 Hagley Road, Edgbaston, Birmingham, United Kingdom, B16 8PE

Tel: +44 (0)121 516 5320 Email: [email protected] Website: www.wyg.com WYG Environment Planning Transport Limited. Registered in England & Wales Number: 03050297

Registered Office: 3 Sovereign Square, Sovereign Street, Leeds LS1 4ER.

Homes England

Whitley Pumping Station, Coventry

Planning Statement

Land at Whitley Pumping Station Planning Statement

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Document control

Document: Planning Statement

Project: Whitley Pumping Station

Client: Homes England

Job Number: A112428-8

File Origin: S:\Job Folders\Homes England & HCA\A090070-573 - Whitley Pumping

Station, Coventry\20. Planning Statement

Revision: 2

Date: October 2020

Prepared by Checked by Approved By

M Stanley J Rowley M Walton

Land at Whitley Pumping Station Planning Statement

www.wyg.com creative minds safe hands

Contents

1.0 Introduction ......................................................................................................................... 1

2.0 Site Location and Description ................................................................................................ 5

3.0 Summary of Proposed Development ...................................................................................... 8

4.0 Planning Policy and Legislative Context ................................................................................ 12

5.0 Planning Assessment .......................................................................................................... 25

6.0 Technical Assessment ......................................................................................................... 33

7.0 Planning Obligations ........................................................................................................... 42

8.0 Summary and Conclusion…………………………………………………………………………………………………44

APPENDICES

Appendix 1 – EIA Screening Opinion

Appendix 2 – Pre-application Letters (dated 24th July 2020)

Appendix 3 – Waste Strategy Plan (Reference: A112428-8 WSP-01)

Appendix 4 – Separation Distance Plan (Reference: A112428-8 SDP-01)

Land at Whitley Pumping Station

Planning Statement

1

1.0 Introduction

1.1 Application Overview

1.1.1 WYG has been instructed by Homes England to provide planning consultancy advice and

subsequently prepare and submit a hybrid planning application for residential development at

land at Whitley Pumping Station, Coventry.

1.1.2 The description of development for the planning application is as follows:

1.1.3 “Hybrid planning application comprising:

Outline application (with all matters reserved except access): Erection of 195 dwellings, new

vehicular access onto London Road, public open space, drainage, landscaping, car parking areas

and other works.

Full application: Renovation of the existing Lodge, conversion of the existing Pump House to

create 4.no apartments, access road from London Road and associated landscaping and open

space”

1.1.4 The Application Site, known as land at Whitley Pumping Station, is identified on the submitted

Site Location Plan (Reference: A112428-8 SLP-01 RevA_HE). The Site consists of greenfield land

which predominantly comprises rough grassland, scrub and trees. Also on the Site are two

disused Victorian buildings which comprise the former Whitley Pumping Station building and the

Lodge.

1.1.5 The Application Site, along with the adjoining land to the north, forms part of an allocation for

residential development within Policy H2 of the adopted Coventry City Local Plan. The land to

the north, known as ‘Land at Allard Way’, is in the ownership of Coventry City Council and will

be subject to a separate outline planning application for residential development of up to 125

dwellings. The submission of the application for ‘Land at Allard Way’ will be submitted shortly

after this hybrid application.

1.1.6 Homes England have worked collaboratively with Coventry City Council throughout the design

process to ensure the whole housing allocation H2:9 is brought forward comprehensively.

Separate illustrative masterplans have been prepared to demonstrate the development capacity

of each site. Notwithstanding this, the sites have been designed to function separately in terms

of access and drainage, and the design process has ensured that the design proposals are

complementary and visually integrated.

1.1.7 This application submission is split into two elements; the conversion of the former Pump House

and renovation of the Lodge in the centre of the site and accessed via the existing entrance to


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the Site on London Road, which is submitted in full; and the residential development of the

remainder of the Site to the north and south, which are submitted in outline at this stage.

1.2 The Applicant

1.2.1 This hybrid planning application is made by Homes England, who are the government’s housing,

land and regeneration agency, and the regulator of social housing providers in England. Their

vision is to create successful places with homes and jobs, with a focus on investment and

regulatory activity to helps increase housing supply and economic growth and create homes

and jobs that meet the needs of local communities. The focus of their regulatory activity is on

governance, financial viability and value for money to maintain lender confidence and protect

social housing assets, the taxpayers’ investment, and the tenants who live in them.

1.2.2 Homes England’s priorities are as follows:

• Bring surplus public land to the market to drive housing growth;

• Support local economic growth through the development of assets;

• Deliver the Affordable Homes Programme targets;

• Increase private sector housing starts through equity, loans and other market

interventions;

• Maintain investor confidence in the affordable housing sector through effective

regulation;

• Work with our local and national partners to ensure effective alignment of resources

and activity;

• Further develop Homes England, our innovative, flexible and commercial approach and

our people so that we continue to deliver public value and can respond to future

challenges.

1.3 Pre-Application Discussion and Engagement

1.3.1 The Applicants have undertaken a consultation and engagement exercise with stakeholders and

the local community as part of the pre-application process. Further details regarding the pre-

application engagement is set out in the submitted Statement of Community Involvement (SCI).

1.3.2 Previously, a request for pre-application advice was submitted to Coventry City Council by

Homes England, in respect of the residential development of their land at Whitley Pumping

Station, and a formal written response was issued on 7th September 2018.


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1.3.3 Following the commission of WYG, a further request for pre-application advice was submitted

to the LPA with a comprehensive illustrative masterplan for the residential development of

Homes England’s land at Whitley Pumping Station and Coventry City Council’s land to the north

at Allard Way on the 5th March 2020. Pre-application advice was subsequently issued on 24th

July 2020. The pre-application advice received is attached in Appendix 2.

1.3.4 Since receiving the pre-application advice, the illustrative masterplan has been updated to

address comments from the Council’s Tree Officer, in order to retain additional trees where

possible.

1.3.5 Separate pre-application discussions and meetings have been held between WYG and Coventry

City Council’s Highway Authority, Lead Local Flood Authority and Ecologist as part of the evolving

masterplan for both Land at Whitley Pumping Station and Land at Allard Way.

1.3.6 A virtual public exhibition and consultation was undertaken presenting the development

proposals for both Homes England and Coventry City Council’s land were presented to local

residents was available online between 21st September and 4th October, with the opportunity to

provide comments and feedback via an online feedback form.

1.4 EIA Screening Opinion

1.4.1 An EIA screening request was submitted to the LPA for the proposed development on 31st

October 2020. A Screening opinion (reference: SCR/2019/2792) was issued by the LPA on 17th

January 2020, confirming that an Environmental Statement would not be required as part of the

planning application. A copy of the LPAs response is attached in Appendix 1.

1.5 Scope of Submission Documents

1.5.1 The planning application is accompanied by the following supporting documentation, which

should be read in conjunction with this supporting Planning Statement. The application package

has been agreed with the LPA during pre-application discussions.

• Completed Planning Application Forms and Certificates;

• Supporting Architectural drawings (including illustrative masterplan, landscape

drawings, and detailed conversion and renovation plans for Lodge and Pump House);

• Planning Statement (including planning merits, policy overview and S106 Heads of

Terms);

• Design and Access Statement;


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• Statement of Community Involvement;

• Transport Assessment;

• Framework Travel Plan;

• A suite of ecology reports;

• Tree Survey and Arboricultural Impact Assessment;

• Phase 1 – Geo-Environmental Report;

• Heritage Statement;

• Archaeological Desk Based Assessment;

• Landscape and Visual Impact Assessment;

• Noise Assessment;

• Air Quality Assessment;

• Lighting Assessment;

• Flood Risk Assessment and Drainage Strategy;

• Sustainability Assessment;

• Health Impact Assessment;

1.5.2 This report is structured to provide a description of the Site, surroundings and planning history

(Section 2); an outline of development proposals (Section 3); a review of the applicable planning

policy (Section 4); an analysis of the planning and technical issues (Sections 5 & 6). In the final

sections (Sections 7 and 8), we have set out our conclusions on the weight that should be given

to relevant planning polices and guidance in the planning balance.


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2.0 Site Location and Description

2.1 Site and Surrounding Context

2.1.1 The Application Site (‘the Site’ hereafter) for the proposed development is shown edged in red

on the submitted Site Location Plan (Reference: A112428-8 SLP-01 RevA_HE) and comprises

circa 9.03 hectares of land within the ownership of Homes England.

2.1.2 The Site falls within the administrative boundary of Coventry City Council, and is located within

the east of Whitley, approximately 2.3km to the south east of Coventry City Centre. London

Road (B4110) runs along the western boundary of the Site, adjoining Allard Way to the north

and Stonebridge Highway to the south, both at roundabout junctions.

2.1.3 The Site consists of greenfield land which predominantly comprises an area of rough grassland,

scrub and trees. The Site also contains two disused Victorian buildings which comprise the

former Whitley Pumping Station building and the Lodge.

2.1.4 The Site was previously owned by Severn Trent Water and historically was used for the

extraction of water. The land is heavily vegetated in parts with a former water pumping station

that sits in the middle of the Site, a former lodge at the entrance (both of which are locally

listed); and associated underground pipe work. The Site also includes the former underground

reservoir associated with the pumping station – an application has recently been approved for

the remediation works associated with the removal of the reservoir and infilling the adits

(planning reference: FUL/2019/1675).

2.1.5 Within the site the land slopes in a south easterly direction towards the River Sowe. Levels fall

from 86m AOD on the site’s northern corner to 65m AOD along the Southern Area’s eastern

edge adjacent to the river corridor. Within the Southern Area, areas of level ground are present

by the pumping station and access track. A raised area of land at 78m AOD is present on the

western extent of the Southern Area (to the south of the gate lodge and access track) where a

covered reservoir associated with the former pumping station is located.

2.1.6 The River Sowe forms the eastern boundary of the site beyond which lie recreation fields, a

primary school, police station and residential areas of Willenhall. The wider area is

predominantly residential in nature. To the south and west on the opposite side of the B4110

London Road lie further residential areas of Whitley.

2.1.7 The eastern part of the Site is located within the River Sowe Local Wildlife Site, equating to

approximately 2.5 hectares. Although the Local Wildlife Site falls within the red line boundary,

there will be no build development within this area of the Site.


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2.1.8 The Government’s online ‘Flood Maps for Planning’ identifies that the majority of the Site is

within Flood Zone 1 and has the lowest probability of flooding from all sources. The River Sowe

borders the Site to the east and flood risk in proximity to the river is higher, as shown on the

figure below. It is also confirmed by ‘Flood Maps for Planning’ that the majority of the Site also

has very low risk of surface water flooding. Further details can be found in the Flood Risk

Assessment submitted in support of this application.

(https://flood-map-for-planning.service.gov.uk/summary?easting=435661&northing=277029)

2.1.9 The Site is not located within a Conservation Area and there are no designated heritage assets

within the extent of the Application Site. The nearest statutorily listed buildings are located over

650m from the Site. The two existing buildings on the Site (the Lodge and Pumping Station) are

locally listed, and as such are considered to be non-designated heritage assets.

2.2 Connectivity

2.2.1 The Site is located within Whitley, which forms part of the wider built-up area of Coventry and

is located approximately 2.3km to the south east of Coventry City Centre. The Site is also

adjacent to the wider strategic highway network with London Road immediately west of the Site

linking with the A46 to the south and A444 to the north. The roundabout junction between

London Road (B4110) and Allard Way (A4082) is located at the north western boundary of the

Site.

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2.2.2 To the west of the Site, there are a number of bus stops located on London Road serving the

existing residential area of Whitley. The nearest bus stops to the existing site access are located

approximately 160m and provide regular services to Coventry, Bell Green, Tile Hill South,

Gosford Green, Kirby Corner (northbound) and Willenhall, Toll Bar End, Longford (southbound)

(Bus route No.s 21/60/112/580).

2.2.3 There are continuous footway connections on the eastern side of London Road adjacent to the

Site.

2.2.4 The closet railway station to the Site is Coventry Rail Station approximately 2.7km to the north

west. Coventry Rail Station is served by Avanti West Coast, CrossCountry and West Midlands

Trains and operate direct services to, inter alia; Birmingham, London, Glasgow Central,

Manchester and Bournemouth. At peak times, there are 5 trains per hour connecting Coventry

to London Euston. There is a multi-storey car park facility at Coventry Rail Station.

2.2.6 The Site is considered to be located within a highly sustainable location which has access to a

range of transport modes. Further details of the site accessibility are set out within the

accompanying Transport Assessment submitted in support of this application.

2.3 Planning History

2.3.1 A planning history search has been undertaken via the Council’s online public access facility,

and the following applications were identified in relation to land at Whitley Pumping Station:

Planning Reference Description Decision Date of decision

S/1949/0979 The construction of an

office block

Approved 10/08/1949

S/1966/1295 Erection of single storey

building to house

Electrical Switchgear

Approved 08/09/1966

S/1973/1586 Use of land as a football

pitch and erection of

four floodlights

Approved 23/01/1973

S/1976/1153 Erection of a garage Approved 27/01/1976

S/1978/0881 Construction of pitches

and alterations to form

changing rooms

Approved 02/08/1978

S/1987/1316 Use of part of Pumping

Station building as

Sports and Social Club

Approved 12/02/1987

L/1989/0113 Erection of free standing

booster station

Approved 10/03/1989

FUL/2010/1836 Proposed re-use of

former Whitley Pumping

Approved 14/02/2011


Planning Statement

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Station (in part) to form

4 No. apartments,

demolition of existing

pumping house and

associated structures,

provision of 2 No.blocks

of 3 storey apartments

with associated car

parking and

landscaping.

P/2019/1675 Site works and

reclamation of land at

the former Whitley

Pumping Station,

London Road, Coventry

including grouting of the

adit, infilling of the well

and borehole to the

pump house and

demolition of the

covered reservoir

Approved 02/10/2019


Planning Statement

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3.0 Summary of Proposed Development

3.1 Introduction

3.1.1 The planning application submitted proposes the redevelopment of the Site for:

“Hybrid planning application comprising:

Outline application (with all matters reserved except access): Erection of 195 dwellings, new

vehicular access onto London Road, public open space, drainage, landscaping, car parking areas

and other works.

Full application: Renovation of the existing Lodge, conversion of the existing Pump House to

create 4.no apartments, access road from London Road and associated landscaping and open

space”

3.1.2 The planning application is supported by an illustrative masterplan (Reference: A112428-8

IMP02-HE RevA) and detail drawings for the renovations and conversion of the existing buildings

comprising the former Pumping Station and Lodge, prepared by WYG. A Design and Access

Statement, and a suite of technical reports are also submitted in support of this planning

application providing a description of the proposals in respect of the technical aspects.

3.1.3 Homes England have worked collaboratively with Coventry City Council throughout the design

process to ensure the whole housing allocation H2:9 is brought forward comprehensively.

Separate illustrative masterplans have been prepared to demonstrate the development capacity

of each site. Notwithstanding that the sites have been designed to function separately in terms

of access and drainage, the design process has ensured that the design proposals are

complementary and visually integrated.

The Masterplan

3.1.4 The Application Site covers an area of 9.04 hectares and is split into two elements. A total of

200 dwellings are proposed as part of this hybrid application, and the Illustrative Masterplan

(Reference: A112428-8 IMP02-HE RevA) demonstrates the accommodation of these dwellings,

open space and access roads within the site area.

3.1.5 The first element is a full application for the restoration and conversion of the Pumping Station

and Lodge building to provide 4 No. apartments and 1 No. dwelling and associated access and

public open space.


Planning Statement

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3.1.6 The second element is an outline application for the remainder of the Site, which comprises up

to 195 new residential dwellings, new vehicular access from London Road, public open space,

drainage, landscaping, car parking areas and other works. This is submitted in outline at this

stage with all matters reserved except access.

Retention of Local Heritage Assets

3.1.7 The Proposed Site Plan (reference: A112428-8-110) includes the red line boundary for the full

application, which includes the existing access onto London Road, the Lodge building, the access

road to the Pump House, its associated car parking and landscaping, and the publicly accessible

green space formally used as the access drive to the Pump House.

3.1.8 The detailed drawings for the proposed renovation and conversion are submitted as part of this

application and show the proposed floor plans and elevations for the renovation of the Lodge

building to one dwelling and the renovation and conversion of the Pump House to 4 no.

apartments.

3.1.9 The conversion strategy for the Pumping Station and Lodge has been carefully considered to

ensure the original integrity of the buildings and their setting is restored and enhanced. The

Lodge is a restoration only with no extensions proposed and will provide a 4-bedroom detached

dwelling. The original materials and detailing are to be restored with any external alterations

limited to those required by modern building standards.

3.1.10 Works to the Pumping Station are limited to reinstating the original details and materials, and

internal alterations to provide 2 no. apartments at ground floor level and 2 no. apartments at

first floor level. In order to practically convert the building a small extension to the rear is

required to accommodate access to the first-floor level. This extension has been designed and

located to have the least impact on the existing facades and to improve the rear elevation

following previous demolitions. The extension has been designed to be markable different

utilising glazing panels to offer a clear break between the old and new. The extension will

present a modern vernacular utilising natural material to link the extension back to the site’s

industrial heritage.

Public Open Space Strategy and Protection of Trees

3.1.11 The arboricultural survey has informed both the layout and the open space strategy for site,

and the illustrative masterplan has focussed around the retention of the better quality trees on

the Site.

3.1.12 The tree lined former access drive from London Road to the Pump House is to be retained as

part of the proposed development in order to preserve the existing tress and maintain as far as

possible the setting of the Lodge and Pump House buildings. This creates an opportunity to


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provide informal open space for future residents and linking the development with the existing

surrounding area. The hedges and trees between Homes England and Coventry City Council’s

land are also retained as part of the proposed development as this forms a historic boundary.

3.1.13 The illustrative masterplan provides a total of 1.54 hectares of public open space, in addition to

the land required for attenuation features and the Local Wildlife Site. This figure is made up

from various types of space, including play space, amenity space, existing trees and woodland.

The Local Wildlife Site, comprising 2.5 hectares of land, will not contain any build development.

Access

3.1.14 The development includes two vehicular access points connected internally through the site via

an internal loop road. The northern access point is an upgrade of the existing access to the

Pump House on London Road. The junction will remain in site, but a new access road will be

aligned and provided to the north of the original driveway. This realignment allows for the

driveway setting to be retained in situ and minimise the loss of existing trees and vegetation.

3.1.15 The southern access point is located on London Road, north of Abbey Road, and is a new

vehicular to the Site.

3.1.16 Car parking for the proposed development will be provided for on-plot, in accordance with the

standards contained within the Coventry City Council guidance document ‘Coventry Local Plan

2016 – Appendix 5: Car and Cycle Parking Standards for New Development.’ Based upon these

standards each residential unit will provide for two off-street parking spaces per unit, with a

further unallocated visitor space provided at a ratio of one space per five units.

Landscaping

3.1.17 Detailed landscaping proposals have been prepared in support of the full element of the hybrid

application (Reference: A112428-8-HE-L-01). These proposals relate to the landscaping

proposed around the Lodge and Pump House buildings and car parking areas.

Site Waste Management

3.1.18 A Waste Strategy Plan (Reference: A112428-8 WSP-01) is included at Appendix 3 to identify

the indicative access and route of refuse vehicles around the site, and the indicative location of

bin collection points for proposed new dwellings and communal bin storage locations for the

proposed apartment buildings. As the application proposals are in outline, further details of

waste management will be determined as part of a subsequent Reserved Matters application.


Planning Statement

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4.0 Planning Policy and Legislative Context

4.1 Introduction

4.1.1 Section 38 (6) of the Planning and Compulsory Purchase Act (2004) requires that proposals are

determined in accordance with the Development Plan unless material considerations indicate

otherwise. The Development Plan comprises those local planning documents which have been

the subject of examination in public or testing through public inquiry and are adopted having

been through due processes.

4.1.2 The Application Site falls within the administrative boundary of Coventry City Council and the

statutory Development Plan comprises of the following documents:

• Coventry City Council Local Plan (adopted 2017)

• Willenhall Neighbourhood Plan (2018)

4.1.3 In addition to the Statutory Development Plan, applications should also be assessed against the

National Planning Policy Framework (February 2019) (NPPF or the Framework) and National

Planning Practice Guidance (PPG), which are material considerations in the determination of a

planning application.

4.1.4 In compliance with paragraph 48 of the National Planning Policy Framework (February 2019),

the weight to be attached to the policies in the Development Plan should be determined

according to their degree of consistency with the NPPF.

4.1.5 Other material considerations include the following:

• Adopted Supplementary Planning Documents (SPDs) and guidance (SPGs), as follows:

o Affordable Housing SPG (2006)

o Residential Design Guide (1991)

o Delivering a More Sustainable City SPD (2009)

o Coventry Connected SPD (DRAFT) (2018)

• Relevant evidence base documents, including:

o Greenspace Strategy 2008 – 2018

o Biodiversity Offsetting: Biodiversity Impact Assessment Calculator v19.0


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4.2 Statutory Development Plan

Coventry City Council Local Plan (adopted 2017)

4.2.1 The Coventry Local Plan was formally adopted on 6th December 2017 and has an end date of

2031. The following policies are relevant to the proposed residential development.

Policy DS1: Overall Development Needs

4.2.2 Policy DS1 requires a minimum of 24,600 additional homes to be provided over the plan period

along with supporting infrastructure and environmental enhancements.

Policy DS3: Sustainable Development Policy

4.2.3 The Council will take a positive approach when considering development proposals that reflects

the presumption in favour of development contained within the National Planning Policy

Framework. Policy DS3 states that the Council will “work proactively with applicants to find

solutions to enable proposals to be approved wherever possible, and to secure development

that improves the economic, social and environmental conditions in the area, including:

a) access to a variety of high quality green and blue infrastructure;

b) access to job opportunities;

c) use of low carbon, renewable and energy efficient technologies;

d) the creation of mixed sustainable communities through a variety of dwelling types, sizes, tenures and range of community facilities

e) increased health, wellbeing and quality of life;

f) measures to adapt to the impacts of climate change;

g) access to sustainable modes of transport;

h) preservation and enhancement of the historic environment; and

i) sustainable waste management.

Policy DS4 (Part A) General Masterplan principles

4.2.4 Policy DS4 highlights a number of general principles to guide master planning for any major

development proposal. These including, but are not limited to the following:

i. Where the site is identified as an allocation within the Local Plan or City Centre AAP it

should plan positively to meet in full the requirements identified within the relevant

policies associated with the allocation. Where the proposal represents a phase or phases

of a wider scheme however, the quantum of development should reflect the relative size

and characteristics of the phase, including its position within the wider site;


Planning Statement

14

ii. Where possible, all proposals should be planned in a comprehensive and integrated

manner reflecting partnership working with relevant stakeholders.

iii. Opportunities to deliver higher density residential and mixed-use development should be

maximised along public transport corridors and in designated centres with lower densities

provided elsewhere (in accordance with policies H9 and R3);

iv. Identify appropriate highway infrastructure along with sustainable transport corridors that

include the provision for integrated public transport, cycling and walking which provides

excellent connectivity and linkages to within the site itself, the City Centre and with the

surrounding area and existing networks;

v. Appropriate levels of car and cycle parking should be made in accordance with the Local

Plan’s parking requirements. Spaces should be well integrated within the development

and laid out to ensure they do not result in the obstruction of the highway as a result of

excessive on-street parking;

vi. Proposals should respond to the local context and local design characteristics (in

accordance with Policies GE3, HE2 and DE1), to create new well designed developments

with a distinctive character which residents will be proud of;

vii. Features of the historic environment should be respected as part of new developments

with existing heritage assets conserved and enhanced as part of development proposals

(in accordance with Policy HE2). Where appropriate, this should include the setting of

buildings and spaces and the restoration of assets at risk of loss;

viii. Sympathetically integrate existing landscape, biodiversity and historic features of the site

into the development taking opportunities to protect, enhance and manage important

features along with mitigation and enhancement measures to provide satisfactory

compensatory provisions where appropriate (having regard to Policies GE1-4);

ix. Provide fully integrated, accessible and connected multi-functional green and blue

infrastructure which forms strategically important links to the surrounding area to provide

routes for people and wildlife and open spaces for sports, recreation and play;

x. All new Masterplans should be informed by consultation with existing communities in

adjoining areas. This should take place prior to the submission of a planning application

to ensure feedback can influence the final proposals.


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Policy H1: Housing Land Requirements

4.2.5 Policy H1 identifies that provisions will be made for a minimum of 24,600 additional dwellings

between 2011 and 2031, with an annual requirement of 1,300 homes throughout the later part

of the plan period (2017 – 2031).

Policy H2: Housing Allocations

4.2.6 Policy H2 confirms that part of the Site is allocated for 200 dwellings under Site Reference H2:9

‘Land at London Road/Allard Way’. The following criteria are considered as essential site specific

requirements:

“Retention and reuse of locally listed pumping station and lodge.

Retention of important hedgerows and management of biodiversity/ecology impacts.

The provision of at least 2.5ha of publicly accessible green space as part of the development.”

Policy H3: Provision of New Housing

4.2.7 Policy H3 seeks to provide high quality residential development to contribute to creating

sustainable communities and which overall enhances the built environment including access to

sustainable transport provision and the infrastructure required to support housing development.

4.2.8 It also states that “A suitable residential environment will include safe and appropriate access,

have adequate amenity space and parking provision and be safe from environmental pollutants

such as land contamination, excessive noise and air quality issues.”

4.2.9 In addition, it states that:

“Wherever possible new developments should also be:

a) within 2km radius of local medical services;

b) within 1.5km of a designated centre within the city hierarchy (policy R3);

c) within 1km radius of a primary school;

d) within 1km of indoor and outdoor sports facilities; and

e) within 400m of a bus stop

f) within 400m of publicly accessible green space.”

Policy H4: Securing a Mix of Housing

4.2.10 Proposals for residential development will be supported where they include a mix of market

housing which contributes towards a balance of house types and sizes in accordance with the

latest Strategic Housing Market Assessment.


Planning Statement

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4.2.11 In assessing the mix of housing, the following circumstances will be taken into account where

it may not be appropriate to provide the full range of housing types:

b) “…locational issues, such as highly accessible sites within or close to a designated

centre where larger homes and low/ medium densities may not be appropriate;

c) sites with severe development constraints where housing mix may impact on viability;

d) sites where particular house types and/ or building forms may be required in order to

sustain or enhance the setting of a heritage asset; and

e) developments in parish or neighbourhood plan areas, where there is an up-to-date

local housing needs assessment which provides a more appropriate indication of

housing need.”

Policy H5: Managing Existing Housing Stock

4.2.12 Policy H5 supports the conversion of buildings from non-residential to residential use providing

a satisfactory residential environment is created.

Policy H6: Affordable Housing

4.2.13 Policy H6 requires residential developments of 25 dwellings or higher, or more than 1ha will be

expected to provide 25% of all dwellings as affordable homes.

4.2.14 The site is located within an area of existing low concentration of affordable housing, where

proposals should make provisions as follows:

a) 15% Social/Affordable Rental provision

b) 10% Intermediate Provision

4.2.15 Where the specified level of affordable housing cannot be provided, including viability, Policy

H6 requests robust evidence to justify a reduced or alternative form of contribution.

4.2.16 Policy H6 also requests that “Through appropriate design standards, new affordable housing

units must be appropriately integrated within the development and with other affordable homes

adjoining the site” and “Through engagement with the Council, Registered Providers, and having

regard to the recommendations of the SHMA, developers should ensure that affordable housing

contributions comprise dwellings of the right size, type, affordability and tenure to meet local

needs.”

Policy H9: Residential Density

4.2.17 Policy H9 promotes the effective and efficient use of land for residential development whilst

ensuring compatibility within the quality and character of the surrounding area. It states that:


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17

“developments outside of the Ring Road (The A4053) a minimum of 35 dwellings per hectare

(net) should be provided on previously developed land.” It also states that “Development on

Greenfield sites should achieve a minimum of 30 dwellings per hectare (net).”

Policy GE1: Green Infrastructure

4.2.18 Policy GE1 states that new development proposals should seek the following:

“1. The Council will protect green infrastructure based on an analysis of existing assets, informed

by the Green Infrastructure Study and Green Space Strategy by incorporating the Council’s

Green Space Standards, and characterisation assessments.

2. New development proposals should make provision for green infrastructure to ensure that

such development is integrated into the landscape and contributes to improvements in

connectivity and public access, biodiversity, landscape conservation, design, archaeology and

recreation.

3. Coventry's existing and planned network of green infrastructure should be used as a way of

adapting to climate change through the management and enhancement of existing habitats.

This must be demonstrated through the creation of new habitats wherever possible to assist

with species movement, to provide a source of locally grown food through allotments and

community gardens, to provide sustainable and active travel routes for people, to provide shade

and counteract the urban heat island effect, and to assist in improving public health and

wellbeing.

4. New development will be expected to maintain the quantity, quality and functionality of

existing green infrastructure. Where quantity is not retained, enhancement to quality is

expected. Where the opportunity arises, and in line with the city's most up-to-date Green Space

Strategy, the Council will also expect new developments to enhance green infrastructure, and

create and improve linkages between individual areas. Any development which is likely to

adversely affect the integrity of a green corridor will be required to be expressly justified and

where appropriate, mitigation measures put in place.

5. A key element of Coventry's approach to green infrastructure will be the continued

development of a network of green spaces, water bodies, paths and cycle ways, with priority

given to those parts of the city where there is an identified deficiency of green space. Where a

development proposal lies adjacent to a river corridor or tributary, a natural sinuous river

channel should be retained or, where possible, re-instated. Culverts should be removed unless

it can be demonstrated that it is impractical to do so.


Planning Statement

18

6. Development must respect the importance of conservation, improvement and management

of green infrastructure in order to complement and balance the built environment. A strategic

network of green infrastructure already exists in the city, connecting natural heritage, green

space, biodiversity, historic landscapes or other environmental assets, together with links to

adjacent districts in Warwickshire and Solihull. This strategic network will be safeguarded and

enhanced by:

a) Not permitting development that compromises its integrity and that of the overall

green infrastructure framework (including the Coventry/Oxford Canal);

b) Using developer contributions to facilitate improvements to its quality, connectivity,

multi-functionality and robustness;

c) Investing in enhancement and restoration where opportunities exist, and the creation

of new resources where possible, such as linking green infrastructure to other forms of

infrastructure;

d) Improving its functionality, quality, connectivity and accessibility;

e) Ensuring that a key aim of green infrastructure is the maintenance and improvement

and expansion of biodiversity;

f) Integrating proposals to improve green infrastructure in the delivery of new

developments, particularly through area based regeneration initiatives and major

proposals and schemes; and

g) Flood risk management and improving surface water quality.“

Policy GE3: Biodiversity, Geological, Landscape and Archaeological Conservation

4.2.19 Policy GE3 seeks to protect and enhance Local Wildlife Sites. It states:

“Development proposals will be expected to ensure that they:

a) lead to a net gain of biodiversity, where appropriate, by means of an approved ecological

assessment of existing site features and development impacts;

b) protect or enhance biodiversity assets and secure their long-term management and

maintenance;

c) avoid negative impacts on existing biodiversity; and

d) preserve species which are legally protected, in decline, are rare within Coventry or which

are covered by national, regional or local Biodiversity Action Plans”.


Planning Statement

19

4.2.20 If this is not possible, the policy states that “adequate mitigation measures must be identified.

If mitigation measures are not possible on site, then compensatory measures involving

biodiversity offsetting will be considered, but only in exceptional circumstances.”

4.2.21 In addition, it states: “Biodiversity will be encouraged particularly in areas of deficiency, in areas

of development and sustainable urban extensions, and along wildlife corridors. Opportunities

will be sought to restore or recreate habitats, or enhance the linkages between them, as part

of the strategic framework for green infrastructure. Protected Species, and species and habitats

identified in the Local Biodiversity Action Plan (LBAP), will be protected and conserved through

a buffer or movement to alternative habitat. Identified important landscape features, including

Historic Environment assets, trees protected by preservation orders, individual and groups of

ancient trees, ancient and newly-planted woodlands, ancient hedgerows and heritage assets of

value to the locality, will be protected against loss or damage. In the case of archaeological

remains, all practical measures must be taken for their assessment and recording in accordance

with Policy HE2.”

Policy GE4: Tree Protection

4.2.22 Policy GE4 outlines that developments will be positively considered provided that there is no

unacceptable loss of existing trees as a result of development and any loss should be supported

by a tree survey. Any tress not to be retained should be replaced with new tress and existing

trees worthy of retention should be “sympathetically incorporated into the overall design of the

scheme” with necessary measures taken to ensure their continued protection and survival during

construction.

Policy IM1: Developer Contributions for Infrastructure

4.2.23 Policy IM1 states that:

“1. Development will be expected to provide, or contribute towards provision of:

a) Measures to directly mitigate its impact and make it acceptable in planning terms; and

b) Physical, social and green infrastructure to support the needs associated with the

development

2. Infrastructure and mitigation measures will be provided in a timely manner to support the

objectives of the Plan.

3. The Council will, where appropriate, seek to secure site-specific infrastructure investments

and/or contributions as well as off-site contributions and/or investments. The nature and scale

of these will be related to the form of development and its potential impact on the site and

surrounding area. The cumulative impact of developments will also be taken into account.


Planning Statement

20

4. Developer contributions in the form of Planning Obligations and/or Community

Infrastructure Levy (CIL) will contribute towards strategic infrastructure required to support

the overall development in the Plan. This will focus primarily on category 1 infrastructure as

identified in the IDP and/or Regulation 123 list.

5. Where site specific issues generate viability concerns, applicants should discuss these with

the Council at the earliest possible stage in the development process. Proposals that are

unable to comply with the Plan’s policies on viability grounds must be accompanied by a

detailed Viability Assessment.

6. The Council will work in partnership with infrastructure providers and other delivery

agencies in updating the Infrastructure Delivery Plan to ensure an up to date evidence base

regarding infrastructure requirements and costs is maintained.”

Policy DE1: Ensuring High Quality Design

4.2.24 Policy DE1 states that development proposals must meet a number of key principles and seek

to respect and positively contribute toward the local identity and character of an area.

4.2.25 Development will be expected to meet the following principles:

“a) respond to the physical context of the site;

b) consider the local distinctiveness and identity of the site but also have regard to opportunities

to enhance the local built and natural environment through new development and enhanced

design;

c) where appropriate, retain and incorporate into the layout the protection of important views,

including key views of the three spires;

d) preserve or enhance the character and setting of the historic built, landscape and where

appropriate archaeological environment;

e) preserve or enhance the character and setting of major road, rail and canal corridors;

f) clearly define the boundaries between public and private spaces and enclosure of space;

g) provide attractive, safe, uncluttered, active and easily identifiable, high quality public spaces;

h) make places that inter‑connect and are easy to move through;

i) ensure places are easily understood by users, with clear routes and distinct physical features;

j) seek high quality design and attention to detail in the layout of developments, individual

buildings and infrastructure in terms of function and impact, not just for the short term, but

over the lifetime of the development;


Planning Statement

21

k) be adaptable to changing social, technological, economic and market conditions and ensure

that developments maximise the use of the site;

l) promote diversity through mixes of uses within a site or building, which work together to

create vital and viable places;

m) be proactive in responding to climate change and adopt sustainable and low carbon

construction principles in terms of their design, layout and density;

n) consider green infrastructure at the earliest stage in the design process, to ensure that it is

well planned, designed, managed and maintained. It should also be well integrated and serve

multiple purposes (as appropriate);

o) Support the integration of through routes for public transport and incorporate suitable bus

priority measures as appropriate;

p) minimise adverse impact on important natural resources;

q) conserve, restore or enhance biodiversity; and

r) respect and enhance landscape quality including trees, hedges and other landscape features

of value.”

Policy HE2: Conservation and Heritage Assets

4.2.26 Policy HE2 states “In order to help sustain the historic character, sense of place, environmental

quality and local distinctiveness of Coventry, development proposals will be supported where

they conserve and, where appropriate, enhance those aspects of the historic environment which

are recognised as being of special historic, archaeological, architectural, artistic, landscape or

townscape significance.”

4.2.27 These Heritage Assets include, inter alia, “Other places, spaces, structures and features which

may not be formally designated but are recognised as significant elements of Coventry’s heritage

and are positively identified on the Coventry Historic Environment Record.”

4.2.28 Proposals likely to affect the significance of a heritage asset or its setting should seek to

demonstrate “an understanding of such significance using currently available evidence.”

4.2.29 Policy HE2 states that “The sympathetic and creative re-use of heritage assets will be

encouraged, especially for heritage that is considered to be at risk, so long as it is not damaging

to the significance of the heritage asset. The embodied energy present in historic buildings

contributes to sustainability.”

Policy AC1: Accessible Transport Network

4.2.30 Where development is expected to generate additional trips on the transport network, it should:


Planning Statement

22

a) “Integrate with existing transport networks including roads, public transport and walking and

cycling routes to promote access by a choice of transport modes.

b) Consider the transport and accessibility needs of everyone living, working or visiting the city.

Special attention should be paid to the needs of disabled people, young children, and people

with special needs. Special attention should be paid to the needs of an aging population to make

Coventry an Age Friendly City.

c) Support the delivery of new and improved high quality local transport networks which are

closely integrated into the built form. This includes networks which support access to strategic

growth corridors. The scale of measures required should be appropriate to the scale and impact

of the proposed development.

d) Actively support the provision and integration of emerging and future intelligent mobility

infrastructure, including electric vehicle charging points, Car Club schemes and bicycle hire.”

Policy AC2: Road Network

4.2.31 Where new development proposals are predicted to have a negative impact on the highway

network, they should seek to mitigate and manage traffic growth and support enhancements to

the wider transport network including those set out in the Infrastructure Delivery Plan.

Policy AC3: Demand Management

4.2.32 Policy AC3 states that Transport assessments and Travel Plans will be required for new

developments which generate significant additional traffic movements on the transport network.

Policy AC4: Walking and Cycling

4.2.33 Walking and cycling routes should be incorporated and existing routes should be enhanced

through new development proposals, with financial contributions potentially being required to

support the wider network. It continues: “High quality cycle parking and associated facilities”

will be expected as part of new development proposals.

Policy AC5: Bus and Rapid Transit

4.2.34 Policy AC5 seeks to ensure new major development proposals should have safe and convenient

access to the existing bus network. The level of need will be determined through Transport

Assessments and Travel Plans.

Policy EM1: Planning for Climate Change Adaptation

4.2.35 Policy EM1 requires all development to be designed to be resilient to and adapt to the future

impacts of climate change through a number of adaptation measures including, inter alia;


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23

building orientation; appropriate materials; optimising use of green infrastructure; incorporating

water efficiency measures and minimising vulnerability to flood risk.

Policy EM4: Flood Risk Management

4.2.36 Developments must be assessed in respect of the level of flood risk from all sources. It states

that “all opportunities to reduce flood risk in the surrounding area must be taken, including

creating additional flood storage.”

Policy EM5: Sustainable Drainage Systems (SuDS)

4.2.37 Policy EM5 states that “All development must apply SuDS and should ensure that surface water

runoff is managed as close to its source as possible.” Consideration should be given to the

discharge of surface water from a site, and infiltration tests and a ground water risk assessment

will be required by all development.

4.2.38 Other relevant policies include:

• Policy C1: Broadband and Mobile Internet

• Policy C2: Telecommunications

• Policy EM7: Air Quality

Willenhall Neighbourhood Plan (2018)

4.2.39 The Willenhall Neighbourhood Plan was made in June 2018 and forms part of the Development

Plan for Coventry City Council. The Site the subject of this application is located within the

defined boundary for Willenhall.

Policy 1: Scale and Distribution of Housing Development

4.2.40 Part of the site the subject of this application is allocated for 200 dwellings within the Coventry

Local Plan. The Willenhall Neighbourhood Plan Provision will be made for a minimum of 323

additional dwellings in the neighbourhood area between 2016 and 2031, including the London

Road site allocation in the Coventry Local Plan providing 200 dwellings.

Policy 2: Mix of housing

4.2.41 Policy 2 requests a mix of market and affordable housing in accordance with the identified need

in Willenhall. It will support schemes where they provide a range of dwelling sizes that include

a limited proportion of smaller dwellings (1-2 bedroom) and a significant proportion of larger,

family sized dwellings (3-5 bedroom units).

Policy 3: Design of New Development

4.2.42 Policy 3 states that new development should be designed to incorporate the following features:


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24

“a) be of a scale and form which would be in keeping with Willenhall and would not result in

the loss of amenity for existing residents;

b) provide adequate levels of car parking, which should be designed to minimise its visual impact

and avoid the creation of extensive parking courts;

c) create well defined, attractive and secure streets and spaces, faced by active frontages and

benefiting from good levels of natural surveillance and lighting;

d) incorporate the principles of ‘Secured by Design’ or any equivalent standard which might

amend or replace it in the future;

e) integrate refuse and recycling storage facilities to mitigate the visual impact they may have

on the public realm; and

f) achieve high levels of environmental performance including energy efficiency measures to

minimise overall running costs.”

Policy 6: Education

4.2.43 Policy 6 seeks to support new residential development where “they make appropriate

contributions towards the creation of new primary school provision or towards the e

improvement of existing primary school facilities in the neighbourhood area in accordance with

the standards operated by Coventry City Council at the time of the determination of the relevant

planning application.”

Policy 7: Health and Well-being

4.2.44 Development will be supported if it promotes health and well-being of the local community.

Where appropriate, development should have regard to inter alia; lower air and noise pollution

by encouraging fewer car journeys and reduce the speed of vehicles through the area; provide

informal green spaces; provide opportunities to grow fruit and vegetables; enable children to

have safe and accessible places to play with friends and to safely walk or cycle to school.

4.3 Material Considerations

National Planning Policy Framework (February 2019)

4.3.1 National Planning Policy is contained within the National Planning Policy Framework (‘NPPF’ or

‘the Framework’ hereafter). The NPPF includes the Government’s planning policies for England,

highlighting the economic, social and environmental roles of planning, and its contribution to

meeting the mutually dependent objectives of a strong, responsive and competitive economy;

strong vibrant and healthy communities; and the protection of the natural, built and historic

environment.


Planning Statement

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4.3.2 The NPPF establishes that the purpose of planning is to contribute to the achievement of

sustainable development (paragraph 7) and in paragraph 8 identifies three overarching

objectives which need to be pursued in mutually supportive ways to achieve sustainable

development: economic, social and environmental:

• ‘An economic objective – to help build a strong, responsive and competitive

economy, by ensuring that sufficient land of the right types is available in the right

places and at the right time to support growth, innovation and improved productivity;

and by identifying and coordinating the provision of infrastructure;

• A social objective – To support strong, vibrant and healthy communities, by ensuring

that a sufficient number and range of homes can be provided to meet the needs of

present and future generations; and by fostering a well-designed and safe built

environment, with accessible services and open spaces that reflect current and future

needs and support communities’ health, social and cultural well-being; and Planning

Statement

4.3.3 An environmental objective – contributing to protecting and enhancing our natural, built

and historic environment; including making effective use of land, helping to improve biodiversity,

using natural resources prudently, minimising waste and pollution, and mitigating and adapting

to climate change, including moving to a low carbon economy.’

4.3.4 At the heart of the NPPF is a presumption in favour of sustainable development (paragraph 10),

which should be applied both through the plan-making and decision-making (para 11) process.

Para.11 states that:

“…For decision-taking, this means:

a) approving development proposals that accord with an up-to-date development plan without

delay; or

b) where there are no relevant development plan policies, or the policies which are most

important for determining the application are out-of-date (footnote 7, granting permission

unless:

i. the application of policies in this Framework that protect areas or assets of importance

provides a clear reason for refusing the development proposed (footnote 6); or

ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits,

when assessed against the policies in this Framework taken as a whole.”

4.3.5 Section 4 deals with the decision-making process, with Paragraph 38 stating that “local planning

authorities should approach decisions on proposed development in a positive and creative


Planning Statement

26

way…and work proactively with applicants to secure developments that will improve the

economic, social and environmental conditions of the area. Decision-makers at every level

should seek to approve applications for sustainable development where possible.”

4.3.6 Section 8 of the NPPF relates to ‘Promoting healthy and safe communities’ and seeks planning

policies and decision which aim to achieve healthy, inclusive and safe places. Paragraph 91 c)

encourages, “…the provision of safe and accessible green infrastructure, sports facilities, local

shops, access to healthier food, allotments and layouts that encourage walking and cycling.”

4.3.7 Section 5 of the NPPF aims to deliver a sufficient supply of homes and paragraph 59 states that

“To support the Government’s objective of significantly boosting the supply of homes, it is

important that a sufficient amount and variety of land can come forward where it is needed,

that the needs of groups with specific housing requirements are addressed…”.

4.3.8 Paragraph 64 confirms that where major development involving the provision of housing is

proposed, planning policies and decisions should expect at least 10% of homes to be available

for affordable home ownership, except for a number of exemptions including development

which “provides specialist accommodation for a group of people with specific needs (Such as

purpose-built accommodation for the elderly or students)”.

4.3.9 Section 16 of the NPPF relates to conserving and enhancing the historic environment. Paragraph

193 states that great weight should be given to the conservation of a designated heritage asset.

Paragraph 196 emphasises that where a development will lead to less than substantial harm to

the significance of a designated heritage asset, this harm should be weighed against the public

benefits of the proposal.

4.4 Other Material Considerations

Supplementary Planning Documents/Guidance

• Adopted Supplementary Planning Documents (SPDs) and guidance (SPGs), as follows:

o Affordable Housing SPG (2006)

o Residential Design Guide (1991)

o Delivering a More Sustainable City SPD (2009)

o Coventry Connected SPD (DRAFT) (2018)


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27

Evidence Base Documents

o Biodiversity Offsetting: Biodiversity Impact Assessment Calculator v19.0

SHLAA 2016

4.4.1 The site is identified within Coventry’s SHLAA (2016) as Site reference H2:9, where it states it

would be suitable for 200 houses. It states that the Site is expected to offer a viable development

option. In terms of suitability, it states that following:

4.4.2 “The site offers a prime opportunity to create a well-connected development that reflects the

surrounding residential area. The site also offers opportunities to reinstate the heritage assets

at the former pumping station and formalise green infrastructure within the surrounding area.

It is well connected and well served by public transport. Subject to appropriate design and

access the site is considered suitable.”


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5.0 Planning Assessment

5.1 Introduction

5.1.1 Section 38(6) of the 2004 Planning and Compulsory Purchase Act requires applications to be

determined in accordance with the Development Plan unless material considerations indicate

otherwise.

5.1.2 An assessment of the proposed development has been made against the relevant planning

policy framework for the Site. Account has been taken of all relevant material considerations.

The assessment has considered the following matters:

• Principle of Development;

• Scheme Benefits and Sustainability

5.2 Principle of Development

Housing Provision and Local Plan Policy H2

5.2.1 Coventry City Council Local Plan Policies D1 and H1 state that during the Plan Period, a minimum

of 24,600 new dwellings will be provided to meet the growth and housing requirements of the

City. As part of the Local Plan housing trajectory this requirement is to be stepped from 1,020

homes per annum in the first five years of the Plan period to 1,300 homes per annum in the

following 15 years. Policy 1 (Scale and Distribution of Housing) of the Willenhall Neighbourhood

Plan identifies the requirements to provide a minimum of 323 dwellings additional dwellings

within the Plan Period.

5.2.2 The application site, along with adjoining land to the north within the ownership of Coventry

City Council, forms part of the housing allocation known as ‘Land at Allard Way/London Road’

within Coventry Local Plan Policy H2:9. The allocation of the application site for residential

development is also identified and supported by Policy 1 of the Willenhall Neighbourhood Plan.

The principle residential development of the site has previously been established through the

Local Plan Examination process, and as such the application proposals are considered to be

acceptable in principle.

5.2.3 In compliance with the requirements of Local Plan Policy H2:9, the proposed development

includes the retention, renovation and conversion of the locally listed buildings on the Site,

retention of trees and hedgerows wherever possible and seeks to manage biodiversity on the


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29

site. Ecology and trees are dealt with in further detail within Section 6 of this report and within

the supporting suite of surveys and reports submitted with the application.

5.2.4 The proposed development will provide 1.54 hectares of publicly accessible open space. In order

to meet the 2.5 hectare requirement contained within Policy H2:9 for publicly accessible open

space within the allocation, the remaining 0.96 hectares is to be provided on the wider site

allocation, as part of the outline application proposals to be submitted for ‘Land at Allard Way’.

Maximising Housing Delivery

5.2.5 Section 5 of the NPPF relates to ‘Delivering a sufficient supply of homes’ and highlights the

government’s objectives of “significantly boosting the supply of homes…” (NPPF para 59). At

NPPF paragraph 60, it goes on to state that, “to determine the minimum number of homes

needed, strategic policies should be informed by a local housing need assessment…” It is

acknowledged that Coventry City Council’s latest 5 Year Housing Land Supply (dated 2017)

figure purports that the LPA have in excess of 5 years supply of housing land. Notwithstanding

this, the NPPF and the Statutory Development Plan state that housing needs and requirements

are set out and applied as a ‘minimum’.

5.2.6 As part of the evidence gathering a ‘Housing Needs Assessment’ for the Willenhall

Neighbourhood Area was undertaken by AECOM in November 2015. Although the Assessment

was informed by Coventry City’s Local Plan evidence base, this specifically identified the housing

needs for the defined Neighbourhood Plan area. Table 2 of the Neighbourhood Plan identifies a

shortfall in housing provision within Willenhall of 664 dwellings over the plan period.

5.2.7 On this basis, there is an acknowledged gap between the number of additional new dwellings

to be provided within Neighbourhood Plan Policy H1, and the level of shortfall identified,

equating to 341 dwellings. Paragraph 7.24 of the Neighbourhood Plan states that Willenhall is

characterised by high density development, with significant environmental constraints, which is

given as justification for restricting the provision of additional housing development so that it

falls below the identified need.

5.2.8 In the context that insufficient housing land has been identified within Willenhall to meet their

identified housing needs, it is considered that the entirety of the residential allocation at Allard

Way/London Road provides an opportunity to deliver above the 200 dwellings identified within

Policy H2:9. Increasing the number of dwellings proposed within the allocation meets with the

government’s objective of significantly boosting housing delivery and also contribute towards

meeting the identified housing needs and acknowledged shortfall within Willenhall

Neighbourhood Plan area.

Design and Capacity of the Site


Planning Statement

30

5.2.9 In addition to the government’s aims relating to boosting housing delivery, Section 11 of the

NPPF seeks to promote the effective use of land in meeting needs for homes. NPPF paragraph

123 specifically states that planning decision should ensure that, “developments make optimal

use of the potential of each site”. Local Plan Policies DS4 (Masterplan Principles) part iv.

encourages opportunities to deliver higher density residential development, and states that

these should be maximised along public transport corridors and in designated centres. Policy

H9 also relates to residential density and requires that all new residential development make

the most effective and efficient use of land whilst ensuring compatibility with the quality,

character and amenity of the surrounding area.

5.2.10 In accordance with the objectives set out in Section 11 of the NPPF and Local Plan Policies DS4

and H9, it is considered that the entirety of the residential allocation at Allard Way/London Road

provides an opportunity to deliver a high quality residential development which goes beyond

the 200 dwellings identified as part of Policy H2:9.

5.2.11 In terms of the wider context, the application proposals reflect the higher density character of

Willenhall acknowledged within the Neighbourhood Plan. Additionally, the Site is located along

public transport corridors (London Road and Allard Way), where Local Plan Policy DS4

encourages opportunities for higher density development.

5.2.12 The Masterplan, although only illustrative, pulls together the constraints, opportunities and

design concepts identified throughout the design process and demonstrates what a scheme for

up to 200 new homes could look like on site, and the sort of built form and open spaces

appropriate when considering the local context and on-site heritage and landscape assets. The

proposed development makes the most effective use of the land by maximising the densities,

without compromising the environmental constraints or future living environment on the site.

5.2.13 Within the proposed development, density variations contribute towards providing a more

balanced community in terms of different housing sizes and tenures. There will be variations in

the built form with the higher density areas including a high proportion of smaller units, and the

lower density zones including larger detached properties. This ensures that the development

reflects the housing mix requirements within the latest Strategic Housing Market Assessment

and complies with Local Plan Policy H4.

5.2.14 Overall, the proposed development demonstrates that 200 dwellings can be accommodated on

site, whilst meeting the principles set out in Local Plan Policies DS4 and DE1 and the Council’s

other design requirements in terms of separation distances, car parking provision, retention of

locally listed buildings, and the quantum of the publicly accessible open spaces. A Separation

Distance Plan (Reference: A112428-8 SDP-01) is provided within Appendix 4 which clearly


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demonstrates that the necessary separation distances and garden depths can be achieved

across the proposed development, in accordance with the Council’s Supplementary Planning

Guidance.

5.3 Scheme Benefits and Sustainability

The NPPF identifies that there are three dimensions to sustainable development: economic,

social and environmental (paragraph 7). The Framework makes clear that these aspects are

mutually dependent and gains in each area should be sought jointly and simultaneously

(paragraph 8). A summary of the benefits is set out below:

Economic Benefits

• The construction of the proposed development will create local employment

opportunities

• The proposed development will support existing jobs in the local economy, both in the

supply chain and through increase expenditure in the local economy.

Social Benefits

• The provision of new jobs during both the construction and operational phases of the

development.

• Provision of housing at a range of sizes, to meet shortfalls identified both locally and

nationally by Government and Willenhall Neighbourhood Plan.

• Provision of policy compliant level of affordable housing to meet identified local needs.

• Provision of publicly accessible open space within the development, as well as

maintaining and enhancing pedestrian and cycle links within and adjoining the site and

along the River Sowe corridor.

• Maintenance, enhancement and future management of the currently unmanaged and

overgrown Local Wildlife Site as part of the proposed development

Environmental Benefits

• Maintenance, enhancement and future management of the currently unmanaged and

overgrown Local Wildlife Site as part of the proposed development


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• Renovation of the currently derelict locally listed buildings, and the sympathetic

restoration and conversion into residential dwellings, which will secure their long-term

future.

5.5.2 There would be economic, social and environmental benefits arising from the scheme in

accordance with the requirements of NPPF paragraphs 7 and 8.


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6.0 Technical Assessment

6.1 Introduction

6.1.1 In preparing this planning application, the design team have had regard to the following material

planning considerations:

6.1.2 Transport Considerations and Sustainability;

• Heritage;

• Archaeology;

• Noise;

• Air Quality;

• Lighting;

• Ecology;

• Trees;

• Landscape and Visual Appraisal; and,

• Flood Risk and Drainage.

6.2 Technical Assessment

Transport Considerations and Sustainability

6.2.1 Section 9 of the NPPF aims to promote sustainable transport and encourages local authorities

to support a pattern of development which facilitates the use of sustainable modes of transport.

The traffic impacts of new development should be managed, and proposed development only

refused planning permission on transport grounds where the impacts of development are

“severe” (NPPF, paragraph 109).

6.2.2 The Application is supported by a Transport Assessment (TA) and Framework Travel Plan (FTP)

prepared by WYG have reviewed the transport and travel implications of the proposed

development. An assessment of the proposed access junctions onto London Road shows that

the proposed access arrangements are predicted to operate well within capacity in all of the

forecast scenarios assessed, with minimal queuing predicted on any approach to the junction.


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The wider impacts of the proposed development traffic have been assessed at the London Road

/ Allard Way junction, which is predicted to operate over capacity in the forecast year as a result

of growth in overall background traffic. The addition of traffic attributable to the proposed

development site is predicted to result in minor increases in queuing and delays on some

junction approaches. It is understood that the Council have previously collected development

contributions towards an improvement scheme at this junction, as well as growth deal funding.

6.2.3 The Transport Assessment (TA) confirms that the Site comprises a sustainable and accessible

location for the proposed development being close to public transport services, good walking

and cycling routes, in accordance with NPPF paragraph 108 a). To further improve travel via

sustainable modes of travel, a Travel Plan is submitted in support of this application. The

measures included within the Travel Plan are the appointment of a Travel Plan Coordinator,

distribution of a Welcome Travel Pack for residents and staff and a website to raise awareness

and provide information on walking, cycling; and public transport routes and promote

opportunities for car sharing. The sites sustainability and the measures within the Travel Plan

support the provisions of Para 103 and 110 of the NPPF.

6.2.4 It is considered that the proposals are in accordance with the principles of the NPPF and Local

Plan Policies AC1-5 relating acceptable impact upon the local highway network and meeting

sustainable and accessible transport objectives.

Built Heritage

6.2.5 A Heritage Statement, prepared by Orion Heritage, supports the application proposals and

considers the potential impact of the proposed new development on the historic environment

and non-designated heritage assets within the vicinity of the Site. In accordance with Paragraph

189 of the National Planning Policy Framework (NPPF 2019) and the requirement for applicants

to describe the significance of heritage assets including contribution to setting, the Heritage

Statement draws together available information on the heritage assets that are likely to be

impacted by the proposal.

6.2.6 There are no designated heritage assets located within the application site. There are three

designated heritage assets within a 1km study area of the application site, however the

distances and level of intervening development are such that none of these assets are impacted

by the development proposals and are scoped out of this assessment. As such, it has been

established that the statutory tests set out at Section 66(1) and 72(1) of the Planning (Listed

Buildings and Conservation Areas) Act 1990 are not engaged. The application does however

also need to be assessed against Section 16 of the NPPF.


Planning Statement

35

6.2.7 In terms of non-designated heritage assets, there are two locally listed buildings located within

the application site, and these are the pump house and lodge house buildings associated with

the former Pumping Station. The Heritage Statement has found that there would be a minor

negative impact on the significance of one non-designated heritage asset. The proposed

development is considered to require the LPA to have a balanced view with regard to the level

of significance of the non-designated heritage asset, and the level of harm occasioned, as per

paragraph 197 of the NPPF.

Archaeology

6.2.8 An Archaeological Desk Based Assessment has been prepared by WYG as part of the planning

application submission. NPPF paragraph 189 states that, “where a site on which development

is proposed includes, or has the potential to include, heritage assets with archaeological interest,

local planning authorities should require developers to submit an appropriate desk-based

assessment and, where necessary, a field evaluation.”

6.2.9 The site was found to contain potential for previously unrecorded archaeological remains

relating to the medieval periods onwards activity of the area, and the industrial use of the

application site, considering the use of the site as the ground of the Pumping Station, due to

the known evidence found of the application site and surrounding areas. A programme of

archaeological mitigation has been advised in the form of a geophysical survey, with any further

archaeological work being undertaken in accordance with the standards and guidance from the

Chartered Institute for Archaeologists, and a Written Scheme of Investigation agreed in advance

with the Coventry City Council Conservation and Archaeology Team. This should be undertaken

at the stage of the submission of a Reserved Matters application.

Noise

6.2.10 NPPF Paragraph 180 makes clear that new development should mitigate and to minimise

potential adverse impacts resulting from noise, and avoid noise giving rise to significant adverse

impacts on health and quality of life.

6.2.11 A Noise Assessment has been prepared by WYG in support of the application, with noise surveys

undertaken to determine the noise exposure on future users of the proposed development. The

dominant noise source at the site is road traffic noise from the A4082 (Allard Way) and the

B4110 (London Road) along the north-west boundaries of the site. Consideration within the

assessment has also been given to noise from the use of sports pitches at the Alan Higgs Centre

to the north east of the site.


Planning Statement

36

6.2.12 The Assessment concludes that through the use of appropriate mitigation, it is considered that

the proposed development will avoid noise giving rise to significant adverse impacts on health

and the quality of life. Recommendations have been provided in Section 5.1 of the report with

regard to a good acoustic design process which has been considered within the proposed

illustrative layout such as building location and orientation. Where feasible, when taking into

account other design considerations, these measures should be considered at detailed design

stage.

6.2.13 Standard double glazing is predicted to be acceptable throughout the majority of the

development site. For the most exposed facades facing the B4110 (London Road) along the

western boundary of the site, enhanced glazing may be required for habitable rooms. With

regard to the means of ventilation to proposed dwellings, noise levels within large parts of the

site will meet the BS 8233 criteria with windows open. However, around the northern and

western boundaries of the site, it is predicted that internal noise levels will be above the BS

8233 criteria in habitable rooms when windows are open. Therefore, typical of developments of

this nature and location, a scheme of ventilation will be required for such areas to enable

acceptable rates of ventilation when windows are closed. This can be provided in several ways

from acoustic trickle vents (which should have a comparable acoustic performance as the

glazing), other passive ventilation systems or mechanical ventilations systems.

6.2.14 For gardens most exposed to road traffic noise, including the Lodge, barriers (e.g. close boarded

fences) of up to 2.5m will be required to be installed. Any barriers which are installed for acoustic

purposes should be of solid construction with no gaps and a minimum mass of 10 kg/m2.

6.2.15 The Assessment concludes that with the mitigation proposed, the development would meet the

requirements of NPPF paragraph 180. It is considered that the proposed mitigation measures

are suitable to reduce any noticeable and intrusive noise from the surrounding environment.

Air Quality

6.2.16 Section 15 of the NPPF states that planning policies and decisions should prevent development

from contributing to, or being put at unacceptable risk from, or being adversely affected by

unacceptable levels of soil, air, water or land instability. WYG have prepared an Air Quality

Assessment in support of the planning application proposals.

6.2.17 T