Homes England Whitley Pumping Station, Coventry Planning ......Land at Whitley Pumping Station...
Transcript of Homes England Whitley Pumping Station, Coventry Planning ......Land at Whitley Pumping Station...
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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
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Land at Whitley Pumping Station Planning Statement
www.wyg.com creative minds safe hands
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
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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)
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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
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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
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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.
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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.
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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;
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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.
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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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“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.
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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”.
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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.
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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;
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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:
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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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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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“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.
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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
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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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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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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
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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.
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Planning Statement
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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.
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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