hearing session 7 employment and retail · already earmarked a small extension at pro-logis park...

Coventry

Local Plan

Examination

www.coventry.gov.uk/localplan

Inspector: Rebecca Phillips BA(Hons) MSc DipM MCIM MRTPI

Programme Officer: Lisa Albrighton

T: 024 7683 2634

E: [email protected]

Examination Room, Civic Centre 4, Much Park St, Coventry, CV1 2PY

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Coventry City Council

Local Plan 2016 - Examination Statement

Hearing Session 7: Employment and Retail

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Part 1: Employment

a) Will the scale and type of employment land provision proposed

meet the identified requirement? The evidence indicates that only 3.9 years’ land supply exists in key categories. Also, that the Plan needs to allocate (B2) land for manufacturing and

industrial/warehousing (B8) land as demand outstrips supply. There is also demand for land for B1 offices and research and

development uses in order to address a potential under supply. Yes, in our view the sites allocated within the Local Plan as well as the sites

promoted and secured adjacent to the city boundary in Warwickshire (as outlined in the Employment Land MOU – see Appendix 1 of this statement) will

help to ensure that the City and its neighbours are planning for the right level of employment land provisions to meet the identified requirements of Coventry and the sub-region.

Page 38 of the CBRE report (LP38) suggests that Coventry has 3.9 years’ worth

of employment land supply; however this is based purely on market take up rates. These rates are set in a context of considering existing levels of land

supply across the sub region at LPA level – discounting anything that has been built speculatively or is potentially secured by a named provider (at the point in time the report was written). This is then compared to the average rate of take

up based on occupational trends between 2005 and 2014. In a broader planning sense, this position is not reflective of wider employment land needs, economic

growth forecasts or labour market characteristics. It also doesn’t have regard to churn of employment land (i.e. if a site is occupied does it release a site elsewhere).

Notwithstanding, the approach does highlight a consistent point raised within the

Councils wider employment land evidence base (including the 2015 GL Hearn Employment Land Review (ELR) (LP30)). This recognises that at this time there are signs of strong growth in the demand for new employment land around

Coventry and Warwickshire and that this demand is eroding current levels of supply. For example this demand has seen the significant pick-up of

development at Ansty Park, Pro Logis Ryton and Whitely Business Park in recent years. It also contributed towards the failed planning application at Coventry Gateway in 2014 (although part of this site has now been granted permission as

part of the Whitley South proposals).

When we factor in other considerations within the city’s employment land portfolio (as well as that of the sub-region) however it is not a case that developable options do not exist, and indeed a significant number do, it is a case

that many of the larger, more strategic options are constrained by current Green Belt policy. This is recognised in Para 4.44 of the ELR (LP30), which highlights,

when referencing wider studies and considerations, that immediate supply within

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the area is good but that longer term supply is potentially risky due to a reliance

on a number of large sites and also constrained primarily by Green Belt policy.

When considering the city’s employment land supply therefore we have given greater weight to our ELR which has considered recent take up rates based on annualised averages and actual completions of employment land. It has also had

regard to the projected growth in the work force, employment growth forecasts and wider market signals as well as the city’s relationship with land on its

boundary (such as Ansty Park). In this context the Councils Employment Land Review has sought to consider a range of employment based needs and projections in accordance with national guidance and has recommended a level

of employment land need that reflects these ranges and seeks to align that initial need with the growth in the city’s population (and working age element)

and the delivery of new homes. This has been key to the proposals within part 3 of policy JE2, which requires a

rolling land availability of 58ha at any given time. We would acknowledge that a failure to identify this rolling land availability would require a targeted review of

the policy to identify additional sites and ensure adequate land was available to support economic growth.

In this context and at the time of submission we have an employment land supply of approximately 146.5ha either within or immediately adjacent to the

city boundary. This comprises: • The 11ha of permissions identified in Table 3.1 of the Local Plan

• The 56ha remaining at Ryton and Ansty Park (Table 3.1 of the Plan) • Site Allocations JE2: 1, 2, 3 and 8 which are all available and benefit from extant permission and total 51.5ha

• The 28ha of land recently granted permission at Whitely South (in Warwick District).

We would acknowledge that when we update our monitoring performance to April 2016 this will have been eroded slightly by completions at Lyons Park, Ansty Park and Ryton, however supply is still likely to be in the region of 100ha.

Having regard to the wider evidence base however we are mindful that the

medium to long term supply is in desperate need of support, which is the reason we have sought to propose additional sites within the city’s Green Belt to support future economic growth and why we have worked with our Warwickshire

neighbours to support additional sites adjacent to the city boundary within the wider Green Belt.

For example, and as highlighted in the Employment Land MOU, a total of 117ha of land at the Coventry Gateway will contribute towards the city’s employment

land requirements (this does include the 28ha already permitted as part of Whitley South), as will a further 26ha within Nuneaton and Bedworth, who have

already earmarked a small extension at Pro-Logis Park Keresley and land at Rowley’s Green near Arena Park for employment provisions within the previous

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draft of their Borough Plan. Given their proximity adjacent to the city boundary

these sites are well placed to support the city’s employment land requirements in the medium to long term. At the same time though, each site is dependent

upon the adoption of the relevant local Plan to remove existing Green Belt constraints.

The allocation of these sites alongside existing provisions will be essential to the continued delivery of employment land to meet the needs of Coventry and the

sub-region. Having regard to our supply portfolio therefore we have sought to develop the

Plan to support market flexibility and to ensure the sites allocated are able to respond to market needs and changes quickly. This will help to ensure they

retain a reasonable prospect of delivery and help to support the wider economic growth of the city. For example we are aware from our evidence base that market needs for B2 and B8 provisions are often very similar and that units are

marketed in a flexible way in this respect. We have sought to mirror this principle in our policy proposals (especially on the larger sites). Our flexibility in

this regard has also taken into account the often volatile nature of the automotive industry in and around Coventry, but the current potential for

significant growth over and above trends. It has also considered the appropriateness of logistics provision in and around Coventry and how potential competition for such sites can be supported whilst still managing the ambitions

of the CWLEP and the Strategic Economic Plan.

In relation to provisions for B1 offices and research and development, the proposed allocation at Friargate is a game changer in terms of the city’s office provision. The site now benefits from new and improved infrastructure whilst

works remain on-going to expand the existing railway station and supporting facilities (as part of the Station Master plan (LP102)). This site is allocated within

policy JE2 and expanded upon further within the City Centre AAP. Through the City Centre AAP provisions are also made to support further R&D

provisions at Coventry University Technology Park, whilst proposals within Warwick District for the continued growth and expansion of the University of

Warwick are also supported in our Local Plan and will ensure provisions are maintained throughout the Plan period.

To reiterate the delivery of employment land within and adjacent to Coventry will be monitored on at least an annual basis through our AMR and will also form

part of our sub-regional monitoring programme in order to support the employment land MOU and support the delivery of the CWLEP’s Strategic Economic Plan. This commitment is also maintained within the employment

MOU.

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b) Is the proposed employment land provision in line with market

requirements in terms of site type, size and location? The evidence indicates a need for prime quality office space, start-

up premises, ‘grow on’ space and deliverable industrial land. The proposed employment land provisions have been developed for the Local

Plan with a specific view to being flexible and able to meet market needs and demands throughout the Plan period. This is also with a view to the sites being

able to respond to changes in market circumstances quickly and effectively. Furthermore the portfolio of sites both within and adjacent to the city boundary offer a varied and flexible supply of land across varying site sizes, locations and

types. They range from small brownfield opportunities to large Greenfield provisions (and everything in between). The varying needs of the employment

land spectrum can be considered as follows: Prime quality office space – The evidence base highlights that pre-recession the

Coventry office market was focused towards small scale units within the city centre supported by larger out of centre office parks. Post-recession this has

changed to a small scale city centre focus, with demand for out of centre office parks significantly reducing and replaced with 1 off city centre large scale offices

(such as the Severn Trent head office). This is reflecting a change in market demand to be focused more towards central locations which benefit from excellent connectivity and accessibility both by a range of transport and to

supporting facilities and services. The proposed office led regeneration scheme at Friargate has therefore been allocated to support larger new high quality

office space in a highly accessible location within the city centre. This provides a sequentially preferable location for major office development and provides a prime opportunity to support one of the City’s key growth areas – Financial and

Business Support services. It is also an opportunity to provide ‘grade A’ office space within Coventry City Centre, which the ELR highlights, has largely been

missing for some time. Although Friargate is allocated as the focal point for prime quality office space,

opportunities also exist in other parts of the city to support ancillary office provisions linked to B2 or B8 facilities (such as Lyons Park and Whitley Business

Park). The evidence base also recognises a need for smaller scale office units to support office based start-ups etc. The existing pipeline of permitted sites makes contributions towards meeting this need as does the existing level of churn

within the existing market place. We have also sought to allocate smaller parcels of land within the Coventry University Technology Park within the City Centre

AAP, whilst other areas within the city centre are also promoted for acceptable provision of smaller scale office units, most notably around the Civic Area and Regeneration areas. The Local Plan is also clear that office provisions will be

acceptable within other designated centres in accordance with national policy.

Start-up premises – As previously highlighted employment allocations within the Local Plan have been developed with a view to being sufficiently flexible to

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support a wide range of employment uses of varying size, scale and format. The

city also has a strong supply of smaller and older industrial units throughout the city which are well placed to support business start-ups. The City Council have

also recently completed a range of units at Lythall’s Lane as part of an expansion programme on its own industrial parks specifically aimed at supporting smaller scale industrial based businesses. Furthermore a selection of start-up based

units have recently been completed as part of the Lyons Park development at Browns Lane and are recognised within the evidence base as showing signs of

strong market interest. As set out above policies within the Local Plan and AAP also make such provisions and allow the market to respond to the needs and demands of business throughout the Plan period.

‘Grow on’ space - our employment land portfolio has identified a range of

opportunities for grow on space. Indeed we have seen a number of examples recently where local companies have begun to outgrow their existing facilities and have sought to relocate to larger and often more modern provisions. The

planned relocation of LTI from Holyhead Road to Ansty Park is a prime example as is the recent relocation of Dunlop from Whitmore Park to Pro Logis Park at

Keresley and Sainsbury’s from Walsgrave Triangle to Ansty Park. As such and in partnership with our Warwickshire neighbours the city is able to offer a range of

grow-on opportunities with the proposed allocations within the Plan again offering a number of opportunities to bring forward new and flexible employment land provisions to support not only business start-ups but also business growth

and expansion. Indeed, within the city boundary, the site at Baginton Fields has been specifically identified with a view to being well positions to support further

expansion of JLR or growth plans of related supply chain companies that would benefit from being located in close proximity to JLR.

Deliverable industrial land – Having regard to our response to ‘part a’ of this statement as well as earlier aspects of this answer, we consider our employment

allocations within the Plan to be sufficiently flexible to support such provisions and allow the market to respond to need and demand. Indeed one of the key considerations when identifying sites around the edge of the city (both within

and adjacent to the city boundary) was with a view to providing appropriate locations for industrial and logistical developments that would have minimal

impact on residential environments. We were also mindful of market characteristics which see B2 and B8 provisions often competing for the same sites and same units due to the similarities in needs and requirements. As such

our land supply in this regard has again been developed in a flexible and responsive way.

c) Will it encourage expansion and new investment by identified

key growth sectors?

We start our response to this question by identifying a necessary modification to the submitted Plan to make a factual correction to the supporting text on page

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27. This modification would ensure the correct reference is made to the

strongest employment growth areas over the Plan period. The data currently identified reflects an earlier draft of the study and data that was subsequently

updated through newly available information as the evidence base evolved. The correct references should state:

• Financial, Legal and Business Support Services up to 11,100; • Education 3,600;

• Health 3,400; • Retail Trade 2,800; • Construction 2,700;

• Wholesale Trade 2,600; and • Architectural & Engineering Services 2,000.

By way of clarification this actually makes very little difference to the situation and simply amends some of the figures for consistent job categories, adds in

Construction and Architectural & Engineering Services jobs and deletes reference to water, sewerage and waste; and residential and social care.

In terms of how the Plan responds to these growth areas, the policies and site

allocations are quite clear. The evidence base recognises the proposed development at Friargate to be ideally placed to support on-going growth in financial and business support services, with new ‘grade A’ office facilities

situated in a highly accessible location. When considering the Friargate proposals within the ELR (LP30) GL Hearn also considered the above trend growth in jobs

that such a development could support. In doing so the ELR considered an above trend increase of 3,800 additional jobs within the financial legal and business support services sectors (Para 5.41 of the ELR).

The planned growth of both universities are expected to be the driver of

educational job creation, with the Local Plan and AAP both supporting and facilitating the continued growth and expansion of both universities.

The retail growth needs of the city are fully planned for during the plan period with schemes such as City Centre South and the new Major District centre at

Eastern Green supporting continued growth within the retail and services sectors. The retail element of the Friargate development will also support growth in this sector.

The construction industry will be supported through significant development

proposals identified within the Plan and the continued economic growth of the city and the sub-region.

In addition to the key growth sectors identified by Cambridge and Oxford Econometrics, the ELR also considered the expected growth of the automotive

industry in accordance with the ambitions of the CWLEP and its Strategic Economic Plan. This had regard to a range of trends and the volatile nature of

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the industry over many decades. On balance though the study projects a growth

of approximately 2,500 jobs over the Plan period which reflects the projected growth of JLR, LTI and the supporting supply chain companies.

d) Given the importance of Jaguar Land Rover as one of the

biggest employers in the City and region, should the Plan include a standalone policy to ensure the necessary support to

facilitate its continued expansion over the Plan period? First and foremost the City Council fully recognise the importance of JLR to the

economy of the city, the sub-region and beyond. In this context we would also clarify that the city council continues to support the future growth and expansion

of JLR within and adjacent to Coventry. Following the period of statutory consultation, we note the proposed policy that

JLR have highlighted and recognise its strategic importance in the context of their existing facilities in Solihull Borough for example where significant land sits

adjacent to existing sites which requires strategic consideration given its Green Belt location. In the context of Coventry however, such an approach is not

considered necessary as existing JLR sites are situated in areas where the Plan already proposes employment based developments or links to land outside of the city’s administrative boundary (Whitley south for example). With regards the

later, the Plan is clear about the support it gives to the Gateway/Whitley South proposals and the cross boundary work it has undertaken with Warwick District

Council that would remove this land from the Green Belt to support further expansion opportunities. Indeed the land that forms part of Whitley South has recently been granted planning consent despite its existing Green Belt location.

With regards the former, JLR are currently based at Whitely Business Park. Land

around the Park is included for allocation at JE2(3) whilst land to the south east of the park is allocated for an extension of the Business Park (policy JE2(4)) the remaining land around the business park is very limited and largely flood plain or

Local Nature Reserve and would therefore be unsuitable for development in principle. Notwithstanding, these policies would clearly support future expansion

of JLR around its existing global headquarters should this prove desirable and necessary for JLR.

Furthermore, we felt that to include a policy specifically for JLR would mean a need for similar policies for all major employers in the city, with no clear steer

on where a suitable line could be drawn. We also have experience of utilising named user policies in our 2001 Plan which have shown experience of constraining land and inadvertently preventing development from being brought

forward. This was a scenario we were keen to avoid in the new Plan. Instead we wanted to ensure our policies were sufficiently flexible to respond to market

demand and market needs. To clarify there is nothing stopping JLR from utilising any of the employment land identified within the Plan and indeed, the City

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Council would be supportive in principle, as it always has been, to the continued

growth and expansion of JLR.

What we have proposed as part of our modifications schedule though is additional supporting text to strengthen the references to JLR and further highlight their importance to the city’s (and sub-regions) economy, as well as a

slight tweak to Policy JE1, again to further highlight the strategic importance of JLR. References include:

• additional text into the introductory section of chapter 3 (page 29 of LP4); and

• additional reference in Policy JE1(e) – page 31 of LP4

These proposed modifications would, in our view strengthen the strategic

importance of JLR to the city and work well alongside existing references.

e) Will the distribution of employment land support the Plan’s strategy and its communities?

We have sought to develop the Local Plan as a holistic blueprint for the

continued growth of the city. We have, where appropriate sought to do this in partnership with neighbouring authorities through the Duty to Cooperate in order to create seamless links between housing, employment and infrastructure. The

key diagram below highlights a range of strategic housing and employment sites within the Coventry plan as well as a select range of strategic allocations and

developments within Warwickshire but adjacent (or close) to the city boundary. This helps to clearly highlight the planned relationship between homes and jobs as well as their opportunity for key connections and linkages. This not only

works at the local/city level, but more importantly at the sub-regional level having regard to the city’s constrained boundaries and travel to work patterns.

Figure 1: employment and housing connectivity

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The blue areas are proposed housing sites whilst the red areas are employment

proposals. This includes the UK Central proposals at the HS2 interchange in Solihull Borough (to the far west of the Plan). The orange lines are A Roads and

the light blue line the Motorway network. The black arrows help to show the inter connectivity between sites and how areas of housing and employment will complement each other and inter-relate.

It is also important to highlight that to the west of the city exist a range of

employment parks already for example the large Tile Hill and Charter Avenue industrial estates. The east of the city is far more residential in nature and includes areas of higher deprivation such as Willenhall and Wood End. The

proposed employment focus around the south east corner of the City (at Whitley and the airport) not only supports the growth of JLR and its supply chain but is

also focused towards reducing localised unemployment and combating deprivation in this part of the city.

f) Should the Plan and its evidence be clearer as to how much and

what type of employment land is allocated in mixed-use sites? It is difficult to determine what contribution they will make to the supply of employment land.

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Through the development of policy JE2 we have sought to highlight which sites

are part of mixed use proposals and how much land they will contribute towards the employment land portfolio. This clarification is repeated in the ‘essential

requirements’ section of policy H2. This helps create a clear cross reference between the sites themselves as well as the amount of land and type of provisions that would be acceptable in principle within the sites. For clarity, such

sites would contribute 33ha towards the employment land supply. This comprises:

• 7ha at Friargate (JE2:1); • 15ha at Eastern Green SUE (JE2:5); • 8ha at Whitmore Park (JE2:6);

• 1.5ha at Durbar Avenue (JE2:7); and • 1.5ha at Alderman’s Green Road and Sutton Stop (JE2:8)

We would acknowledge there would need to be clear design considerations at the panning application stage, to have regard to appropriate heights, distances

and buffering etc., this would be especially true of the smaller sites at Alderman’s Green Road and Durbar Avenue (although the former already

benefits from extant planning consent to overcome this issue) and the medium sized sites at Whitmore Park and Eastern Green. As already discussed as part of

the earlier sessions however, we are confident that having regard to existing pre-application discussions and informal master planning as well as the on-going master planning work at Eastern Green that such issues or concerns can be

overcome.

In this context however we would confirm that for clarification and consistency with Policy H2 we would propose 2 small modifications to Policy JE2:

• Site JE2:8 should be renamed to be called “land at Alderman’s Green

Road and Sutton Stop” the same adjustment should be made to site H2:7 in Table 4.2.

• part 2 of policy JE2 should include reference to the land at Alderman’s Green Road and Sutton Stop as a mixed use allocations.

g) What evidence is there to support the viability of mixed-use

sites – will they be delivered? Further to linked discussions at earlier hearing sessions we would clarify that the

AHEVA (LP39) focused primarily on residential developments and by virtue the residential elements of mixed use schemes. However, the Council remain

confident that the evidence available to the Council is sufficient to suggest the schemes can be delivered as planned.

For example, the Plan identifies a number of mixed use site proposals including with uses including residential, employment and retail. With the exception of the

site at Durbar Avenue (H2:20 and JE2:7), all other mixed use opportunities have been subject to plan representations at the submission stage or pre-submission

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engagement and master planning that have clearly demonstrated that mixed use

opportunities are desirable and actively being pursued as well as being deliverable/developable.

The Durbar Avenue site has been slightly different in that it was previously found sound as a mixed use proposal within the 2009 Core Strategy and has remained

a component of the city’s housing and employment land supply ever since. In deed the site has continued to be promoted having been approved unchallenged

in 2009/10. We are also aware of a number of change of use applications being pursued relating to D1, Sui Generis and B8 type uses which have been refused within recent years suggesting the existing employment units are coming under

increasing pressure in terms of demand, viability and suitability. As such, the allocation is based on half the site being redeveloped for residential development

to help cross subsidise a regeneration of the employment aspect of the site. This broadly mirrors the proposals in the 2009 Core Strategy.

h) Do the Plan’s policies and proposals adequately address the

needs of all employment-generating sectors of the economy?

When considering employment needs the Plans policies and evidence have focused primarily on the land requirements within the B-use sector of employment. Notwithstanding, as part of the Employment Land Review (LP30)

this did provide a clear overview of growth sectors and other areas of employment that will be non B-use orientated. Of primary focus here are

employment generating uses within health, education, retail and community provisions.

The provision of new jobs within health related industries is expected to be linked to both the University Hospital at Walsgrave, but also overlap with

research and development industries associated with the universities. As such the Local Plan provides a flexible platform from which to support the growth and expansion of the University hospital as well as additional local health centres etc.

The provision of university linked and health based R&D can be supported through the Technology Park policies in the AAP and wider employment based

policies in the Local Plan. With regards education this primarily relates to the growth of the city’s

universities and through the Local Plan and City Centre Area Action Plan, we have identified a range of flexible opportunities to support the growth of both

universities. In the case of the University of Warwick, this has been managed in partnership with Warwick District Council who are proposing the removal of the university land within their District from the Green Belt to support their

expansion plans and delivery of their Master plan. We also expect growth in jobs in this sector as part of the new schools being planned to support the increase in

population and support sustainable communities.

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Both of the Local Plan and AAP also make significant provisions to support the

planned growth and qualitative improvements in the retail sector, with the planned city centre regeneration and new Major District Centre at Eastern Green

prime examples. The retention and provision of new community facilities is managed through policies CO1 and CO2 with new provisions supporting new jobs in the most sustainable and accessible locations.

Opportunities for agricultural based jobs in Coventry are limited due to its urban

focus, but the retained Green Belt land to the city’s North West corner as well as surrounding agricultural provisions within Solihull Borough and Warwickshire will continue to support any further growth in agricultural jobs.

The Plan also identifies the growth in tourism industry throughout Coventry and

the sub-region. Policy JE6 has been included within the Plan and is linked to the Councils Tourism Strategy (LP33). The policy supports the delivery of tourism related jobs within the key tourist areas of the city – the city centre, the Ricoh

Arena and the 2 university campus’.

The tourism strategy coupled with this policy is expected to become increasingly important in the coming years linked to the city’s bid to be the UK City of Culture

in 2021.

i) Does the Plan ensure that sites allocated for employment uses will not be protected in the long term where there is no

reasonable prospect of them being used for that purpose? When allocating land for employment use we have been mindful of the

requirements of the NPPF in this regard and as such have taken care in ensuring our allocations are supported by site promotions and/or planning consents or

where ever possible end users. This is an approach that has been mirrored across the sub-region. This sort of approach also provides confidence that there is a reasonable prospect that the sites being identified will be brought forward

and used for their intended purpose.

Notwithstanding we are also mindful of the requirement of Para 22 of the NPPF which expects site allocations to be monitored on a regular basis and reviewed as appropriate. This will be managed through our Annual Monitoring Report

which will provide an annual progress update on each of the site allocations within the Plan.

This approach will form the trigger for any need to review the Plans employment allocations having regard to market signals and wider development needs.

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j) Should the requirement to provide 6 months’ evidence of

marketing activity before key employment sites are considered for other uses in Policy JE3 ‘Non-Employment Uses on

Employment Land’ be extended? The marketing requirement in policy JE3 is linked to the requirements set out in

Appendix 2 of the Local Plan. As such the marketing requirement is at least 6 months, with this shorter timescale linked to individual buildings and smaller

sites as opposed to larger provisions which require either 9 or 12 months marketing dependent upon their size.

We gave strong consideration to whether or not such timescales should be longer or shorter, being mindful of the NPPF requirements in Para 22 but also

current employment land demand across the city and the sub-region. As such, on balance we felt that between 6 and 12 months dependent upon size was an appropriate approach for marketing purposes.

k) Are the employment policies in the Plan flexible enough to allow for a rapid response to a change in economic

circumstances? Yes, in developing the employment based policies within this Plan the Council

have sought to ensure they are suitably flexible and able to respond to the needs of the market at any point throughout the Plan period. Policy JE1 very

much sets the overarching strategy for the delivery of economic growth and job creation, whilst policy JE2 identifies a selection of sites to support employment land growth. These sites have been allocated to support both short and long

term employment options with sites of varying sizes and locations to support different employment needs. They have incorporated flexible use class

categories to ensure their delivery can, in principle, respond to any changes in market demand and/or need. Policy JE3 then provides a platform for considering any proposed loss of employment land.

Policies JE4 and JE5 then focus on specific types of employment provision, which

would be more windfall in origin. In relation to office developments this is largely reflective of national guidance in its approach to focusing new provisions towards designated centres. In relation to industrial and logistic based provisions Policy

JE5 takes account of accessibility and the relationship of proposals to surrounding uses. This helps to ensure that detailed design and layout proposals

can be taken firmly into account at the planning application stage. Indeed, policy JE5 is clear that it still applies to allocated sites (in JE2) meaning it is able to respond to the most up to date situation should surrounding land uses have

changed over time.

Policy JE6 relates to tourism developments and focus on the city’s main tourist assets. Policy JE7 then promotes enhanced accessibility to employment

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opportunities. This relates to our answer to question e of this statement and the

clear links that have been put in place to support the delivery of new (and existing) homes and new (and existing) jobs in a coordinated and accessible

way.

l) Does the Plan provide an adequate numerical and geographical correlation between employment land supply and housing

provision? How will the MOU help align housing and employment land provisions?

Further to our response in part e of this statement, it is our view that in partnership with our Warwickshire neighbours this Plan does provide a clear

numerical and geographical balance between the location of new housing and employment developments.

In terms of numerical alignment we would highlight the C&W MOU that was agreed at the sub-regional Joint Committee on the 21st July 2016 and is

scheduled to be presented to each respective authority for endorsement. In relation to Coventry we can confirm that this will be presented to Cabinet on the

4th October and full Council on the 11th October. The agreed MOU is attached to this Hearing Statement at Appendix 1 alongside the Joint Committee Report which accompanied it. At the time of writing it is too early to append the

Council’s relevant cabinet report.

What the report and MOU at Appendix 1 shows however is a clear process by which employment land has been redistributed from the city. This has had regard to a range of factors including a direct numerical alignment with

redistributed housing provision, commuting flows, Travel to Work patterns and market demand and signals.

m) Should the Plan include more information related to the timing

and release of employment land allocations linked to the timing and provision of key infrastructure?

With regards the release of employment land to support the economic growth and job creation within Coventry, we have taken a consistent approach to that

used with housing. We have not imposed a phased approach to land release which recognises the need to increases the city’s land options and support its

continued economic growth. The table below helps to clarify the infrastructure position in relation to the sites allocated in JE2.

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Site Ref

Site Ward/LPA

Area Ha (Hectares)

Employment Type

Infrastructure links

JE2:1

Friargate (part

of mixed

use site)

St. Michael’s

7 Primarily B1a

Supporting public realm

infrastructure is actively being

delivered as is new rail and parking

infrastructure. The delivery of

buildings is linked to the approved master plan and

outline approval.

JE2:

2

Lyons

Park

Bablake 16.5 B1, B2 & B8 Site already

benefits from planning consent

and is being delivered in a phased way.

Access is in place.

JE2:

3

Whitley

Business Park

Cheyles

more

26.5 B1b&c, B2

& B8

Highway

improvement works recently

completed and site benefits from planning consent.

Some development

already completed.

JE2:4

Land at Baginton Fields

and South

East of Whitley Busines

s Park

Cheylesmore

25 B1b&c, B2 & B8

Site would benefit from recent highway

improvement works at Whitley

junction and proposed works as part of Whitely

South development.

JE2:5

A45 Eastern

Green (part of

Bablake 15 B1b&c, B2 & B8

Access would be required direct

form the A45 and would be linked to

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mixed use site)

the overall delivery of the SUE.

JE2:6

Whitmore Park

(part of mixed

use site)

Holbrook 8 B1b&c, B2 & B8

Highway improvements

may be required around

surrounding highway network; however quantum

of employment land is reducing

relative to existing provisions. Accessibility

policies would support localised

improvements through the Section 106

process.

JE2:

7

Durbar

Avenue (part of

mixed use site)

Foleshill 1.5 B1b&c & B8 Highway

improvements may be required

around surrounding highway network;

however quantum of employment

land is reducing relative to existing provisions.

Accessibility policies would

support localised improvements

through section 106 process.

JE2:

8

Former

Electric Power

Station Land off

Alderman’s Green

Road

Longford 1.5 B1c & B8 Site benefits from

planning consent, with necessary

infrastructure requirements

identified in the relevant Section 106 agreement.

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(part of mixed use

site)

TOTAL 101

Based on this table the 2 sites of key consideration are those at Baginton Fields and Eastern Green.

In relation to Baginton Fields, this site will largely form an extension of the existing Whitely Business Park and has opportunities to link to the new

infrastructure already committed under the Whitley South proposals.

Given the remaining availability of land at Whitley and Whitley South and the expected phased delivery on these sites, we also expect the site at Baginton Fields to be a longer term development option.

In relation to the employment element at Eastern Green, we feel it has already

been established as part of the housing discussions that although a level of residential may be acceptable prior to the junction development at the A45, the employment provisions is very likely to be dependent upon this junction being

constructed prior to any occupation of the employment units.

Furthermore, we are mindful of our potential inclusion of a master plan principles policy that relates to the SUE’s (which will need to highlight the junction works at Eastern Green) as well as the likely modification to Policy IM1 to draw links

with category 1 infrastructure in the IDP. In this context we feel the Plan would provide adequate information in relation to the timing of development and its

supporting infrastructure. Lastly, and in relation to both sites, we feel the requirements within our

Accessibility policies would be sufficient to manage the release of the sites in accordance with infrastructure needs and the principles of sustainable

development.

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Part 2: Retail

a) Is the Plan’s retail strategy founded on a robust, credible and

up-to-date evidence base? Is there sufficient evidence to demonstrate that the retail strategy will be delivered?

The Councils retail strategy is underpinned by a suite of retail evidence. This includes the 2014 Shopping and Centres study completed by NLP (which in itself

was an update of 2004 and 2006 versions of the study) as well as a range of monitoring and localised retail assessment work.

The NLP study undertook 2 specific projection runs looking at retail needs linked to a constrained level of housing growth and the total population growth

projected for the city to 2031. These approaches reflected the projection work undertaken as part of the Joint Coventry and Warwickshire SHMA work. Although the study focused primarily on the constrained level of need, the Council has had

regard to a range of consultation responses and its on-going Duty to Cooperate work and has planned for the total level of retail need to meet the city’s full

projected population growth (to 2031). This reflects the city centres position as a sub-regional centre; its accessibility – especially linked to the NUCKLE rail

project and the Friargate improvements; and its need for regeneration. Appendix 1 of the NLP study provides a detailed overview of the methodology

used in assessing the city’s retail needs. At the time of its production the study utilised the most up to date data available from Experian, utilising 2012 prices

and projections lifted from the Experian Retail Planner briefing Note 11 (October 2013). It also undertook an update of the primary research around shopper trends and habits within the local area and reviewed the city’s retail based

catchment area.

The study has also incorporated data and evidence from wider Experian databases; the household survey; GOAD plans; the VOA; Oxford Retail Consultants StorePoint Database; Verdict; Mintel Retail Rankings; the Councils

own monitoring records; and NLP’s own projections and experience.

The study has also factored in small allowances for growth in market share, especially linked to the qualitative improvements planned for the city centre, which the study acknowledges are essential to helping ensure the city centre is

able to compete with other neighbouring centres such as Solihull and Leamington.

Furthermore, the methodology also explains how it includes an allowance for e-tailing which includes the continued growth in market share for internet

shopping, but acknowledging that there is a key overlap between internet shopping and the needs for retail floor space with links to click and collect

services, the continued demand for overall retail experience and the utilisation of the internet as a shop window.

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With regards the wider strategy, the NLP study is clear (Para 3.83 in particular) that a hierarchy of centres should be retained with a primary focus remaining on

the city centre. It also clarifies that the lower order centres must continue to support and compliment the city centre and not compete with it. This is clarified further in relation to the Arena Park MDC at Para 5.32, which helps inform our

strategic approach in this regard. In terms of the city centre focus this is referenced on a number of occasions throughout the NLP study. It is clear

though that the city centre needs to regenerate and revitalise itself at the top of the hierarchy in order to compete with surrounding areas, maximise its city wide catchment and support the city as a whole. The study suggests that the

provision of additional floor space can help to increase market share by attracting greater footfall, whilst qualitative improvements are essential to

respond to market needs and demands in terms of unit size, shape and function. The allocation of greater proportions of floor space to the city centre area (over and above initial projections in Appendix 3 of the NLP Study) reflects the need to

ensure the city centre remains the focal point for new retail based investment across the city. To allocate such need elsewhere would continue to undermine

the city centre at the top of the hierarchy and have unacceptable impacts on the city centre and its ability to play a sub-regional role. This also capitalises on the

city centres city wide catchment and strong accessibility by a range of transport options.

Lastly, the NLP study is clear that the face of retail and town centres as we know it is changing and there is an essential need to diversify how centres operate,

bringing in a greater level of leisure, tourism and entertainment provisions. As such we have taken a strategic approach to how we plan for our retail and retail based needs across Coventry and have sought to allocate our retail floor space

in a flexible and responsive way. Instead of specifying A1 uses in particular and risking higher levels of vacancy we have sought to group need within a broader

use class range (A1-A5) to help ensure units and floor space is able to respond to market needs and market demand in an appropriate, quick and flexible way without unnecessary constraints or risks of increased vacancy rates.

In terms of how the strategy will be delivered and whether or not sufficient

evidence exists, we would point towards a range of planning permissions that are already secured alongside wider commitments to deliver the planned retail elements of SUE’s etc. For example,

• Within the City Centre retail consent already exists for at least a 10,000sq.m uplift in retail floor space at City Centre South.

• Additional retail floor space is under construction as part of the new phase of development at Belgrade Plaza.

• Additional planning consents exist along Corporation Street and Hales

Street with opportunities to diversify and regenerate ground floor frontages in this area.

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• Further permission is already in place to deliver 20,000sq.m of retail floor

space at Friargate as part of ground floor developments at commercial buildings and as part of the station master plan.

• The Eastern Green Major District Centre (approximately 10,000sq.m) features within the indicative master plan for the SUE and the site promoters have highlighted their commitment to its delivery. As part of

this centre a new supermarket would be delivered within the North West of the city which reflects evidence within the NLP study and would support

sustainable communities within the SUE and its surrounding environs. • Provisions for approximately 1,500sq.m of locally focused provisions within the Keresley south local centre is already included within the

indicative Master plan by Lioncourt homes • Half of the retail provisions at Jardine crescent are included within an

extant planning permission as part of a mixed use scheme The final point in relation to the overall strategy is the comprehensive

redevelopment of the Bell Green District Centre at Riley Square. The NLP Study is clear that the centre suffers from significantly high vacancy rates, limited

retail based choice and a poor quality physical appearance. To combat this, the relevant stakeholders within the centre and its environs are entering into a

development partnership to completely regenerate the centre and deliver the aspirations of the policy to the benefit of local communities.

b) Will the policies and proposals in the Local Plan and City Centre

Area Action Plan (AAP) enable estimated retail needs to be met?

Yes, further to our comments in the question above, both documents have sought to allocate all retail needs over the life time of the Plan period. The NLP

Study identified a need for 105,820sq.m of retail and retail based floor space. This included an acceptance that a range of vacant units within the centres hierarchy would be occupied as part of meeting this need. Table 5.3 of the Local

Plan shows how this need will be met and highlights existing commitments and proposed allocations to deliver approximately 106,800sq.m

In identifying allocations, we have had regard to planned areas of development and opportunities to support sustainable communities e.g. the proposed centres

at Keresley and Eastern Green. We have also had regard to the strategic focus and importance of regenerating and revitalising the city centre to the benefit of

the city as a whole. Furthermore in planning for the needs identified through the study, we have

sought to establish a clear and flexible approach to delivering needs which will allow centres to maximise flexibility and respond quickly and appropriately to

changing market circumstances and market demand. This will help reduce vacancy rates and ensure vibrant and viable centres throughout the hierarchy.

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c) Is there sufficient clarity about the total need for comparison

retail floor space? Does the reference to ‘total other retail floor space’ in Tables 3 and 4 of the AAP comprise A1 comparison floor space and A2-A5 uses combined? Class A2 to A5 is not

typically regarded as comparison floor space. How does this figure accord with the NLP 2014 Shopping and Centres Update?

We appreciate that the consideration of table 3 in isolation could be confusing in relation to the amount and type of retail floor space that is to be provided within

the city centre. Our intention however was to use Table 3 and 4 in a way that moved on from the information contained within the Local Plan (most notably

Tables 5.1 and 5.2), which themselves reflected the tables and information contained within the NLP Study (LP59).

As such, we would confirm that Tables 3 and 4 of the AAP do group together other forms of retail provision under a single banner of “other retail floor space”.

This is consistent with the more general approach we have taken throughout the Local Plan as well and reflects the changing face of retail markets and demand

and the importance of supporting a diversification of town centres, offering a more varied and flexible supply of units and provisions that ensure they remain viable and attractive for years to come.

To clarify the total level of purely comparison shopping promoted by the NLP

study is identified in table 5.1 of the Local Plan (and is discussed further in response to question F of this statement.

We recognise that uses A2-A5 do not normally fall within a definition of comparison shopping; however we have chosen to group the needs for such

floor space in order to promote the flexible, varied and responsive town centres that we have already outlined above. It is our view that such an approach accords with the NPPF’s desire to promote viable and attractive town centres

that operate at the heart of their communities.

In terms of how this approach relates to the NLP study, it takes its conclusions and recommendations around floor space requirements for varying types of need and links this with wider discussions around the importance of diversifying

centres and helping them compete with surrounding areas. It also has regard to the wider changes in shopping patterns that are discussed within the study and

the need to combat above average levels of vacant units. We believe that the strategy approach put forward in this regard helps to achieve these key aspects raised within the NLP study.

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d) Should the proposed growth figure for the City centre in

Policies DS1 ‘Overall Development Needs’ and R1 ‘Delivering Retail Growth’ include Class A1 – A5, not retail classes only?

Yes, the total figures in both policies reflect total retail based needs (including use classes A1-A5). We propose to change the first element of part c) of DS1

(part 1) to read as follows:

“105,900sq.m gross retail based floor space (including uses A1 – A5) of which 21,900sq.m will be gross convenience floor space with approximately 70,000sq.m to be allocated to Coventry city centre…..”

In relation to Policy R1, we would propose clarifying the title and the initial text

to introduce the word “based” after “retail”. In our view this would clarify that retail provisions are the basis of the policy and floor space allocations but that other supporting uses (within A1-A5) are also acceptable in principle which

reflects permitted development rights and the importance of a flexible and responsive centres portfolio.

e) How has the identified gross retail warehouse figure of 21,758 sq. m. in Table 5.1 of the LP been calculated in the context of the recommendations of the NLP 2014 Shopping and Centres

Update? Should this be directed in its entirety to the City centre?

The gross retail warehouse figure of 21,758sq.m has been based on Table C in Appendix 3 of the NLP Study. The final 2 rows of this table (excluding the totals)

cover Bulky and Non-Bulky Retail Warehouses and identify a need to 2031 of 18,077sq.m and 3,681sq.m respectively (which totals 21,758sq.m). The text

within the study itself however only relates to the initial baseline projection as opposed to the alternative population projection (which are utilised in Table 5.1 of the Local Plan).

Notwithstanding, Para 5.17 of the NLP Study highlights the opportunity to focus

retail warehouse demand towards the city centre where possible. This is echoed in Para 5.35 which highlights the importance of focusing such needs towards designated centres. As the city centre sits at the top of the hierarchy of centres

we have sought to promote the provision of retail warehousing and the types of users that occupy these units within the city centre, potentially as part of wider

regeneration projects within and adjacent to the primary Shopping Area. This is consistent with the Sequential Approach for such provisions that frequently have a city wide or wider catchment area (Para 3.115 of the study).

In terms of how table 5.1 is presented though we would accept that in order to

present a fair reflection of the NLP Study that the retail warehouse figure could be presented as a ‘merged cell’ with totals presented as a range to reflect the

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strategic intention to focus delivery to the City Centre where appropriate but

accepting that through the sequential process this may not prove possible. As such, the end 2 columns of Table5.1 could be amended to look as follows:

Retail Warehouse Total*

21,758 56,376 - 78,134

27,686 - 49,444

21,758 105,820

* The range in totals reflects the provision of retail warehouse units. The total

provision of retail warehousing should not exceed the relevant total figure identified in the table (unless associated with an appropriate in centre proposal).

To supplement this we would also propose the additional sentence being added

to the bottom of the first paragraph on page 70. “If this does not prove possible through the Sequential Assessment process then

provisions should be focused towards the other centres within the hierarchy as appropriate”.

This would also ensure that the table then relates better with the proposed allocations at the Eastern Green and Cannon Park Major District Centres (in

policy R1), which in total contain approximately 5,000sq.m of predominantly bulky goods retail warehouse provision.

In relation to Tables 3 and 4 of the AAP an additional * note would be added to the bottom of the tables to clarify “total figures for other retail floor space and

total floor space are reflective of all retail warehousing being delivered within the city centre as outlined in Table 5.1 of the Local Plan”.

Paragraph 4.9 on page 8 of the AAP would be amended to say “up to approximately 78,000sq.m” and Para 4.11 extended to include the same

sentence suggested for Page 70 of the Local Plan at the end.

f) Table 5.1 of the Plan identifies a retail need of 27,667 sq.m. for

the City Centre with 13,175 sq.m. for the rest of the City. How

was the City Centre figure derived? The NLP Update at Table C identifies a floor space requirement for the City Centre of

17,667 sq.m. based on the alternative (i.e. boosted) population projections.

When calculating the retail needs of the city centre under the alternative population projection the NLP study had accounted for the uplift in floor space

proposed by City Centre South as an existing commitment. The projections (in Table C for example) were therefore identifying retail floor space needs over and above City Centre South. This is highlighted in the first paragraph at the top of

Page 5 of the NLP Study (LP59) and again as part of the footnote to Table B

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within Appendix 3. Given that City Centre South forms a key allocation within

the AAP and is a central element to the successful delivery of the city’s retail strategy, we felt it appropriate to add the 10,000sq.m uplift allowance back into

the projections of need. This ensured that we did not double count the contribution of City Centre South when allocating provisions against the requirement.

It is for this reason that the figure for city centre comparison retail need in table

5.1 is 27,667 as opposed to 17,667, it is exactly 10,000sq.m higher (i.e. the allowance of floor space at City Centre South)

g) Why are there discrepancies between Table 5.2 of the Plan and

Tables 3 and 4 of the AAP? Table 5.2 advocates 32% of the retail needs to be met up to 2021 with 68% to 2031 whereas the percentages in the AAP in Table 3 are 28% and 72%

respectively.

The discrepancy relates to the fact that Table 5.2 of the Local Plan covers the floor space requirements for the city as a whole as apposed just the

requirements for the city centre, which are shown in Tables 3 and 4 of the AAP. As such:

• Table 5.2 shows 32% of the requirement to be delivered by 2021 – this is 34,077sq.m as a proportion of 105,820sq.m

• Tables 3 and 4 of the AAP shows 28% of the city centre requirement to be delivered by 2021 – this is 21,811 as a proportion of 78,134

h) It is not clear in the Plan how Table 5.3 reflects the conclusions and recommendations of the NLP Update. Table 5.3 promotes 60,100 sq. m. (86%) of comparison/other floor space to 2031

for allocations in the City centre with 10,000 sq. m. (14%) for the wider City. The NLP assessment of comparison goods

showed a City centre requirement of 33.6%, District/Local Centres 25% and Retail Warehousing 41.4%.

In responding to this question we would draw on our response to question A

within this statement. In particular the following paragraph: “In terms of the city centre focus this is referenced on a number of occasions

throughout the NLP study. It is clear though that the city centre needs to regenerate and revitalise itself at the top of the hierarchy in order to compete

with surrounding areas, maximise its city wide catchment and support the city as a whole. The study suggests that the provision of additional floor space can

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help to increase market share by attracting greater footfall, whilst qualitative

improvements are essential to respond to market needs and demands in terms of unit size, shape and function. The allocation of greater proportions of floor

space to the city centre area (over and above initial projections in Appendix 3) reflects the need to ensure the city centre remains the focal point for new retail based investment across the city. To allocate such need elsewhere would

continue to undermine the city centre at the top of the hierarchy and have unacceptable impacts on the city centre and its ability to play a sub-regional

role. This also capitalises on the city centres city wide catchment and strong accessibility by a range of transport options.”

As such, we have taken on board both the initial projections contained within the NLP Study alongside the more contextual commentary and recommendations to

reach an informed approach to our retail strategy. We would accept that such an approach is technically a diversion of projected need towards the city centre and is therefore a ‘policy on’ reflection of the evidence base. Furthermore we would

accept that we have not slavishly followed the floor space projections and turned those into site allocations. As already highlighted above though, to have done so

would have risked undermining the city centres role within the retail hierarchy of Coventry and the sub-region. Instead we have maximised the opportunity of the

city centres city wide catchment, opportunities for regeneration and extant permissions to put forward a retail strategy that responds to national guidance as well as the broad conclusions of the evidence base. In our view this is a fair

and justified reflection of policy development informed by evidence

Lastly, we would stress however that we have not taken this approach in isolation or on an exclusive basis and indeed, the Plan has continued to allocate retail based provisions to other centres within the hierarchy where opportunities

exist to support new developments in a way which will compliment and not compete with the city centre. This is referenced further below in relation to the

hierarchy of centres.

i) Policy R1 ‘Delivering Retail Growth’ seeks to restrict further retail development at Arena Park unless it is shown that it will

not directly impact on the City centre. Is this consistent with paragraph 23 of the Framework?

Arena Park has been defined as a Major District Centre within the Local Plan, which reflects its original policy designation within the 2001 Plan where its

development was first promoted. Since the centre has been completed however it has grown larger than originally anticipated and is now more reflective of an out of centre retail park. The NLP Study (Para 5.32) describes Arena Park as

already having “a large critical mass of retail floor space and further retail expansion would compete rather than compliment the city centre”.

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This is an issue that has also been identified through various consultation

events. As such we are aware that the centre is fully occupied and trading very well (Appendix 6 of the NLP Study). It is economically sound having come

through the recessionary period strongly. As such, Arena Park MDC is already a strong, viable, resilient, competitive and attractive centre, and is performing stronger than other centres in the city and has the potential to impact negatively

on such characteristics in other centres, most notably the city centre. By virtue of this and in order to protect the city centre for the benefit of the city as a

whole, the further growth and expansion of Arena Park MDC needs to be carefully managed.

In that context it is important to stress that the policy does not prevent further development at Arena Park MDC altogether it simply links it to its relationship

with the higher order centre and the provision of robust evidence to demonstrate that it would not compete with the city centre. This reflects the hierarchy type approach supported by the NPPF and helps to protect and maintain the vitality

and viability of the city centre at the top of the retail hierarchy.

Consideration was given to delisting Arena Park as a centre in order to prevent further competition with the city centre, but we felt that such a proposal would

be inappropriate given its previous designation. We have also had regard to limited expansion opportunities that exist at Arena

Park with the site fully developed with existing retail units, service area or car parking. There is an area of vacant land adjacent to the stadium itself but this

has planning consent for leisure uses, which would remain acceptable in accordance with its edge of centre location and surrounding provisions.

j) Is the hierarchy of centres appropriate and justified by the

evidence?

Yes, The NPPF is clear that the establishment of a centres hierarchy is

appropriate and that this should be established within a Local Plan. It also requires policies to be set out which manage the “growth of centres over the

plan period”. The NPPG then requires Local Plans to set out “what is the appropriate and realistic role, function and hierarchy of town centres in the area over the plan period”. It considers this a key question to consider when

establishing a Plans retail policies and strategy. In this context, the NLP Study (LP59) recognises at a number of locations (including within the summary of

recommendations in the study) that the centres hierarchy remains appropriate and sustainable in the context of Coventry and its overarching requirements.

Appendix 6 of the NLP Study then considers the current status of the Major District and District Centres identified within the hierarchy, considering their

current position, strengths and weaknesses. To supplement this work we have undertaken a similar assessment of the Local Centres hierarchy within LP60.

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Both assessments have been undertaken with national guidance in mind and will be monitored and reviewed on a regular basis to ensure any emerging issues

with the centres hierarchy can be identified. This will be particularly important as part of the monitoring of this Plan as it will need to consider the make-up of centres (including use classes and vacancy rates) to understand if the Plans

greater flexible approach (compared to the previous 2001 Plan) is proving appropriate and suitable to help reduce vacancy rates and meet local needs.

k) Is there adequate justification for the local circumstances

which warrant a retail impact assessment threshold of 400 sq.m. (Considering the Framework’s default threshold is 2,500

sq.m.)? The NPPF is clear that there will be a requirement for an impact assessment if

the development is over a proportionate, locally set floor space threshold, or a threshold of 2,500sq.m if there is no locally set threshold. This is referred to as

the default threshold, but by no means is insisted upon and by virtue of being a default threshold there is an expectation that a locally set threshold may be

established. In establishing a locally derived threshold and understanding local impacts, consideration should be given to existing, committed and planned public and private investment in a centre or centres in the catchment area; and

the impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area.

As set out on page 79 of the Local Plan the city’s existing retail stock is heavily skewed towards smaller units. For example 88% of units within designated

centres (excluding the city centre) are below 250sq.m, and although this decreases slightly to 74% when including the city centre, this is still a significant

skew towards smaller units, suggesting a greater propensity for impact to be realised within smaller existing and planned units.

In addition to the NPPF, we have also had regard to the expanded support in the NPPG. This states that “As a guiding principle impact should be assessed on a

like-for-like basis in respect of that particular sector (e.g. it may not be appropriate to compare the impact of an out of centre DIY store with small scale town-centre stores as they would normally not compete directly). Retail uses

tend to compete with their most comparable competitive facilities.” In this context we consider the significant focus on smaller scale units across the city

means a need to consider impact at a scale lower than the default threshold identified in the NPPF and at a level more aligned to the average unit size across the city. This would help to allow consideration of the potential impacts on the

vitality and viability of the centres hierarchy as a result of the proposed development.

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In the context of the local nature of the city’s centres hierarchy we therefore

consider a reduction in the default threshold entirely justified.

l) Are the designated Major District Centres, District Centres and

Local Centres in Policy R3 ‘The Network of Centres’ founded

upon a robust and credible evidence base and consistent with the advice in the Framework/PPG?

In responding to this question we would first draw attention to our response to part J of this statement.

In addition, we would highlight that the NPPG also recognises that “Strategies

should identify changes in the hierarchy of town centres, including where a town centre is in decline. In these cases, strategies should seek to manage decline positively to encourage economic activity and achieve an appropriate mix of uses

commensurate with a realistic future for that town centre”. In the context of the city’s proposed Local Plan this specifically applies to the Major District, District

and Local Centres aspect of the hierarchy. For example the Plan has utilised evidence to manage the change of Ball Hill Major District Centre to a District

Centre in order to reflect its more localised provisions and strategic difference with higher order centres (principally the lack of large scale convenience retail operator). It has also managed the upgrading of the Binley District Centre to a

Major District Centre to recognise its recent development programme. The assessment has also recognised opportunities to diversify Brade Drive District

Centre and regenerate the Bell Green District Centre, both of which are supported in policy R2, with the later discussed above in response to part A of this statement.

Furthermore, we would highlight that the designation of centres and their

review, and amendment, has been supported by NPPF compliant health checks and continued monitoring and assessment. In this regard we draw attention to Appendix 6 of the Shopping and Centres Study (LP59) and the Local Centres

Assessment (LP60). We would also clarify that the network of centres has been long established and is supported in principle through our engagement

processes. It also provides a solid basis for focusing community provisions, supporting local needs and providing a focus for community cohesion.

m) Policy R3 ‘The Network of Centres’ sets out that the centres will

be the preferred locations for new shops and other main town centre uses which do not serve a City-wide catchment and are not more appropriately sited in the City Centre. Would this

contradict the statement that these centres are the preferred locations to support the City centre? The sequential test in the

Framework does not differentiate between centres in the hierarchy.

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It is our view that such an approach would not contradict the statement that these centres are the preferred locations to support the City centre. In deed by

being a focal point for centres investment which cannot be accommodated within the city centre and which does not serve a city wide catchment they are providing a vital local and sustainable service to local communities which

supplement the offer of the city centre.

We would acknowledge that the sequential test within the NPPF does not differentiate between centres within a hierarchy; however we consider such an approach essential within the local context of Coventry. For example, bullet point

1 of Para 23 does require Local Plans to “recognise town centres as the heart of their communities and pursue policies to support their viability and vitality”. In

this context we are mindful that if we allowed a free for all approach to the delivery of town centre uses within the hierarchy that this could end up placing significant viability and vitality pressure on higher order centres, especially the

city centre.

This approach to the centres hierarchy would also help ensure all centres, but again especially the city centre, would remain resilient to anticipated future

economic changes as they will maintain their purpose and place within the hierarchy (bullet point 2 Para 23)

Bullet point 3 is also clear that local Plans should make “clear which uses will be permitted in such locations”, whilst bullet point 5 requires the “retention and

enhancement of existing markets”. The approach set out in Policy R3 has been developed with these aspects of national guidance in mind, which in our view help provide a solid basis for establishing a retail hierarchy that is clear about its

roles and responsibilities to the city as a whole. We would also suggest that the very purpose of a hierarchy itself suggests an ‘ordering’ or ‘preference’ for

higher order elements within that hierarchy relative to elements lower down. As such, to order something within a hierarchy is by its nature applying a more sequentially preferable list of elements. In this regard the elements are

designated centres.

By taking this approach therefore it also helps to ensure from a strategic context that the centres continue to deliver provisions of an appropriate scale and context without competing with higher order centres and continuing to support

their intended community.

To clarify the City Centre sits at the top of the hierarchy and remains the starting point for city wide retail investments. Through Local Plan policies it is therefore essential that lower order centres support and compliment the city

centre but do not unduly compete with it (as suggested and recognised in the NLP study). The sequential assessment as set out in Policy R3 is therefore a key

component to allowing this approach to be managed and monitored in an appropriate way for the benefit of the city as a whole.

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n) Is the 3km radius area of support for Major District Centres

justified? The 3km radius has been identified as a guide to support the sequential

assessment process in this respect. This is with a view to providing a clear steer to applicants when preparing Sequential Assessments and to Planning Officers

when working through the decision making process. In this respect we would not anticipate it being slavishly applied hence the reference to “around 3km” and not “within 3km” or something similar.

It should be noted that as the order of centres decreases as does the radius of

influence and consideration. We have also had regard to general access to Major District Centres across the

city. When we place a 3km buffer around the city centre and 4 Major District Centres (including the proposed MDC at Eastern Green) we see that 92% of the

city is covered by such a radius.

o) Is the requirement in Policy R4 ‘Out of Centre Proposals’ for the

sequential assessment to include vacant units in the out-of-

centre retail parks consistent with national planning policy?

We accept that the inclusion of out of centre retail parks as a last resort stage in the sequential approach is not technically in keeping with national guidance due to it not being referenced in such guidance.

Notwithstanding, the explicit oversight in national guidance though, we have had

regard to local circumstances and have included it as an alternative option to stand alone or isolated developments that would be less sustainable in the context of the Framework when considered as a whole.

When we have regard to the policy proposal in this respect it is clear that should

a sequentially preferable option not exist within a designated centre and the option be between an isolated provision or a vacant unit within an out of centre retail park, then we consider the later to offer greater benefits in terms of

sustainable access, linked provisions and economies of scale. The provision would be better placed to support the wider sustainable development principles

of the Plan and Framework (in relative terms) and in that sense would be consistent with overarching threads of national policy.

p) Is the Plan suitably clear and flexible enough to allow retail

uses to effectively integrate within the strategic sites without

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any adverse implications on the City Centre or other centres

within the defined network?

Yes. As identified in response to earlier parts of this statement the proposed centres complement the existing spatial distribution of centres. This is also reflected in the Supplementary Housing Paper (LP51) where the assessment of

existing provisions relative to homes shows where gaps exist and where accessible provisions would be beneficial.

In addition to the geographic context of the centres, we have also had regard to the proposed uses within those centres and the size and scale of units to help

ensure they complement the existing hierarchy and do not compete with it inappropriately.

In relation to the Eastern Green MDC for example, we have highlighted the importance focusing delivery on a new supermarket and bulky goods retail, with

a small amount of small scale localised provision. The supermarket and localised provision in particular are specifically linked towards meeting local needs within

the local area and supporting the North West corner of the city. The bulky goods element may offer a wider catchment but is a prime alternative opportunity to

help meet the bulky goods retail needs identified within the NLP study in a planned and sustainable way without competing with the city centre.

The 2 local centres at Keresley have been very much focused on meeting local needs and local provisions. This would be supported through a rage of smaller

scale shops and facilities within a flexible and varied use class order. In proposing these provisions consideration has been given to access to local facilities in the short term but also longer term access to Arena Park to the east

and the new MDC at Eastern Green to the west through the completion of the Keresley link road.

In both cases we will consider adding further clarity around design and location through the Master plan Principles policy which we have started to consider as

part of any subsequent modification processes.

q) Does Policy R5 ‘Retail Frontages Ground Floor Units in Defined

Centres’ strike an appropriate balance to enable the protection

of the shopping function of important frontages whilst also being flexible enough to respond to changing market demands?

Yes. In drafting this policy we have had to be mindful of permitted development rights and the ability of smaller units in particular to change between use classes

easily and freely and the effect this could have on retail frontages. We have also had regard to a range of appeal decisions and planning applications that we have

been through around changes of use between A class uses within retail frontages. This has had specific regard to a previous threshold proposed in our

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2001 CDP where a reduction below 85% A1 use was considered to have a

negative impact on the retail frontage. Since 2001 the majority of centres have been eroded significantly below this level, although many still retain a majority

concentration (i.e. above 50%). By establishing this approach and utilising an appropriate monitoring target (as

set out in Appendix 8) we feel the policy will support an appropriate balance between the maintenance of the shopping function whilst being flexible enough

to respond to market needs and market demand. We have also sought to apply appropriate and flexible approaches to how ‘frontages’ are considered, whether it be a single aspect frontage or an element of multi aspect frontages which form

part of a more dispersed centre.

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Part 3: Monitoring & Implementation

a) Is the Plan’s retail strategy sufficiently flexible enough to

respond to changing circumstances and does it include clear and appropriate mechanisms for the implementation and monitoring of the Plan’s objectives?

In accordance with national guidance, the retail strategy and the hierarchy that

supports it will be monitored on a regular basis. This will include regular assessments of retail requirements and health checks of the centres within the hierarchy. This will be managed through the annual monitoring report process.

National guidance requires such assessments to be undertaken on a 3-5 year cycle. We will endeavour to undertake the assessments across Coventry on a 3

yearly basis which reflects the policy drive towards focusing growth within the city centre and will help to ensure the remaining centres within the hierarchy remain viable and attractive areas. It will also help to ensure that retail

investment is being delivered as planned and hoped and help identify any issues sooner rather than later. As such, the next health check review will be in 2018.

Through the health checks, we will continue to monitor vacancy rates and the

mix and use class of each centre. We will also review areas of concentration where the centre is larger in scale or split across a number of component parts.

We note the targets and monitoring requirements already identified in relation to these policies in Appendix 8. In respect of the live nature of this Appendix we

will seek to keep this under review and update it accordingly to reflect the aspects identified above.

Part 4: Any Other Matters

We have no further matters to raise in relation to parts 1, 2 or 3 of this statement.

hearing session 7 employment and retail · already earmarked a small extension at pro-logis park...

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