Agenda item

Report of the Director of Streetscene and Regulatory Services

The Cabinet considered a report of the Director of Streetscene and Regulatory Services which indicated that Policy DS1 of the Local Plan commits the Council to review certain triggers before March 2021 which, if met, would lead to a review of the current Local Plan. The report reviewed these triggers and recommended that there is no requirement to commence a Plan Review in March 2021.

The report indicated that The Local Plan was adopted in December 2017 and included, within policy DS1, the following provision;

“3. The Council will undertake a comprehensive review of national policy, the regional context, updates to the evidence base and monitoring data before 31st March 2021 to assess whether a full or partial review of the Plan is required. In the event that a review is required, work on that review will commence immediately.”

The full text of the policy and its explanatory notes was included in Appendix 1 to the report.

With the conclusion of the most recent housing and employment monitoring, it is considered an appropriate juncture to review the triggers set out in DS1 to determine whether a review of the Plan is appropriate.

The report indicated that with regard to National Policy, since the adoption of the Local Plan in 2017 the National Planning Policy Framework (NPPF) has undergone revision, the most recent version of which is dated February 2019. By itself this is insufficient to trigger a review, and analysis was undertaken regarding the extent of the changes to the NPPF and the subsequent impact on the adopted Plan. Whilst the NPPF revisions provide updated provisions and guidance, there are no material changes that result in the current Plan being rendered unsound; it is therefore not considered appropriate to commence a review on this basis.

Since Plan adoption the government has introduced a Standard Methodology which Councils are obliged to use when calculating housing requirements, replacing the method that was used in the Local Plan. This Methodology takes the official government population projections produced by the Office of National Statistics (ONS) and applies a multiplier to them based on average affordability in the City. Any plan review would need to use this Methodology as a basis for calculating housing need, and then add any additional modifiers driven through previous under-delivery, supporting economic growth or other drivers for additional growth. As the Methodology uses the same ONS population projection principles as the Local Plan there are no significant changes to the growth pattern of the city and sub-region as a result.

The most recent ONS population projections (currently the 2018 projections, released in Summer 2020) would need to be input into the Standard Methodology when conducting a review. These projections show a slight increase in growth over the plan period when compared to the 2012 projections used at plan-making stage. This additional growth is not considered significant enough to trigger a review but will need to be accommodated in any future review, as has been the case in neighbouring authorities where emerging Local Plans have been asked to demonstrate their ability to accommodate the most recent population projections. 

A recent government consultation proposed a revision to the Standard Methodology which proposed a significant increase in housing requirement. As there is no established timeline for the review of the consultation responses, or any subsequent changes to the planning system, it is not considered appropriate to delay a decision on Coventry’s Plan Review. In addition, there has also been recent public consultation on the future nature of the planning system (Planning for the Future White Paper). Whilst the proposals in the White Paper would constitute a radical change rendering a review, or wholesale new Plan, required there has only been an opening consultation conducted, with several years of further consultation and legislation required before the White Paper is enacted. It is therefore not considered appropriate to commence a Review based on this.

With regard to the Regional context, the explanatory text to Policy DS1 makes clear that the Regional triggers refer to the progress of neighbouring authorities in delivery of the City’s unmet employment and housing need. The agreement to the delivery of the City’s unmet need is shared with neighbouring Warwickshire authorities as part of the Memorandum of Understanding. Significant under delivery may contribute to the need for a Plan Review. A review of neighbouring authority Housing Delivery Test (HDT) results has taken place to assess their delivery against Local Plan targets, which include meeting Coventry’s unmet need. A HDT result of 100% means that an authority is fully meeting the housing requirement set out in their Local Plan, measured over the last three years.

The most recent data available is for the year 2018/19, as the global pandemic has hindered monitoring. As a result, government is likely to publish the most recent results during the Spring of 2021 and therefore after the point a decision is required regarding Plan Review. In addition, officers in the neighbouring authorities indicate that there are no significant changes in the monitoring results currently being processed by government and that we can be confident overall delivery will remain on track.

Employment land delivery for neighbouring authorities has also been assessed. The delivery of employment land is not centralised in the same way that housing delivery data is. However, a review of neighbouring authorities employment land delivery was detailed in the report. The report indicated that the nature of employment land delivery is more erratic than housing delivery, with large allocations often being completed in single developments. It is therefore appropriate to look at the total quantum delivered in the subregion against the total target to assess whether there is a significance issue with employment land delivery. A table in the report detailed the total requirement and delivery over the plan periods of the Warwickshire authorities which indicated that sufficient employment land has been delivered across the subregion and that the Regional trigger is not met.

The Council has recently completed work on the most recent monitoring year (2019/20) for the City, the detailed results of which will shortly be published as part of the Authority Monitoring Report.  As this data is produced in-house, the most recent dataset is able to be used. The key indicators relevant to the Plan Review triggers are housing and employment land delivery and the delivery over the plan period so far, compared to cumulative requirement were detailed in the report which demonstrates  that both housing and employment land delivery is above the targets set out in the Plan. As such the triggers have not been engaged and there is no requirement to commence a Plan Review.

There have been no material changes in the evidence base underpinning the Local Plan and therefore the second part of this trigger has not been met, and there is no requirement to commence a Plan Review in March 2021.

As a result of the above analysis it is concluded that the triggers set out in Policy DS1 have not been engaged and that there is no basis to commence a Plan Review in March 2021.

The Cabinet Member for Housing and Communities had considered two petitions at his meeting on 27 November, 2020 which requested an urgent review of the Local Plan. The Cabinet Member reported on issues raised at that meeting and referred the following additional Recommendation for Cabinet:-

That Cabinet recommend that Council commit to commence a Local Plan Review prior to the end of 2022 in the event that the Government’s Standard Methodology for Assessing Local Housing Need indicates a housing need lower than that currently provided for within the adopted Coventry City Local Plan (i.e. 1230 dwellings per year).

The Cabinet noted that the Cabinet Member had also requested a meeting with the Minister of Housing at the earliest opportunity.

RESOLVED that the Cabinet recommends that Council:-

1)  Notes the assessment of the Plan Review triggers

2)  Approves that there is no requirement to commence a Plan Review in March 2021 as a result of the triggers set out in Policy DS1 of the Local Plan

3)  Commits to commence a Local Plan Review prior to the end of 2022 in the event that the Government’s Standard Methodology for Assessing Local Housing Need indicates a housing need lower than that currently provided for within the adopted Coventry City Local Plan (i.e. 1230 dwellings per year).