(Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

THE COUNCIL OF THE CITY OF COVENTRY (COVENTRY STATION WARWICK ROAD CAR PARK AND ADJACENT LAND CITY CENTRE) COMPULSORY PURCHASE ORDER 2019

PROOF OF EVIDENCE

ALLEN CREEDY MRTPI FIEMA PLANNING DIRECTOR SLC PROPERTY

Submitted on behalf of the Acquiring Authority, Coventry City Council

For the public local inquiry to be held on 10th September 2019 at 10:00am at the Council House, Earl Street, Coventry CV1 5RR

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

CONTENTS

1.0 QUALIFICATIONS AND EXPERIENCE ...... 4 1.1 Qualifications ...... 4 2.0 INTRODUCTION ...... 6 2.1 Preliminary ...... 6 2.2 Scope of Evidence ...... 6 2.3 Structure of evidence ...... 7 3.0 THE ORDER LANDS AND SURROUNDINGS ...... 9 3.1 Introduction ...... 9 3.2 The Order Lands ...... 9 3.3 Surrounding Lands and Context ...... 11 4.0 THE CPO SCHEME, THE FULL SCHEME AND THE COVENTRY STATION MASTERPLAN ...... 12 4.1 Introduction ...... 12 4.2 The CPO Scheme ...... 12 4.3 The Full Scheme ...... 14 4.4 Coventry Station Masterplan ...... 19 5.0 THE PLANNING POLICY CONTEXT ...... 22 5.1 Introduction ...... 22 5.2 MHCLG Guidance on Compulsory Purchase Process and the Crichel Down Rules’ ...... 22 5.3 Coventry Local Plan– Public Consultation and Examination ...... 23 5.4 Coventry City Centre Area Action Plan (2017) Public Consultation and Examination ...... 26 5.5 Development Plan: Coventry Local Plan (2017) ...... 28 5.6 Development Plan: Coventry City Centre Area Action Plan (2017) ...... 29 5.7 National Planning Policy Framework ...... 31 5.8 National Planning Practice Guidance (NPPG)...... 33 5.9 Other Relevant Plans and Policies ...... 34 6.0 PLANNING HISTORY ...... 37 6.1 Introduction ...... 37 6.2 The CPO Scheme ...... 37 6.3 Implementation ...... 37 6.4 The CPO Scheme: Permitted Development Rights ...... 38 6.5 The CPO Scheme – Planning Permission ...... 38 6.6 The Full Scheme ...... 42 6.7 The Full Scheme – Permitted Development Rights ...... 42 6.8 The Full Scheme – Planning Permission and Listed Building Consents ...... 44 6.9 Environmental Impact Assessment ...... 49 6.10 Other Applications: Friargate ...... 50 6.11 Other Applications - City Centre South Masterplan ...... 51 7.0 Assessment of the CPO Scheme ...... 52 7.1 Introduction ...... 52 7.2 ‘Clear Strategic Framework’ – Assessment of the CPO Scheme against the Local Policy framework ...... 52

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

7.3 Assessment of the CPO Scheme against the Local Plan and CCAAP Policies ...... 53 7.4 Bus Interchange (Building, Bus Parking and Manoeuvring) ...... 54 7.5 Central Six Access Road Improvements etc ...... 55 7.6 A new bay platform for Coventry Station ...... 57 7.7 Station car parking ...... 58 7.8 Assessment of the CPO Scheme against the NPPF ...... 60 7.9 Assessment of the scheme against Regional Policies ...... 63 7.10 Conclusion ...... 64 8.0 PLANNING BENEFITS OF THE CPO SCHEME ...... 66 8.1 Introduction ...... 66 8.2 Full Scheme – Completed works ...... 66 8.3 Highways and Transport Connectivity ...... 68 8.4 Regeneration ...... 68 8.5 Urban Design ...... 69 8.6 Accessibility ...... 71 8.7 Environmental benefits ...... 71 9.0 EQUALITIES ACT ...... 74 9.1 Introduction ...... 74 9.2 The Duty ...... 74 9.3 Consultation...... 74 9.4 Equality and Consultation Analysis ...... 75 9.5 Equalities Act – Conclusion ...... 76 10.0 Summary and Conclusions ...... 78 10.1 Qualifications, Experience and Introduction ...... 78 10.2 The Order Lands and Surroundings ...... 78 10.3 The CPO Scheme and the Full Scheme ...... 78 10.4 Planning Policy Context ...... 78 10.5 Planning History ...... 79 10.6 Assessment of the CPO Scheme ...... 80 10.7 Planning benefits of the scheme ...... 81 10.8 Equalities ...... 82 10.9 Conclusion ...... 82 11.0 DECLARATION ...... 83

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

1.0 Qualifications and Experience

1.1 Qualifications

1.1.1 My name is Allen Creedy, I hold a Bachelor of Arts with Honours Degree in Town and Country Planning from the University of Newcastle upon Tyne. I have been a chartered member of the Royal Town Planning Institute since 1982 and a Fellow of the Institute of Environmental Management and Assessment since 2016. I hold undergraduate level vocational qualifications in Ecology and Landscape Design. I am a qualified lead auditor in ISO14000 and ISO9000.

1.1.2 Experience

1.1.3 I was Assistant Head of Planning at the Council of the City of Newcastle Upon Tyne until 1999 when I was seconded to the European Commission as the UK’s Urban Policy Expert. Since returning to the UK in 2003 I have worked in private practice as an independent Chartered Planner. Since 2016 I have been Director of Planning for SLC Property Ltd. A good proportion of my commissions in the private sector have involved advising clients on the assembly of land for major urban developments. These schemes have required the acquisition of land by negotiation or through Compulsory Purchase.

1.1.4 As a Local Government Planner and a Chartered Planner in private practice I have experience of advising on the regulations, procedures and tactics appropriate with Compulsory Purchase Orders and large- scale Planning Applications.

1.1.5 These large scale complex urban development schemes have involved providing clients with planning and environmental assessments for a wide range of development proposals, including major infrastructure projects, large-scale residential and mixed-use development proposals. This includes the promotion of strategic land, outline and detailed planning applications, planning appraisals and associated work. This has included working on; major urban extensions to Peterborough, Manchester and Newcastle; applications under s.36 of the Electricity Act 1989 for Biomass Power Stations; large scale remediation on Merseyside and currently for five new rail stations for the West Midlands Combined Authority.

1.1.6 Of relevance to the matters under consideration in this Inquiry, I have had extensive involvement in the preparation of Structure Plans and

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

Development Plans together with giving evidence at Examinations in Public and associated inquiries.

1.1.7 I give evidence to this Inquiry on behalf of Coventry City Council (“the Council”) in support of its use of compulsory purchase powers pursuant to Section 226(1)(a) of the Town and Country Planning Act 1990 and Section 13 of the Local Government (Miscellaneous Provisions) Act 1976 in relation to the Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019.

1.1.8 I have inspected the site and its surroundings, and I am familiar with the proposals, the policies of the Council, and the wider policy framework.

1.1.9 I confirm that this Proof of Evidence is true and has been prepared, and is given, in accordance with the guidance of the professional institutions of which I am a member. I further confirm that the opinions expressed in my evidence are true and my professional views.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

2.0 Introduction

2.1 Preliminary

2.1.1 The Council made the Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019 pursuant to Section 226(1)(a) of the Town and Country Planning Act 1990 (“the 1990 Act”) and Section 13 of the Local Government (Miscellaneous Provisions) Act 1976 to acquire land and rights as contained therein.

2.1.2 The Order is required to enable the implementation of the “CPO Scheme”. The CPO scheme forms part of the “Full Scheme”. The Full Scheme forms part of the “Coventry Station Masterplan”. The individual developments which combine to form the CPO Scheme, Full Scheme and Coventry Station Masterplan are described in section 4.0 of this Proof of Evidence.

2.1.3 The Order was made having regard to the Ministry of Housing, Communities and Local Government’s ‘Guidance on compulsory purchase and the Crichel Down Rules for the disposal of land acquired by, or under the threat of, compulsion’ dated February 2018 (and now updated in July 2019) (“the MHCLG Guidance”).

2.1.4 In accordance with Section 226(1)(a) of the 1990 Act, the acquisition of the Order Lands is necessary to facilitate development that will contribute to the promotion and improvement of the economic, social and environmental well-being of the area.

2.1.5 In light of the above, and in order to provide certainty of delivery of the whole of the CPO Scheme, the Council considered that the necessary land and rights need to be acquired, either by agreement or through the exercise of powers of compulsory acquisition.

2.1.6 The purpose of the Order is to allow the implementation of the CPO Scheme. As stated above, the CPO scheme is part of the Full Scheme and also the Coventry Station Masterplan which will deliver improvements to the accessibility and operational capacity of public transport infrastructure at and in the vicinity of Coventry Railway Station.

2.2 Scope of Evidence

2.2.1 My evidence addresses planning matters including:

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

 A brief description of the Order Lands, the proposal and its planning context;

 The planning history of the site and its immediate surroundings;

 The planning policies that are relevant;

 The significance of any environmental effects and whether or not the proposals are ‘EIA development’;

 The status of the relevant permissions – facts about the planning applications, their determination and the decision notices;

 The planning conditions and their status in terms of ‘discharge’; and

 The engagement with stakeholders during the planning process.

2.2.2 Within this Proof of Evidence, I assess the planning merits of the CPO Scheme, including its compliance with the development plan, the National Planning Policy Framework (“the NPPF”), Planning Practice Guidance (“NPPG”) and other material considerations that I consider to be relevant.

2.2.3 My evidence should be read in conjunction with the Proofs of Evidence prepared by:

1. Mr Colin Knight (CCC) whose evidence covers the need for the development, the funding of the scheme, the assessment of scheme costs, benefits of the scheme and how it would be implemented.

2. Ms Rachel Jarrett (SLC) whose evidence covers third party negotiations, rail regulatory processes, joint working with Network Rail and updated responses to objections.

2.3 Structure of evidence

2.3.1 The remainder of my evidence is laid out as follows:

Section 3.0 describes the Order Lands and surroundings

Section 4.0 describes the CPO Scheme the Full Scheme and the Coventry Station Masterplan

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

Section 5.0 describes the Policy Context including the relevant MHCLG Guidance, the Development Plan, the NPPF and the NPPG

Section 6.0 addresses the relevant planning history.

Section 7.0 assesses the CPO Scheme against Planning Policy

Section 8.0 describes the planning benefits of the CPO Scheme

Section 9.0 describes the ways in which the CPO Scheme will further the objectives of the Equality Act 2010.

Section 10.0 summarises my evidence and sets out my conclusions.

Appendices

1. 281_010 Rev C Relevant Planning Permission and Application Redline Boundaries 2. 281_011 Rev C Redline Boundaries plotted on Aerial Photograph 3. 281_P_022-23 Rev C Views; Photographs taken from Viewpoints

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

3.0 The Order Lands and Surroundings

3.1 Introduction

3.1.1 The Order Lands are those lands contained within the red line boundary of the Order Plan.

3.1.2 The description of the Order Lands in this section includes reference to the current land uses, together with the existing physical and other features.

3.1.3 Mr Knight’s evidence provides more detail in relation to the Order Lands and surroundings as part of his consideration of the need for the development, the benefits of the CPO and Full Schemes and how they would be implemented.

3.1.4 Ms Jarrett’s evidence also provides more detail in relation to the Order Lands and surroundings as part of her consideration of the ownership of land and property, third party negotiations, rail regulatory processes, and joint working with Network Rail.

3.2 The Order Lands

3.2.1 The Order Lands are bounded on the east by the edge of the footway to Warwick Road (Reference Photographs 1 & 2); bounded on the west by the yellow metal fence to the western edge of Virgin West Coast Station Car park (Reference Photograph 3); bounded to the south by the steel palisade fence of the Network Rail operational boundary (Reference Photographs 4,5,6), bounded to the north by the northern edge of the footway to the unadopted road providing access to the Central Six Retail Park (Reference Photographs 7,8,9,10).

3.2.2 The Order Lands are used for the following purposes and have the following characteristics:

3.2.2.1 Parking of cars on tarmac in a pay on foot car park operated by Virgin West Coast (Reference Photographs 11 N/E/S/W), with yellow low metal steel tubular fence to the west (Reference Photograph 3) and low brick wall forming the boundary of the car park with shrubs and trees separating the car park from the Central Six access road and Warwick Road. The car park is flat at a similar datum to that of the operational rail land and the Central Six access road

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

(Reference Photographs 11 N/E/S/W). There are various steel cabinets located within the car park relating to the supply of power and operational rail equipment. The trees and shrubs have recently been removed from the embankment separating the car park from Warwick Road. This has been to facilitate the works to construct the pedestrian underpass connection from the station to the Order Lands. (Reference Photograph 12)

3.2.2.2 There is an existing very narrow pedestrian access path under the Warwick Road rail bridge from the car park in the south east corner of the Order Lands though to Coventry rail station (Reference Photograph 13). Evidence pertaining to the efficiency and functionality of the car park can be found in the evidence of Mr Colin Knight paragraph 3.4.1.3.

3.2.2.3 The Order Lands include the unadopted and privately-owned access road for vehicles and pedestrians to gain access from the roundabout on the adopted Warwick Road into the Central Six Retail Park. This road has tarmacadam surfacing and tarmacadam footways on both sides of the road. (Reference Photograph 10)

3.2.2.4 The Order Lands accommodate a number of structures including (1) a cuboid ‘temporary’ modular type building which accommodates operational rail equipment and associated facilities, the building is approximately 10.00m x 2.4m x 2.4m and is enclosed within a green steel palisade fence. The fence also includes an externally located ground mounted steel cabinet 1.2m x 1.2m x 0.3m (Reference Photograph 14) (2) a brick building with a single pitch slate roof with no windows and a single door, used by Network Rail. The building is painted black and is approximately 5.00m x 3.00m x 4.00m (Reference Photograph 15).

3.2.2.5 The Order Lands include a number of mature trees along the southern boundary (Reference Photographs 4 & 5).

3.2.2.6 The Order Lands also include lighting columns to illuminate both the car park and the Central Six access road. Various directional and information signs are located throughout the car park and on the Central Six access road within the Order Lands.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

3.3 Surrounding Lands and Context

3.3.1 Land to the south of the Order Lands comprises Network Rail operational land, including the West Coast Main Line between Euston and Birmingham New Street and beyond (Reference Photograph 16). The rail lines are embanked to the south beyond which there are various buildings being used for commercial purposes including Warwick Road Garage (Reference Photograph 17). Occupants of these buildings have views into the site, however these are limited by the operational equipment associated with Network Rail and by mature trees (Reference Photograph 16).

3.3.2 Land to the north of the Order Lands is occupied by the car parks and buildings of Central Six Retail Park (Reference Photographs 18,19,20).

3.3.3 Land to the west of the Order Lands is used as a car park associated with the activities of Central Six Retail Park (Reference Photograph 7).

3.3.4 Land to the east of the Order Lands beyond the Warwick Road is variously occupied by a tower block of offices (Eaton House), and a four- storey block of residential apartments with retail units facing onto Warwick Road (Reference Photographs 21 & 22). Adjacent to and to the east of Warwick Road is variously the surface car parks and buildings associated with Coventry Station (Reference Photographs 23,24,25,26,27,28,29,30).

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

4.0 The CPO Scheme, the Full Scheme and the Coventry Station Masterplan

4.1 Introduction

4.1.1 This section describes the development which will be undertaken within the Order Lands (“the CPO Scheme”).

4.1.2 This section also describes other development which will take place within the Full Scheme.

4.1.3 Reference is also made in this section to other works and other proposals which are intended to be implemented and are part of a partnership programme of works within the Coventry Station Masterplan.

4.2 The CPO Scheme

4.2.1 The CPO Scheme comprises the following works;

 the Bus Interchange: The Order Lands are required to allow the construction of a bus interchange building within the Order Lands. Planning permission has been granted for an interchange building which would adjoin Warwick Road. (Core Document C1). It would be connected at grade to the rail station by an access tunnel beneath Warwick Road for pedestrians. Pedestrian access to the Bus interchange will also be from Warwick Road via a lift and staircase down to bus level. The interchange is an essential component of the multi- modal transport hub comprising the Rail Station and bus interchange. Juxtaposing the two will encourage rail passengers to connect to bus services and vice versa. This will make the use of more sustainable modes more attractive than currently and assist in shifting passengers from the private car. the current bus provision at the railway station is poor. There is current provision for buses however this is temporary as it is located on a development plot for the Friargate Masterplan. The facility must move in order to facilitate future development. In

 Bus Parking Stands and Manoeuvring: The Order Lands are required to allow the construction of bus parking and manoeuvring (associated with the bus interchange building) within the Order Lands. Planning permission has been granted for a scheme which would provide for 8 parking stands together

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

with the associated safe manoeuvring areas. (Core Document C1). These bus parking stands and this interchange are intended to provide the facilities for bus services and sufficient capacity for rail replacement bus services.

 Central Six Access Road Improvements etc: The Order Lands are required to allow upgrading works to be undertaken to the Central Six access road. Planning permission has been granted for the section of the Central Six access road within the Order Lands to be upgraded to a standard which can then be adopted as highway. The upgrading of the road will include improvements to both footways, junctions and alignment of the road so that public service vehicles will be able to gain access from the Warwick Road roundabout and the highway network into the bus interchange.

 A new bay platform for Coventry Station: The Order Lands are required to allow sufficient land to be made available for the construction of a new Bay Platform to enable an additional rail service to be operated between Coventry and Nuneaton (known as NUCKLE bay platform). The additional platform will provide greater resilience to, and flexibility for rail services.

 Station car parking The Order Lands are required to allow the construction of (approximately) 70 car parking spaces of which 10 are dedicated for disabled users. Planning permission has been granted for a scheme which will allow the existing station car park within the Order Lands to be reconfigured to provide the bus interchange, bus stands etc, new bay platform with sufficient lands to then allow this parking to be provided. (Core Document C1). It is intended that the station car park will revert to the Network Rail ownership on completion of the CPO Scheme, see Ms Rachel Jarrett’s evidence at section 6.8. The Order Lands intended to be used for the construction of the station car park will be used (temporarily) for the compounds for the construction of; the new bay platform, the works to the Central Six access road and the bus interchange. Once these works are completed then the car park will be (re)constructed.

4.2.2 The works to construct the bus interchange, bus parking and manoeuvring, and highway improvements etc. were approved through Planning permission FUL/2018/1733 (Core Document C1).

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

4.2.3 The Works to construct the infrastructure etc. required for the new bay platform are permitted development as set out in section 6 below and obtained prior approval through PA/2018/2938 (Core Document C7)

4.3 The Full Scheme

4.3.1 I describe the Full Scheme in my proof of evidence. The Full Scheme reflects those works which are intended to be implemented to deliver the ambitions of the current iteration of the Coventry Station Masterplan.

4.3.2 In addition to the works which together comprised the CPO Scheme, the works for the Full Scheme include the following:

A. A new footbridge: to provide improved access between platforms. Works have started to implement this scheme as approved by PA/2017/3200 and LB/2017/3198 (Core Documents C6 and C5). The boundaries of the works are shown on drawings in Appendices 1 and 2. This can be implemented without the CPO Scheme.

B. Extensions to the existing platform canopies: to provide additional cover for pedestrians. Works have started to implement this scheme as approved by PA/2017/3200 and LB/2017/3198 (Core Documents C6 and C5). The boundaries of the works are shown on drawings in Appendices 1 and 2. This can be implemented without the CPO Scheme.

C. The new NUCKLE bay platform for Coventry Station: As described above, the platform itself will be constructed on Network Rail operational land and will enable an additional rail service to be operated between Coventry and Nuneaton. The works are permitted development and have been approved under PA/2018/2938 (Core Document C7). The boundaries of the works are shown on drawings in Appendices 1 and 2. The works have not yet started. The works cannot be implemented without the CPO Scheme.

D. Warwick Road etc. Improvements: including the realignment of the road, construction of new roundabout, construction of a new road to connect the new roundabout into the new multi storey car park and reconstruction. The existing Warwick Road alignment is shown on drawing 281_P_022 (Appendix 3). This shows the works include realignment to the connecting roads into Eaton Road/Station Square.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

The works have not started and cannot be undertaken in their planned form without the CPO Scheme.

E. the New Station Building: The building will be to the west of the existing station building and adjacent to Warwick Road. As Warwick Road is at a higher level than the railway land, two concourse levels and two entrances will be provided. The entrance to Station Square serves those approaching from the east and has been orientated to reflect the approach from a new boulevard. Two projecting forms to either side and a large entrance canopy serve to highlight the entrance and create a new public space between existing and proposed station buildings. A second entrance sits at Warwick Road level, again with a projecting form and canopy to define it. The lower concourse sits at existing platform level and is accessed from Station Square. It provides direct access to platform 1 via a gateline and is connected to the Warwick Road access tunnel at the western end, providing a direct link to the new bus interchange. The upper concourse sits at Warwick Road level and is connected to the new footbridge, providing access to all platforms via a 2nd gateline. It also has direct access to the multi storey car park above. Stepped and lift access connects both concourse levels. Two waiting rooms are on the lower concourse. Overall, five retail units will be provided, ranging between 55 and 250sq m in area. One would be located at upper concourse level with the others at lower level. The boundaries of the works are shown on drawings in Appendices 1 and 2.

The scheme which has planning permission (FUL/2018/1732) (Core Document C3) and Listed Building Consent (LB/2018/1810) (Core Document C4) cannot be implemented without the CPO Scheme because it relies upon the Warwick Road highway improvements being implemented – which rely upon the CPO Scheme being implemented. Whilst it is possible that a revised scheme could be developed if the Order were not to be confirmed, any such revised scheme would provide for a less efficient highway network or design when compared to the Full Scheme. The evidence of Mr Colin Knight provides further details on this matter at section 6.6. It is also important to note that if the Full Scheme could not be implemented

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

because the Order was not confirmed, there would be substantial delay whilst the new revised scheme was prepared, submitted, consulted upon and determined. Such a delay is likely to prejudice the implementation of the new station building and lead to additional costs. The evidence of Mr Colin Knight provides further details on this matter at section 7.4.

F. The multi storey car park (MSCP) forms part of the New Station Building. The construction of the MSCP and new Station Building will take place on the site of an existing surface level car park. Located immediately adjacent to the existing station building it will be located above the new station concourse. It comprises a split-level deck arrangement with one-way flow circulation. 634 parking spaces would be provided over 7 and a half decks. Accessible and enlarged spaces are provided within and it will also facilitate pick up with 20 minutes free parking. 149 of the spaces will be available for the use of the non-station traffic. The boundaries of the works are shown on drawings in Appendices 1 and 2.

The scheme which has planning permission cannot be implemented without the CPO Scheme because it relies upon the Warwick Road highway improvements being implemented – which rely upon the CPO Scheme being implemented. As with the Station Building (above), it is possible that a revised scheme could be developed with alternative highway arrangements if the Order was not confirmed. However, any such revised scheme would provide for a less efficient highway network or design when compared to the Full Scheme. The evidence of Mr Colin Knight provides further details on this matter at section 6.6.6. It is also important to note that if the Full Scheme could not be implemented because the Order was not confirmed, there would be substantial delay whilst the new revised scheme was prepared, submitted, consulted upon and determined. Such a delay is likely to prejudice the implementation of the new station building and lead to additional costs. The evidence of Mr Colin Knight provides further details on this matter at section 7.4.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

G. Temporary Car Park: Located on land off Westminster Road. This car park was permitted under FUL/2018/1591 (Core Document C8) and opened to the public on 16th October 2018. It provides replacement car parking for the existing station car park capacity which will be lost during construction of the bus interchange, new station entrance building and multi-storey car park. The boundary of this car park is shown on drawings in Appendices 1 and 2.

The temporary car park has planning permission and has been implemented. The temporary car park has been implemented ‘in part’ to ensure that when the CPO Scheme and Full Scheme are implemented there continues to be sufficient capacity in the vicinity of the Station so that train passengers arriving by car can continue to park their cars within a convenient walking distance. The temporary car park is therefore not dependent upon the CPO Scheme, but rather has been implemented to ensure that Railway Station continues to operate efficiently; and benefits from the CPO Scheme and Full Scheme accrue as early as possible for passengers in the implementation phase of the Full Scheme. The evidence of Mr Colin Knight provides further details on this matter at section 9.10.2.5.

H. The ‘western link road’: A planning application (ref: FUL/2019/1396) (Core Document C8) for this element of the Full Scheme is currently pending determination by the local planning authority. This will connect the adopted highway known as Westminster Road to the A4053 Ring Road. This will assist in unlocking the development site to the north of Central Six Retail Park which is identified to deliver over 400 new homes within the Friargate Masterplan and will deliver additional highway network resilience and capacity. The boundaries of the proposed works are shown on drawings in Appendices 1 and 2.

The ‘western link road’ scheme is anticipated to be granted planning permission in mid-September. In the event that it is granted planning permission it cannot be implemented without the CPO Scheme because it relies upon the Warwick Road highway improvements

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

being implemented – which rely upon the CPO Scheme being implemented. As with the Station Building (above), it is possible that a revised scheme could be developed with alternative highway arrangements if the Order was not confirmed. However, any such revised scheme would provide for a less efficient highway network or design when compared to the Full Scheme. The evidence of Mr Colin Knight provides further details on this matter at section 6.6. It is also important to note that if the Full Scheme could not be implemented because the Order was not confirmed, there would be substantial delay whilst the new revised scheme was prepared, submitted, consulted upon and determined. Such a delay is likely to prejudice the implementation of the new station building and lead to additional costs. The evidence of Mr Colin Knight provides further details on this matter at section 7.4.

I. Relocation of Rail station taxi ranks: consequent on the construction of the New Station Building and MSCP is the relocation of the taxi ranks from in front of the existing station building to an alternative location.

The relocation of the taxi’s from ‘in front’ of the existing station entrance forms part of the Full Scheme. This relocation will be implemented by the Council using a Traffic Regulation Order made under the Road Traffic Regulation Act 1984. It is intended that the taxi ‘rank’ will be relocated onto Manor Road, which is adjacent to the current station building. This relocation becomes necessary with the construction of the New Station Building and MSCP. The evidence of Mr Colin Knight provides further details on this matter at section 3.4.3.2.

J. Relocation of the existing cycle parking facilities: consequent on the construction of the New Station Building and MSCP is the relocation and of the existing cycle parking facilities from in front of the existing station building. Associated with the relocation is an increase in the number of parking stands and the provision of stands which are more secure.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

The relocation of the existing cycle parking facilities together with the provision of additional secure parking is an essential element of the Full Scheme. The additional and safer parking for cyclists cannot be provided without the implementation of the CPO Scheme.

K. Improvements to the public and private realm: a programme of improvements to the footways, cycleways, public information signage, landscaping and ‘street furniture’ forms part of the masterplan and pertains to all the public land and land that is in private ownership and which is used by the public.

The comprehensive programme of improvements to all the private and public realm is dependent upon the implementation of both the Full Scheme and the CPO Scheme.

4.4 Coventry Station Masterplan

4.4.1 In 2013 Coventry City Council appointed a team of consultants (including SLC) to prepare a Masterplan for Coventry Station. This broad policy, implementation and partnership framework was produced in 2014.

4.4.2 The Masterplan is referenced in the Coventry Local Plan (p.147). The masterplan includes;

 The strategic case for the development of the station based upon recent and predicted passenger growth, existing station capacity and a future vision.  The interface with committed and planned rail projects that interface with Coventry Station.  The interface with non-rail projects in particular the Friargate Development, the Warwick Road station access and other highway works.  Conceptual designs taking into account the above, the existing site parameters transport network and heritage value of the existing station.  a sound business case for investment in the station.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

 a clear block plan for land use and activity across the operational area available to the station and rail industry.  a clear framework for the development of detailed designs.

4.4.3 Subsequent to the plan being agreed by the Council it has been integrated into the development plan (p.147)

4.4.4 Coventry City Council has worked with the Coventry & Warwickshire LEP, Friargate LLP and rail industry partners to update the masterplan.

4.4.5 The current iteration of the plan provides for a framework for partnership working together with a suite of ambitions and investments to be made by the partners. (See evidence of Mr Colin Knight at sections 4.5 -4.9.)

4.4.6 The delivery, updating, monitoring and implementation of the masterplan is led by Coventry City Council.

4.4.7 The Coventry Station Masterplan is the largest component of ‘Coventry City Centre First’ which is a £630m+ package of transport improvements aimed at improving connectivity to UK Central and HS2 and boosting jobs and growth in the city centre.

4.4.8 The consultants in 2014 identified that the size, configuration and approaches to the current Grade-II listed railway station have seen little change since it opened in 1962. The building is now a constraint on achieving these objectives. The station has experienced unprecedented passenger growth over the last 10 years and is now operating beyond its design capacity, which is suppressing demand for travel and acting as a brake to future economic and employment growth in the city.

4.4.9 Coventry Station has experienced very high rail growth, becoming one of the busiest stations on the West Coast Mainline, and passenger demand is forecast to continue to increase significantly, particularly with the Friargate development around the station. Passenger activity at the station is forecast to increase from circa 6.9m trips per annum today to 7.5m pa in 2023 and nearly 11m pa in 2043, contrasting with just 2.25m pa in 2001. The station has suffered from a lack of investment and is experiencing capacity issues that will start to increasingly displace passenger activity to other stations and modes of transport. This will undermine the role of the station in supporting city centre regeneration and its ability to attract and retain inter-city rail services, which significantly benefit the city economy.

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4.4.10 The Full Scheme set out above reflects the current programme of works which the partnership intends to implement as part of the station masterplan.

4.4.11 The comprehensive redevelopment of the station as envisaged by the Coventry Station Masterplan has been designed to ensure it is ‘HS2 ready’ and will be able to capitalise on the benefits that HS2 can bring, while helping the station meet the needs of an aspirational, growing city and make the most of the rapid growth in passenger numbers.

4.4.12 In December 2017 Coventry was successful in being selected as the UK City of Culture for 2021. It is estimated that the year-long series of events will bring 2.55 million visitors into the city in 2021, and Coventry Railway Station will be the main entry point to the city for many of these visitors. The Coventry Station Masterplan project, which will provide a modern and attractive gateway to the city for those arriving by rail, is critical to ensuring that the transport network serving Coventry will have sufficient capacity to handle the volume of visitors that is expected during 2021. The City of Culture Travel Plan, which is in development with initial draft due September 2019, will be based upon encouraging visitors to travel sustainably to the city, and rail will obviously be a key mode given Coventry’s excellent rail connections to London, Birmingham and to other key cities across central, southern and northern England. Whilst it has always been the objective to deliver the Coventry Station Masterplan project as quickly as possible, securing City of Culture means that it is critical to deliver the new facilities to provide a fitting arrival point for visitors to the city during 2021.

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5.0 The Planning Policy Context

5.1 Introduction

5.1.1 This section describes the Planning Policy Framework for the CPO Scheme and the Full Scheme.

5.1.2 It commences with a description of what seem to me to be the most relevant parts of the MHCLG Guidance in order to set the context for that exercise.

5.1.3 My analysis demonstrates that the policies in the Local Development Plan have been holistically conceived; are founded on a sound evidence base; were subjected to consultation with affected stakeholders and landowners; subjected to examination by an Inspector on behalf of the Secretary of State; modified to take account of both representations from landowners and the inspector; found to be ‘sound’ and adopted in accordance with relevant legislation.

5.1.4 This section also describes the changes that have been made to the NPPF and NPPG subsequent to the adoption of the Local Plans. It then describes any consequence of these changes for the Order. In doing so it concludes that the development plans and the relevant strategic policy framework remain sound, relevant and sufficient to justify the Order.

5.2 MHCLG Guidance on Compulsory Purchase Process and the Crichel Down Rules’

5.2.1 Paragraph 104 of the MHCLG Guidance states that “Any programme of land assembly needs to be set within a clear strategic framework, and this will be particularly important when demonstrating the justification for acquiring land compulsorily under section 226(1)(a). Such a framework will need to be founded on an appropriate evidence base, and to have been subjected to consultation processes, including those whose property is directly affected”.

5.2.2 It continues by stating that “the planning framework providing the justification for an order should be as detailed as possible in order to demonstrate that there are no planning or other impediments to the implementation of the scheme.” In assembling the justification, the guidance notes that “the National Planning Policy Framework is a material consideration in all planning decisions and should be taken into account”.

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5.2.3 Paragraph 106 of the MHCLG Guidance identifies factors the Secretary of State will take into account in deciding whether to confirm an order under section 226(1)(a). The Guidance confirms that “any decision about whether to confirm an order made under section 226(1)(a) will be made on its own merits, but the factors which the Secretary of State can be expected to consider include:

 “whether the purpose for which the land is being acquired fits in with the adopted Local Plan for the area or, where no such up to date Local Plan exists, with the draft Local Plan and the National Planning Policy Framework”.

5.2.4 The Development Plan for the Order Lands comprises the Coventry Local Plan (2017) (“Local Plan”) and the Coventry City Centre Area Action Plan (2017) (“CCAAP”) which both cover the period 2011 to 2031. Both were adopted on 5th December 2017 and came into force the following day.

5.2.5 I have examined the policy context underlying the Order and assessed this against the MHCLG Guidance.

5.2.6 In this section I describe the Local, Regional, and National Planning Policy context for the Order and the works proposed for the CPO Scheme (and Full Scheme).

5.2.7 In Section 6 I describe the express Planning Permissions, Listed Building Consents and Prior Approvals which the Council intend to rely upon to implement the CPO Scheme and the Full Scheme.

5.2.8 My assessment that the ‘planning’ evidence is sufficient to justify the Order (when tested against the criteria set out in paragraph 104 and paragraph 106 of the Guidance) is set out in section 7.

5.3 Coventry Local Plan– Public Consultation and Examination

5.3.1 The Plan was informed by the then current iteration of the Coventry Station Masterplan dated 2016 (Core Document D1). The public consultation on the Local Plan included making available to stakeholders and landowners an up to date ‘evidence base’ in support of the vision and ambitions of the masterplan and how it would assist in delivering the objectives of the Local Plan. The masterplan included a revised vision for the station and its immediate area;

 Growth - a station able to accommodate major growth predicted in passenger numbers

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 Passengers - facilities of quality that are easy to use, making rail a highly attractive choice  Integrated - a new and transformative multi-modal transport interchange  Easy to get to - an accessible station for all  Attractive - a stylish, aesthetic and visible gateway to a proud city  Heritage - a celebrated, well-conserved 1960s Grade II listed building  Friargate - a station matching the quality, scale and ambition of the Friargate development  Place - a place in its own right, working well with the new place created by Friargate  Retail - eating, drinking and shopping for rail passengers and citizens alike  Commercial - a commercially viable station, supporting the wider Coventry economy

5.3.2 The Local Plan was submitted for examination on 1 April 2016. The examination hearings were held in July, October and November 2016 and January 2017 (File Ref: PINS/U4610/429/6). The Inspector’s report concluded that the Coventry Local Plan provides an appropriate basis for the planning of the City provided that several main modifications (“MMs”) are made to it (Core Document B3).

5.3.3 As such the Inspector concluded that in so far as the MMs have been made the plan was prepared having regard to the duty to co-operate, had been positively prepared, justified, effective and was consistent with national policy, was sound and compliant with the legal requirements (NPPF 2012, paragraph 182).

5.3.4 The Inspector found that the Council carried out widespread public consultation over a six-week period, both on the Plan before its submission and on the proposed main modifications. The Inspector took account of all the responses to those consultations in preparing the inquiry report. The Council contacted everyone on their extensive consultation database. Notices were also placed in local newspapers, local libraries and community venues and on the Council’s website. Officers held open evenings and exhibitions and attended Parish Council meetings and other local meetings on request.

5.3.5 The Inspector’s report notes that a very large number of representations were received at both stages of consultation, from local residents and businesses, community organisations, neighbouring local authorities, statutory agencies, developers and others. The Inspector expressed the view that the consultation process gave all those potentially affected by the Plan an adequate opportunity to express their views. The Inspector

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concluded that the consultations met all the relevant legal requirements, including compliance with the Council’s Statement of Community Involvement.

5.3.6 The Council specifically requested the Inspector to recommend any MMs necessary to enable the Plan to be adopted. The MMs all concerned matters that were discussed at the examination hearings. Following the hearings, the Council prepared schedules of the proposed modifications and carried out sustainability appraisal of them. The MMs were subject to public consultation over a six-week period. The Inspector recommended their inclusion in the Plan after considering all the representations made in response to consultation on them.

5.3.7 The Inspector’s report at paragraph 162 identified that “The West Midlands Strategic Transport Plan sets out the overarching transport strategy for the area and the Plan’s policies have regard to it. In particular, policies that support strategic connectivity such as rail, HS2 and rapid transit”. The Inspector supported a series of related Local Plan Major Modifications (“LPMM”) and City Centre Area Action Plan Major Modifications (“AAPMM”) proposed by Coventry City Council in response to the representations made to the Plan. Those relevant to the CPO Scheme, the Order Lands and the Full Scheme are cited below.

5.3.8 LPMM115 inserts an additional paragraph into the introduction to the section ‘Accessibility: Strategic Connectivity to provide further clarity and strengthen links to the Strategic Transport Plan.

5.3.9 LPMM116 inserts additional text to the introduction to Policy AC1 – reinforcing the importance that “everyone in the city has a good level of access to major public transport hubs such as Coventry Station…….to boost the attractiveness of public transport services”.

5.3.10 LPMM124 inserts additional text to the introduction to Policy AC4 – reinforcing the importance of providing cycle parking at transport hubs such as Coventry Station.

5.3.11 LPMM125 clarifies the introduction to Policy AC5 in that “The West Midlands Strategic Transport Plan sets out a strategy for a core bus network which is closely integrated with high frequency rail services.”

5.3.12 The inspectors report, at paragraph 167, makes reference to the NPPF in that it aims to extend transport choice, reduce congestion and encourage the use of sustainable modes of transport, and that it expects this to be achieved through improving accessibility, promoting walking,

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cycling and use of public transport, promoting a mix of uses for larger scale developments to encourage shorter journey lengths for employment, education, shopping and leisure as well as improving traffic management and infrastructure. The Inspector indicates that the achievement of the Plan target for a 10% modal shift from single occupancy car use to more sustainable forms of travel will be challenging, but that the Council consider this to be realistic based on the anticipated level of investment in infrastructure as well as evidence of changing travel habits such as an increase in home working, walking and use of public transport.

5.3.13 The inspector concludes, at paragraph 175, that “The Council has undertaken a thorough and robust assessment of the transport implications of development in the Plan and is satisfied that the effects of the strategic sites and allocations on traffic and transport can be adequately mitigated. The Plan will provide effectively for delivery of development, including any necessary supporting infrastructure. There would be sufficient scope to review transport, infrastructure and mitigation measures as the development of the strategic sites progress to ensure that the transport network is accessible, and opportunities are taken to improve connectivity.”

5.4 Coventry City Centre Area Action Plan (2017) Public Consultation and Examination

5.4.1 The Plan was submitted for examination on 1 April 2016 and the examination hearing was held on 20 October 2016 (File Ref: PINS/U4610/429/7).

5.4.2 The Inspector’s report concluded that the CCAAP provides an appropriate basis for the planning of the City Centre provided that several MMs are made to it (Core Document B3).

5.4.3 As such the Inspector concluded that in so far as the MMs have been made, the plan was prepared having regard to the duty to co-operate, had been positively prepared, justified, effective and was consistent with national policy, was sound and compliant with the legal requirements (NPPF 2012, paragraph 182).

5.4.4 The Inspector found that the Council carried out widespread public consultation over a six-week period, both on the Plan before its submission and on the proposed main modifications. The Inspector took account of all the responses to those consultations in preparing the inquiry report.

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5.4.5 The Inspector’s report summarised the importance of the CPO Scheme and Full Scheme to the success of the AAP in writing that “The AAP seeks to create a highly accessible City centre where people will find it easy to access, understand and move around in. The AAP recognises that the economic geography will change during the life of the Plan, most notably a likely increase in focus of economic activity towards southern parts of the City centre as the Friargate and Southern Precinct developments come forward. As such, the AAP says that it is essential that the City has a comprehensive integrated transport network in place to ensure new development opportunities are highly accessible making them more attractive for new business growth and well connected to other parts of the City.” [Para 36]

5.4.6 The CCAAP sets out how the Council will work in partnership with neighbouring local authorities, Local Enterprise Partnerships, the West Midlands Combined Authority (“WMCA”) and others to deliver the necessary infrastructure to support growth. The West Midlands Strategic Transport Plan sets out the overarching transport strategy for the area and the Local Plan’s policies, in particular those that support strategic connectivity such as rail, HS2 and rapid transit, are consistent with that strategy. As part of its joint working, the Council is working with Transport for West Midlands.

5.4.7 AAP/MM35 makes changes to the supporting text of Policy CC11 and places greater emphasis on the importance of rail facilities, in particular, Coventry station. These changes set out that a masterplan has been developed for the station area which will provide for improved linkages.

5.4.8 AAP/MM36 rewords the introductory text to policy CC11 to reinforce the centrality of the Station Masterplan and importance of the effective functioning of the transport interchange,

“Coventry station is an increasingly important strategic gateway into the city centre catering for well over five million business, leisure and educational trips into the city centre each year with these figures continuing to grow. A masterplan has been developed for the station area, and this will see the creation of new entrances combined with improved linkages on to Warwick Road and improved transport interchange linked to a new cycle parking hub. The Council will continue to engage with the rail industry to secure improved rail connectivity, in accordance with its rail strategy, to secure improved services which will support economic growth objectives. As more people use

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Coventry station to leave Coventry than arrive – and vice-versa in the evening, it is important that access to the station is sufficiently robust to sustain the continued growth in passenger numbers and future schemes support this like the station interchange”.

5.5 Development Plan: Coventry Local Plan (2017)

5.5.1 The Development Plan comprises the) Local Plan and the CCAAP which both cover the period 2011 to 2031. Both were adopted on 5th December 2017 and came into effect the following day. Together the two plans provide the strategic policy framework against which the justification of the order is provided.

5.5.2 The Plan sets out Coventry’s vision to “…help re-establish itself as one of the country’s top 10 cities, enhance its position at the centre of the Coventry and Warwickshire Sub-region and contribute towards the West Midlands engine for growth.” The plan sets out the planning policy framework against which applications for planning permission, development proposals and other initiatives will be tested.

5.5.3 Policy JE1 of the Local Plan supports ‘development’ which will deliver sustainable economic growth and job creation. The supporting text to the policy indicates that the Council will ensure that job opportunities arising from employment development are accessible to all the city’s working age residents, particularly priority groups and those in the most deprived areas of the city.

5.5.4 Policy AC1 of the Local Plan encourages and supports development proposals which are integrated with existing transport networks including roads, public transport and walking and cycling routes to promote access by a choice of transport modes.

5.5.5 Policy AC4 of the Local Plan states that walking and cycling should be encouraged as part of development proposals, and high-quality cycle parking should be provided.

5.5.6 Policy AC5 of the Local Plan states that new major development proposals should have safe and convenient access to the existing bus network. In areas where this is not achieved, new development may be required to include the provision of appropriate bus infrastructure to enable services to be fully integrated into the development site.

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5.5.7 Policy AC6 of the Local Plan is focussed on rail services and provides that there will be encouragement and support for further improvements to the quality of local rail services and access to stations and rail interchange.

5.5.8 Policy R2 of the Local Plan states that the city centre will continue to be developed and regenerated to ensure it is a truly world class city centre, leading in design, sustainability and culture. The supporting text indicates that this will be achieved by making Coventry accessible for all, providing an attractive and safe environment for pedestrians, cyclists and motorists; providing a high-quality public transport system that benefits from seamless integration and is well connected to existing and new infrastructure.

5.5.9 Policy DS3 of the Local Plan states that the Council will take a positive approach towards development proposals that accord with the sustainable development principles contained within the NPPF. These include development proposals that improve access to sustainable modes of transport.

5.6 Development Plan: Coventry City Centre Area Action Plan (2017)

5.6.1 The CCAAP provides a planning policy framework which guides, informs and can be used to test the appropriateness of development proposals within Coventry City Centre.

5.6.2 The CCAAP complements the Local Plan and in doing so provides both additional detail and policies.

5.6.3 The principal aim of the CCAAP is to provide the platform from which to regenerate and develop the city centre for the next 15 years. This involves the provision of new homes, employment space, new retail and leisure, together with social and community facilities.

5.6.4 Policy CC1 of the CCAAP states that the city centre will continue to be developed and regenerated to ensure it is a truly world class city centre, leading in design, sustainability and culture. It indicates that the city centre will continue to be developed and regenerated to ensure it is a truly world class city centre; leading in design, sustainability and culture. The policy indicates that this will be achieved by enhancing its position as a focus for the entire sub-region and as a national and international destination to live, work and play. The policy also notes that this ambition will be delivered by schemes which deliver; accessibility for all and a connected public realm including public squares and green

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spaces, easily accessible through the creation of desirable and legible pedestrian routes;

5.6.5 The supporting text indicates that this will be achieved by making Coventry accessible for all, providing an attractive and safe environment for pedestrians, cyclists and motorists; providing a high-quality public transport system that benefits from seamless integration and is well connected to existing and new infrastructure.

5.6.6 Policy CC3 requires all new buildings to satisfy prescribed design criteria and to maximise energy efficiency and limit carbon emissions and the resultant impact upon the environment. One of the specific criteria is the provision of secure cycle storage to help promote both the city’s sustainability initiative and the city’s public health objectives.

5.6.7 Policy CC6 requires all new development to incorporate high quality hard and soft landscaping using a palette of materials appropriate to the city centre.

5.6.8 Policy CC10 requires new development to be designed to minimise environmental impact within the city centre and ensure that any impacts of pollution are appropriately considered and mitigated.

5.6.9 Policy CC11 of the CCAAP states that development proposals in the city centre will be required to incorporate improvements to the specified pedestrian and cycle routes and linkages into the city centre. It also states that development proposals (Planning applications etc) should have regard to, and where appropriate, make provision for the delivery of the Coventry Station Masterplan. This policy also explicitly supports the delivery of integrated public transport infrastructure such as the proposed bus interchange. The supporting text explains that improved provision for bus services will be created at Coventry Station through the construction of a new bus interchange as part of the Coventry Station Masterplan.

5.6.10 Policy CC12. The policy requires development proposals within the Friargate (Business Area) to be informed by the Coventry Station Masterplan. The policy specifically cites that the provision of public transport infrastructure delivered in accordance with the Station Masterplan and NUCKLE project are acceptable. The policy also cites that improvements to and expansion of the Coventry Railway Station are acceptable.

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5.7 National Planning Policy Framework

5.7.1 The NPPF sets out the Government’s planning policies for England and how these should be applied.

5.7.2 The Local Plan and the CCAAP were both adopted in 2017. They were prepared having regard to the NPPF which was issued in 2012. Subsequent to the adoption of both plans, modifications have been made to the NPPF in July 2018 and February 2019.

5.7.3 I have carried out a review of the changes made to the NPPF in both July 2018 and February 2019. Those that I consider to be relevant to the justification of the Order and the strategic policy framework are described below.

5.7.4 Whilst the definition of what is meant by the presumption in favour of sustainable development was altered, the changes do not have implications for the Order, the CPO Scheme or the Full Scheme (Chapter 2).

5.7.5 Modifications have been made to the NPPF which have implications for the process and content of development plans being prepared (at the time of the publication of the changes) and in the future. These include a requirement for authorities to review Plan policies at least once every 5 years following the date of adoption, with updates, as necessary (Chapter 3). The implications of these changes are that policies within both the Local Plan and the CCAAP should be reviewed in advance of December 2022. However, in advance of that date the policy in the NPPF means that full weight can be attributed to the policies in both plans in the determination of applications and for the purpose of providing the strategic policy framework for the purposes set out in paragraph 104 of the MHCLG Guidance.

5.7.6 Modifications to Chapter 9 ‘Promoting Sustainable Transport in the NPPF’ require sites which may be allocated for development in plans, or specific applications for development to ensure that….” appropriate opportunities to promote sustainable transport modes can be – or have been – taken up, given the type of development and its location” (NPPF paragraph 108). The modifications indicates that local planning authorities when considering applications for development should applications for development should… “give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring

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areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use” (NPPF paragraph 110).

5.7.7 The Local Plan, CCAAP and the Coventry Station Masterplan include policies which use similar criteria and establish these priorities. However, in my view the modifications to the NPPF further strengthen the policy importance of decision making on planning matters facilitating access to high quality public transport.

5.7.8 Chapter 9 of the NPPF starts with importance of considering transport issues from the earliest stages of plan-making and development proposals. Paragraph 102 then provides what can be considered to be strategic policy framework which will allow transport matters to be so considered that;

 the potential impacts of development on transport networks can be addressed;  opportunities from existing or proposed transport infrastructure, and changing transport technology and usage, are realised – for example in relation to the scale, location or density of development that can be accommodated;  opportunities to promote walking, cycling and public transport use are identified and pursued;  the environmental impacts of traffic and transport infrastructure can be identified, assessed and considered – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains; and  patterns of movement, streets, parking and other transport considerations are integral to the design of schemes and contribute to making high quality places.

5.7.9 Paragraph 103 requires the planning system to actively manage patterns of growth in support of achieving the outcomes set out in paragraph 102. In so doing Planning authorities are expected to direct significant development towards locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.

5.7.10 Paragraph 104 (a) requires planning authorities to adopt policies which support an appropriate mix of uses across an area, and within larger scale sites, to minimise the number and length of journeys needed for employment, shopping, leisure, education and other activities.

5.7.11 Paragraph 104 (b) requires planning authorities to prepare policies with the active involvement of local highways authorities, other transport

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infrastructure providers and operators and neighbouring councils, so that strategies and investments for supporting sustainable transport and development patterns are aligned.

5.7.12 Paragraph 104 (c) requires planning authorities to identify and protect, where there is robust evidence, sites and routes which could be critical in developing infrastructure to widen transport choice and realise opportunities for large scale development.

5.7.13 Paragraph 104 (e) requires planning authorities to provide for any large- scale transport facilities that need to be located in the area, and the infrastructure and wider development required to support their operation, expansion and contribution to the wider economy. The footnote to part (e) indicates that ‘Policies for large scale (public transport) facilities should, where necessary, be developed through collaboration between strategic policy-making authorities and other relevant bodies”.

5.7.14 Paragraph 108 (a) requires planning authorities when determining applications to ensure that ‘appropriate opportunities to promote sustainable transport modes can be – or have been – taken up, given the type of development and its location’.

5.7.15 Paragraph 108 (b) requires planning authorities when determining applications to ensure that safe and suitable access to the site can be achieved for all users.

5.7.16 The modifications made to the NPPF in February 2019 are (minor and technical) with regard to; ‘housing supply’, the provision of ‘guidance concerning housing and economic needs assessments’ and ‘appropriate assessment and habitats’. These modifications are not relevant to the Order lands, the CPO Scheme or the Full Scheme.

5.7.17 In my professional opinion the relevant development plan policies are up to date having regard to the modifications made to the NPPF in July 2018 and February 2019. I consider that the modifications at paragraph 110 lend additional weight to the policies of the Local Plan and CCAAP, and to the case for confirmation of the Order.

5.8 National Planning Practice Guidance (NPPG)

5.8.1 NPPG is a web-based resource which brings together planning guidance on various topics. It was launched in March 2014 and coincided with the cancelling of the majority of Government Circulars which had previously given guidance on many aspects of planning. It is important to note that

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the guidance is exactly that, guidance, and should not be seen as representing Government policy.

5.8.2 Frequent modifications are made to NPPG to assist in the interpretation and implementation of the NPPF. The most recent modifications to the planning practice guidance were made in July 2019.

5.8.3 I have undertaken a review of the modifications made to the NPPG subsequent to the adoption of the Local Plans in December 2017. These modifications do not include matters which cause me to change my view that the relevant development plan policies are up to date with regard to the modifications made to the NPPF in July 2018 and February 2019.

5.8.4 In undertaking a review of the NPPG I find that the guidance relating to chapter 9 of the NPPF provides technical guidance on the preparation of transport assessments and similar. I am of the view that the NPPG does not add to the strategic policy framework against which this Order will be considered.

5.9 Other Relevant Plans and Policies

5.9.1 There are a number of approved plans which contain adopted policies which are relevant in so far as they form part of the strategic policy framework which supports the Order (paragraph 104 MHCLG guidance). These are as follows;

5.9.2 The Transport for West Midlands Movement for Growth Strategic Transport Plan for the West Midlands (2017) (Core Document D5) has been established by the WMCA. The Plan aims to address 5 core challenges; Economic Growth and Economic Inclusion, Population Growth and Housing Development, Environment, Public Health and Social Well-Being.

5.9.3 The Plan provides a set of 15 policies which are designed to support the improvements of the West Midlands transport system.

5.9.4 In so far as the CPO Scheme and the Full Scheme form part of the Coventry Station Masterplan they are central to the achievements of the objectives of ‘Movement for Growth’ in terms of its contribution to the Midlands economic ‘Engine for Growth’. As such the CPO Scheme and Full Scheme ‘functions as a great and efficient example through its sustainable, attractive, resilient, safe and economically vibrant features as it integrates different modes of public transport seamlessly whilst

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being embedded within the greater infrastructure network of the Midlands’.

5.9.5 The most relevant policies to the CPO Scheme and the Full Scheme are set out below;

5.9.6 Policy 1: Increased travel demand will be accommodated by existing transport and new sustainable transport capacity. This will be reflected by the future ready approach of Coventry Station by considering future transport demand.

5.9.7 Policy 2 and Policy 3: Existing transport capacity will be used more effectively to provide greater reliability and average speed for the movement of people and goods.

5.9.8 Policy 4: Connections to new economic development locations will be improved to help them flourish, primarily through sustainable transport connections.

5.9.9 Policy 5: Economic centres will be shaped into attractive places where people wish to be. The new station development will add to Coventry in terms of its public realm and attractiveness and therefore acts as a future economic stimulus for investments and potential new company headquarters.

5.9.10 The 2026 Delivery Plan for Transport by the WMCA (Core Document D6) establishes the long-term strategy of Movement for Growth of the region. The Plan outlines in detail the different schemes and action plans for all modes of transport within the Midlands that are required to unlock economic growth opportunities, support wider initiatives and improve social wellbeing. The two primary focus points for Coventry are the importance of being “plugged in” to the two High Speed Rail Stations as well as the importance to steer transport investment into priority corridors for new jobs and homes.

5.9.11 Midlands Connect: Our Routes to Growth (Core Document D7) provides the strategic policy justification for a fundamental shift in how major infrastructure investment is planned and delivered in the Midlands. It has a suite of policy objectives which include more frequent rail services to and from existing stations to Coventry together with new direct rail services.

5.9.12 Midlands Connect was established in October 2015 with one objective - to determine what transport infrastructure was needed to boost the

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

region’s economy. It is made up of 22 local authorities, nine Local Enterprise Partnerships, East Midlands and Birmingham airports, and chambers of commerce.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

6.0 Planning History

6.1 Introduction

6.1.1 The MHCLG Guidance indicates that “the planning framework providing the justification for an order should be as detailed as possible in order to demonstrate that there are no planning or other impediments to the implementation of the scheme.”

6.1.2 One of the potential impediments to the implementation of the CPO Scheme is the need for planning permission.

6.1.3 This section describes the planning permissions and permitted development rights which are available to implement the CPO Scheme and confirms that there are no planning impediments to the implementation of the scheme.

6.1.4 This section also describes the planning permissions and permitted development rights which are available to implement the Full Scheme and confirms that there are no planning impediments to the implementation of the Full scheme.

6.2 The CPO Scheme

6.2.1 The CPO Scheme comprises the following works as set out in Section 4 above;

 Bus Interchange Building:

 Bus Parking and Manoeuvring:

 Central Six Access Road Improvements etc

 The new bay platform for Coventry Station

 Station Car Parking

6.3 Implementation

6.3.1 The entire CPO Scheme will be implemented by the Council. The Council will rely upon the express planning permissions as set out in this section.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

6.3.2 The council is negotiating with Network Rail to obtain the necessary other consents to implement the CPO Scheme where it is on or affects Network Rail operational land.

6.3.3 Notwithstanding the availability of express planning permissions some works within the scope of the scheme can be carried out using permitted development rights as set out in this section.

6.3.4 In the event that minor or other modifications to the scheme are required then the Council may rely upon permitted development rights where these are available to make such changes to the scheme.

6.4 The CPO Scheme: Permitted Development Rights

6.4.1 The Works to construct the infrastructure etc. and the new bay platform are permitted development under Class A of Part 18 of Schedule 2 to the Town and Country Planning (General Permitted Development) (England) Order 2015 (“the 2015 GPDO”).

6.4.2 The 2015 GPDO details certain types of development which can be undertaken without the need for planning permission to be obtained. Of particular relevance to this Inquiry are the parts set out below:

 Class A of Part 8 of Schedule 2 sets out that development by railway undertakers on their operational land, required in connection with the movement of traffic by rail is permitted.

 Class A of Part 18 of Schedule 2 sets out the development under local or private Acts or Order which is permitted development pursuant to the 2015 GPDO. The London and Birmingham Railway Act 1833 and the London and Birmingham Railway Act (Coventry and Nuneaton Railway) 1846 provides Network Rail, as successor in title to the authorising Act, with the power to undertake future works not limited to the construction of the railway.

6.4.3 The Council, in its capacity as highway authority, is able to exercise powers under the Highways Act 1980 to make alterations and improvements to the highway.

6.5 The CPO Scheme – Planning Permission

6.5.1 Planning Permission FUL/2018/1733 was granted for ‘Construction of a single-storey bus interchange, including passenger facilities (including waiting area and seating, retail/ cafe kiosk concession), pedestrian lift up

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

to Warwick Road, staff welfare facilities, with associated lighting, soft and hard landscaping, services and boundary treatment. Construction of; bus waiting and standing areas and pedestrian access tunnel under Warwick Road. Stopping up highway’ on 27th June 2018.

6.5.2 The design of the approved development has been informed and constrained by the need to include dedicated safe vehicular access into the site from the upgraded Central Six access road and the need to include a separate vehicular access into the upgraded Station Car park. Visibility splays and safety considerations have fixed the positions of the two junctions onto the upgraded Central Six access road. Access to the bus stands and waiting areas is designed for and restricted to bus, coach and authorised vehicles only. The design and layout of the bus stands and manoeuvring has been informed by discussions with bus operators and with reference to relevant standards. The reconfigured Station Car Park includes accessible parking provision and drop-off.

6.5.3 Although the Station Car Park is level, there is a significant level change between the car park and Warwick Road. This level change varies between four metres adjacent the railway and two metres at the roundabout and needs careful consideration in order to provide an interchange that responds to the various pedestrian approaches. The design solution which has received planning permission includes a two- level concourse—the lower concourse at the level of the Western Car Park and proposed bus apron, the upper concourse at the level of the Warwick Road. This two-level design includes vertical circulation in the form of a stair, step free vertical circulation is provided by a lift. Together this allows for seamless circulation across all levels of the site. The location of the site adjacent to Warwick Road and the reconfigured roundabout will give the bus interchange a visual presence and allow it to act as an identifier for the bus interchange.

6.5.4 The Warwick Road pedestrian access tunnel (currently under construction) provides the opportunity to create a direct link between the new station building and the bus interchange, improving connectivity between various transport modes. The scheme facilitates step free movement across the site.

6.5.5 The design of the building responds to the key pedestrian approaches and desire lines and takes account of the need for new circulation arrangements associated with the new bay platform.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

6.5.6 Cycle access will be from the Central Six access road. Cycle parking will be located adjacent to the northern edge of the interchange building between the building itself and the highway beyond.

6.5.7 The application for planning permission was determined under the ‘scheme of delegation’ within the council. This provides for officers of the Council to grant planning permission subject to the following limitations;

 Any decision must comply with the Core Strategy and all other appropriate City Council policies, standards or guidelines.  Any decisions must not be the subject of five or more unresolved public representations which are material planning comments and which are take a contrary view to that of the planning officers.  Any decision must not be the subject of any unresolved conflicts of advice from other City Council Directorates as statutory consultees.  No Member of the City Council having objected to the application being a delegated decision and requested it to be considered by Committee, having first given material planning reasons in writing.

6.5.8 The application generated an almost negligible level of objections, and so under the scheme of delegation did not need to be reported to or determined by a planning committee. This reflects the fact that in planning terms the application (and therefore the CPO Scheme) is remarkably uncontroversial and clearly in the public interest.

6.5.9 The case officer in the determining report confirmed that the proposal was compliant with Policies AC2, AC4, AC5 and AC6 of the Local Plan, and “is clearly in accordance with Policy as it accords with the station masterplan and would help to improve access to and from the train station without using the private car. As a result, the proposal will contribute towards sustainable development”. The officer report noted there were no objections from internal or statutory consultees.

6.5.10 The officer report stated that “Policy CC12 of the City Centre Area Action Plan states that development proposals will be informed by the approved Masterplan. Part (e) of the policy states that public transport infrastructure delivered in accordance with the Station Masterplan will be supported.”

6.5.11 The Officer report indicated that neighbours were notified and site and press notices were posted following the submission of the application.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

Only two objections were received, and the officer was of the view that the issues raised were not sufficient to overcome the compliance of the proposal with the development plan. The officer report concluded that none of the matters raised in the two representations made in response to the consultation were such as to call into question the presumption in favour of the scheme by virtue of compliance with the development plan polices.

6.5.12 The report acknowledged that the scheme would not provide the exact same uses on the same site as indicated on the Friargate masterplan (OUT/2011/0036). However, the report confirmed that; a bus interchange, retail units and car parking are all proposed by Friargate and the approval of this application would not prejudice the implementation of the Friargate Masterplan.

6.5.13 Planning permission was granted with conditions. The conditions included those; requiring compliance with the submitted scheme and drawings; commencement within three years; the submission of materials and minor details for approval of the local planning authority; with some required to be discharged in advance of construction starting; and others in advance of the occupation of the development.

6.5.14 It is important to note that the conditions are largely ‘compliance’ with the submitted scheme. As such there is only one pre-commencement condition requiring the submission and prior approval of the external finishes for the bus interchange building. This is a standard condition and can be discharged swiftly and certainly within the standard 8 weeks.

6.5.15 The application generated a very low level of objections having regard to its significance, prominence and the publicity afforded to the proposals. None of the small number of objectors requested that the application be heard by the planning committee. Under the Council’s scheme of delegation the decision was delegated. This reflects the fact that in planning terms the application (and therefore the Full Scheme) is uncontroversial and clearly in the public interest.

6.5.16 A prior approval application was submitted by myself on behalf of the Council to the Council in its capacity as the local planning authority for the new bay platform (ref: PA/2018/2938). Prior approval was granted on 20th December 2018. This includes only one condition relating to the compliance with the submitted plans.

6.5.17 Based on the above assessment planning permission has been granted for the majority of the CPO Scheme with only one pre-commencement

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

condition. Prior approval has been secured for the new bay platform. I am of the view therefore that there are no planning impediments to the implementation of the CPO Scheme.

6.6 The Full Scheme

6.6.1 The Full Scheme comprises the following as set out in Section 4 above:

 A new footbridge  Extensions to the existing platform canopies  The new NUCKLE bay platform for Coventry Station  Warwick Road etc. Improvements  the New Station Building  The multi storey car park  Temporary Car Park  The ‘western link road’  Relocation of Rail station taxi ranks  Relocation of the existing cycle parking facilities  Improvements to the public and private realm

6.7 The Full Scheme – Permitted Development Rights

6.7.1 As explained above, the 2015 GPDO details certain types of development which can be undertaken without the need for planning permission to be obtained. Of particular relevance to this inquiry are the parts set out below:

 Class A of Part 8 of Schedule 2 sets out that development by railway undertakers on their operational land, required in connection with the movement of traffic by rail is permitted. This part of the 2015 GDPO has not been relied upon to allow Network Rail to undertake works to implement the Full Scheme.

 Class A of Part 18 of Schedule 2 sets out the development under local or private Acts or Order which is permitted development pursuant to the 2015 GPDO. The London and Birmingham Railway Act 1833 and the London and Birmingham Railway Act (Coventry and Nuneaton Railway) 1846 permits Network Rail, as successor in title to the authorising Act, the power to undertake future works not limited to the construction of the railway.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

6.7.2 Part 18 states that permitted development applies when it is “authorised by (a) a local or private Act of Parliament [i.e. the Act of Parliament that authorised the construction of the railway]… which designates specifically the nature of the development and the land upon which it may be carried out… Development is not permitted unless the prior approval of the appropriate authority to the detailed plans and specifications is first obtained.”

6.7.3 Additionally, it is important to note that Part 18 states prior approval is “not to be refused… nor are conditions to be imposed unless they are reasonably satisfied that – (a) the development ought to be and could reasonably be carried out elsewhere on the land; or (b) the design or external appearance would injure the amenity of the neighbourhood and is reasonably capable of modification to avoid such injury.”

6.7.4 Coventry Station was authorised under the London and Birmingham Railway Act 1833 and extended under the London and Birmingham Railway Act (Coventry and Nuneaton Railway) 1846. The 1846 Act incorporated Section 16 of the Railway Clauses Consolidation Act (“RCCA”), which permits Network Rail, as successor in title to the authorising Act, the power to undertake future works not limited to the construction of the railway. The powers conferred under the RCCA allow for Network Rail to from time to time, alter, repair or discontinue the aforementioned works or any of them and substitute others in their stead, and do all other acts necessary for making, maintaining, altering, repairing or using the railway.

6.7.5 The decision of the Court of Appeal in Emsley v North Eastern Railway Company (1846) 1 Ch 418 confirmed that these powers are not restricted to the period of construction but can be invoked “from time to time”. The use of the original Act of Parliament as a means of using permitted development rights has also been upheld in an English Ministerial appeal decision (ref: APP/X/98/X5210/003059).

6.7.6 A prior approval application was submitted by myself on behalf of the Council (ref: PA/2018/2938). The LPA granted permission for the NUCKLE bay platform on 20th December 2018. This includes only one condition relating to the compliance with the submitted plans.

6.7.7 The footbridge and canopy extensions were the subject of a prior approval application (ref: PA/2017/3200) under Part 18 of Schedule 2 (Miscellaneous Development), Class A. This application was made by myself. The prior approval application was approved on 7th February 2018.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

6.7.8 The Council, in its capacity as highway authority, has general powers of improvement under s.62 of the Highways Act 1980. The Council intends to rely upon these powers to make alterations and improvements to Warwick Road and other highways associated with the Full Scheme.

6.8 The Full Scheme – Planning Permission and Listed Building Consents

6.8.1 The footbridge and canopy extensions were the subject of a listed building consent application (ref: LB/2017/3198). This was approved on 8th February 2018.

6.8.2 The new station entrance building and multi-storey car park was the subject of applications for both planning permission and listed building consent. The planning application (ref: FUL/2018/1732) was granted by planning committee on 15th November 2018. The listed building consent (ref: LB/2018/1810) was granted on 24th August 2018.

6.8.3 Planning Permission FUL/2018/1732 was granted for the ‘Construction of new station building providing a second entrance at the western end of the station, including passenger facilities, retail/café concessions, pedestrian lift access between concourse levels, staff welfare facilities, with associated lighting, soft and hard landscaping, services and boundary treatment. Construction of; new and temporary roads; and a new 634-space multi-storey car park’.

6.8.4 The new station building and MSCP will provide a new main station entrance, ticket hall, and retail units, with the MSCP located above and adjacent to the new station on 7 and a half levels. This will introduce increased massing to the west of the existing station. As a result, views to and from Warwick Road to the station will be reduced, with the addition of the height and mass of the car park.

6.8.5 The analysis of the setting of the existing Coventry Station informed the design and location of the new station building and MSCP. As the existing Coventry Station is a Listed Building great care has been taken to ensure that its setting would not be adversely impacted. The existing road and intervening car parking do not meaningfully contribute to the setting of the station or its heritage significance; indeed, they currently undermine the potential contribution of historic setting to the station on its western side.

6.8.6 The new station building and MSCP will not result in direct physical effects to the fabric of Coventry Station and its attached platform structures, and so there will be no harm to the building’s ‘significance’.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

The new buildings will change the current setting of Coventry Station and its attached platform structures. However, the designs minimise any potential effects that might result in harm to the significance of the listed station, whilst also enhancing the current setting of the station.

6.8.7 The heritage statement submitted as part of the planning application for the new station building and MSCP acknowledged that the development is part of a wider master planned approach to the development of Coventry Station and its immediate environs. The heritage statement concluded that the new station building and MSCP will result in a permanent minor (beneficial) change to the setting of the listed station resulting in no harm to the station’s significance.

6.8.8 The officer report to the Planning Committee recommended that the application be granted with conditions. The report explained that:

 The proposal is acceptable in principle.  The proposal will not adversely impact upon highway safety.  The proposal will not adversely impact upon the amenity of neighbours.  The proposal will not adversely impact upon the character of the area or heritage assets.  The proposal accords with Policies: DS3, JE7, DE1, HE2, AC1, AC2, AC3, AC4, AC5, EM4, EM5 and EM7 of the Coventry Local Plan 2016 and Policies CC1, CC2, CC3, CC6, CC10, CC11 and CC12 City Centre Area Action Plan together with the aims of the NPPF. 6.8.9 The report to the Planning Committee explained that “Policy CC12 of the City Centre Area Action Plan states that proposals in this area must be informed by the approved Masterplan, and that improvements to and expansion of Coventry railway station will be supported in accordance with the station masterplan, so long as it does not adversely affect the listed building. The proposal has been drawn up specifically to help deliver the station masterplan. Other aspects of the masterplan have either already received permission (such as the bus interchange and the extended platform canopies and additional footbridge) or are permitted development (such as the additional bay platform). As such the proposal clearly complies with Policy CC12.”

6.8.10 The report acknowledged the quality of the design of the proposed new station building and MSCP and drew the attention of the committee to

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

the fact that “the (new) NPPF increases the focus on achieving high quality design” and states that it is “fundamental to what the planning and development process should achieve”.

6.8.11 The report to the Planning Committee confirmed that no objections were received from: Conservation (CCC), Historic England, Cadent Gas, and that subject to conditions being imposed there were no objections from Environmental Protection (CCC), Drainage (CCC), Severn Trent, West Midlands Fire Service, or Highways (CCC).

6.8.12 Immediate neighbours and councillors were notified, and site and press notices were posted following the submission of the scheme. Only 6 letters of objection were received.

6.8.13 The officer report identified that one of the objections concerned possible adverse impact upon the commercial viability of Central Six Retail Park, if traffic congestion and queuing increases around the junction with Warwick Road.

6.8.14 The objector did not submit any evidence to substantiate the objection. The officer came to a view in the report that the weight attributable to the objection was not sufficient to overcome the overwhelming compliance of the proposal with the development plan policies. Addressing the objection to the committee in the report, the officer concluded: “whilst any adverse economic impact would be regrettable, the vast majority of the retail park lies outside of the defined City Centre and any impact would not outweigh the benefits associated with the development of the station building”.

6.8.15 The officer report concluded that there were ‘material considerations’ raised in the letters of objections. In considering the weight to be given to these representations (in determining the application) the officer was of the view that the considerations were not sufficient to undermine presumption in favour of the scheme by virtue of compliance with the development plan polices. The members of the planning committee in approving the application can be considered to have accepted that advice.

6.8.16 The report further identified that the proposal would not prejudice the Friargate masterplan (OUT/2011/0036). The indicative Friargate masterplan suggested that an office building would be located next to a small new station entrance building, with a new multi storey car park to the west of Warwick Road. However, the outline permission allows for both a new station building and a car park as well as retail uses in the

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

area. The officer was of the view that the ‘lost office floorspace’ could be accommodated by adding height to other indicative plots on the masterplan. Furthermore, the proposal complies with the Friargate permission requirement for a building on the site to have a minimum height of 26m. The Report identified that the indicative Friargate masterplan anticipated 868 sq. m of retail (Use Classes A1-A5) floorspace on the two plots which would have occupied the same space as the proposed station building. Given that the proposal includes 792 sq.m of retail floorspace the officer was of the view that this was compliant with the masterplan and would not prejudice the implementation of the Friargate masterplan.

6.8.17 I attach great weight to the fact that the scheme was granted planning permission by the planning committee on the basis that the scheme was compliant with the relevant development plan polices and the NPPF.

6.8.18 Conditions were imposed on the grant of planning permission. These included conditions requiring compliance with the submitted scheme and drawings; commencement within three years; the submission of materials and minor details for approval of the local planning authority; with some required to be discharged in advance of construction starting; and others in advance of the occupation of the development.

6.8.19 Some of the schemes to discharge come of the conditions have been prepared and submitted although none have yet been discharged by the local planning authority.

6.8.20 Application for Listed Building Consent: Listed Building Consent LB/2018/1810 was granted for “Construction of a new station building and multi storey car park with associated works” on 29th June 2018.

6.8.21 Neighbours were notified and site and press notices posted. No comments were received.

6.8.22 The scheme was granted planning permission following a determining report by the case officer. This indicated that as the proposal was for listed building consent, the only relevant issue was the impact of the development upon the listed building.

6.8.23 The officer report concurred with the submitted heritage assessment “that the proposal will alter the setting of the listed building and affect views from Warwick Road. However, the road and car park do not meaningfully contribute to the setting of the listed building at present. If

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

anything, they undermine the potential contribution of setting to the western side.”

6.8.24 The officer report concurred with the submitted heritage assessment that “the new building will knit together the ad hoc, fractured urban fabric to the west of the station and will create a more contained setting that sits more comfortably within the development framework of the area.”

6.8.25 The officer report supported the proposal as it will “make a positive impact to the significance of the station and will comply with Policy HE2 and the NPPF.” The report noted that the Council’s Conservation officer concurs and raises no objections.

6.8.26 Two conditions were imposed on the grant of Listed Building Consent planning permission. These require works to start within three years and to comply with the submitted scheme.

6.8.27 A planning application (ref: FUL/2019/1396) for the ‘Western link road’ is currently pending determination by the local planning authority for this element of the scheme. The link road is part of the Full Scheme and does not form part of the CPO Scheme.

6.8.28 Planning permission (ref: FUL/2018/1591) was granted on 3rd August 2018 for a temporary car park on land off Westminster Road. This car park opened to the public on 16th October 2018 and provides replacement car parking for the existing car parking that is to be lost during construction of the bus interchange and new station entrance building and MSCP. At present no objections have been made by statutory consultees or stakeholders.

6.8.29 The application for a temporary car park is expected to be granted permission in advance of the inquiry. An oral update will be provided at the inquiry.

6.8.30 Planning permission for the New Station Building and the MSCP includes provision for the relocation of Rail Station taxi ranks; relocation of the existing cycle parking facilities and improvements to the public and private realm.

6.8.31 Based on the assessment set out above, planning permission and Listed Building Consent has been granted for almost all of the elements of Full Scheme, with only a limited number of standard and expected conditions.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

6.8.32 The only outstanding permission which has yet to be granted is for the Link Road. It is anticipated that this will be granted during the Autumn of 2019. Prior approval has been secured for the new bay platform, footbridges and canopies. So far as I am aware there are no reasons to believe that planning permission for the Link Road will not be forthcoming. It is a development which accords with the relevant policies in the development plan and the NPPF and would deliver significant public benefits. There are no obvious grounds for believing that any adverse impacts would be such as to justify a refusal to grant planning permission.

6.8.33 I am of the view therefore that there are no planning impediments to the implementation of the Full Scheme.

6.9 Environmental Impact Assessment

6.9.1 A Request for a Screening Opinion (“RfSO”) was made on the 13th September 2017 pursuant to the Town and Country Planning (Environmental Impact Assessment) Regulations 2017.

6.9.2 The scope of the scheme which was the subject of the RfSO included all the works proposed for the Order Lands (the CPO Scheme) together with all the works proposed as part of the Full Scheme.

6.9.3 The following is the list of the proposed works and is taken from the RfSO:

 Extended canopies to the platforms to provide greater protection to rail users on the platforms,  A second footbridge to provide the capacity required to meet current and anticipated footfall at the station, and to provide a secondary means of escape from the platforms,  A new station building, to include a new main station entrance and ticket hall, and retail / café units to provide services to rail passengers,  A new multi-storey car park for station users on up to 5 upper levels over the new station building, providing up to 646 parking spaces,  Revised drop off, bus and taxi facilities,  Construction of new access/ egress roads associated with the new station building and multi-storey car park,  Walkway linking the at grade station car park and transport interchange to the west of Warwick Road to the new station building via an underpass under Warwick Road,

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

 A new transport interchange and associated highways off Station Road West comprising of up to six bus stands including rail replacement services,  New Station Square including open space around the new Western entrance and the current station building, and a  New taxi rank and creation of a ‘kiss and drop’ zone.

6.9.4 An oversight by the local planning authority meant the Screening Opinion was not issued in response to the request. This was remedied with the issuing of the opinion on 9th July 2019.

6.9.5 The Council’s opinion was that the scheme as described above was not EIA development and was not required to be accompanied by an Environmental Statement. In the light of that conclusion, I consider that the earlier oversight was inconsequential.

6.10 Other Applications: Friargate

6.10.1 The Council has supported the regeneration of the land and property around the Central Station. This regeneration initiative is referenced in the relevant development plans and is reflected in the ‘Friargate Masterplan’ and the ‘Friargate Scheme’. This Scheme aims to create a new ‘city quarter in Coventry, which both abuts and is to the north of the Order Lands.

6.10.2 The Friargate masterplan was granted outline planning permission for a mixed-use development; predominantly office accommodation with supporting residential, retail, hotel, leisure and community uses. The Friargate masterplan will provide approximately 14,500 jobs to the area through the proposed office space. Outline permission was granted for the scheme in 2011 (ref: OUT/2011/0036) Subsequently Reserved Matters applications have been submitted and construction work began in 2014.

6.10.3 The Friargate scheme was prepared and granted planning permission in advance of the CPO Scheme, Full Scheme and adoption of the Coventry Station Masterplan.

6.10.4 The outline permission for the Friargate scheme provides the broad parameters for the location of the proposed developments and plot densities. Subsequent Reserved Matters Applications are finessing the design of the individual plots. The officers’ reports which facilitated the grant of the planning permissions for both the CPO Scheme and the Full Scheme confirmed that the CPO Scheme would not compromise the implementation of the ambitions and intent of the Friargate Masterplan.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

6.10.5 The developments being constructed by and forming components of the Friargate Masterplan will benefit from the CPO Scheme and Full Scheme but are not dependent upon it.

6.11 Other Applications - City Centre South Masterplan

6.11.1 The Local Plan proposed a masterplan for the City Centre South area. The plan area is adjacent to the Friargate Masterplan and the Coventry Station Masterplan.

6.11.2 The City Centre South masterplan is focused on the regeneration of the area through attracting up to 10,000sq.m of new retail (Core Document B1, p.81) and significant visitor and leisure developments. These initiatives together with the Friargate Masterplan are expected to stimulate a shift of the city core of retail and leisure uses in a southerly direction towards the railway station.

6.11.3 The recently opened water park is amongst one of the early successes of the City Centre South masterplan regeneration initiatives which underpin the need for improved transport hub facilities.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

7.0 Assessment of the CPO Scheme

7.1 Introduction

7.1.1 This section includes an assessment of whether there is a ‘clear strategic framework’ …’ for the CPO Scheme which is founded on an appropriate evidence base, and to have been subjected to consultation processes, including those whose property is directly affected’.

7.1.2 I have undertaken a review of those policy documents which I believe to be relevant and which in my opinion provide the ‘required clear strategic framework’.

7.1.3 I am of the view that there is in place the required strategic framework and it is made up of documents at a national level (NPPF and NPPG) the Regional level (produced by WMCA, TfWM and others) and the local level (Local Plan, CCAAP and Coventry Station Masterplan).

7.1.4 This section sets out my opinions as to the relevance of each level of policy documents to providing the necessary framework. I also describe my views on the extent to which the contents of each of the documents supports and reinforces the others.

7.1.5 This section includes an assessment of the extent to which the purpose for which the land is being acquired fits in with the adopted Local Plan for the area and is consistent with the policies and objectives of the NPPF.

7.1.6 This section also addresses the requirement to ‘demonstrate that there are no planning or other impediments to the implementation of the scheme.’

7.2 ‘Clear Strategic Framework’ – Assessment of the CPO Scheme against the Local Policy framework

7.2.1 At the Local level the works required to implement the CPO Scheme include elements of the Coventry Station Masterplan. The works required to implement the Full Scheme will implement the current iteration of the Coventry Station Masterplan. Taken together, the works for the CPO and Full Schemes seek to implement the Coventry Station Masterplan.

7.2.2 The Coventry Station Masterplan was conceived as part of the policy framework and delivery mechanism for both the Local Plan and the CCAAP.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

7.2.3 I place great weight on the fact that the Local Plan and AAP have been the subject of extensive public consultation with stakeholders and land owners. I attach significance to the fact that following the public hearings, further consultation on the proposed modifications was held to allow stakeholders and landowners to make representations.

7.2.4 The representations to the Local Plan and the CCAAP did not include any objections to the planned outcomes from the Coventry Station Masterplan, and there were no objections made to the planned outcomes from the CPO Scheme or the Full Scheme. Those parties with an interest in the land and those that may be materially affected have had the opportunity to express their views but did not object to the policies that underlie the Coventry Station Masterplan and hence the planning policy case for the Order.

7.2.5 I attach great weight to the Inspector’s reports with regard to the Local Plan and the CCAAP. The Inspector identified modifications which were needed to be made to both plans. I am of the view that the Inspector’s modifications reinforced the importance and centrality of the CPO Scheme (and Full Scheme) in delivering the ambitions, objectives and policies of both plans.

7.2.6 It is significant for the purpose of justifying the Order that the conclusion in both of the Inspector’s reports is that with the main modifications both plans satisfy the requirements of Section 20(5) of the Planning and Compulsory Purchase Act 2004 and meet the criteria for soundness in the NPPF.

7.2.7 I consider that the development plan sets a clear strategic framework supporting the CPO Scheme as required by the MHCLG Guidance.

7.3 Assessment of the CPO Scheme against the Local Plan and CCAAP Policies

7.3.1 The following sections focus on the more detailed policy framework provided by the relevant Local Plan and CCAAP policies and examines each element of the CPO Scheme against the relevant policies. In my view each of the elements of the CPO Scheme is in accordance with the relevant policies contained within the adopted development plans and Station Masterplan. Indeed, I consider that delivery of the Coventry Station Masterplan (of which the CPO Scheme forms an important part) is central to the strategy for the City Centre set out in the development plan.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

7.3.2 This section therefore assesses the policy compliance of the elements of the CPO Scheme:

 Bus Interchange (Building, Bus Parking and Manoeuvring)  Central Six Access Road Improvements etc  A new bay platform for Coventry Station  Station car parking

7.4 Bus Interchange (Building, Bus Parking and Manoeuvring)

7.4.1 The provision of a bus interchange within the Order Lands is in accordance with the Local Plan and CCAAP as set out Section 5 above. I am of the view therefore that in accordance with Paragraph 106 of the MHCLG Guidance the purpose for which the land is being acquired fits in with the adopted Local Plan for the area.

7.4.2 It is my view that the bus interchange is compliant with the relevant policies in the Local Plan and CCAAP.

7.4.3 The bus interchange is compliant with Policy JE1 in that it will improve the accessibility of Coventry City Centre to local people by public transport. As such it is a development which will enable job opportunities in the city centre and beyond to be more accessible for residents. It will also provide more efficient operation of the bus network and improve accessibility to the most deprived areas of the city.

7.4.4 The bus interchange is compliant with Policy AC1 in that it will provide additional bus and pedestrian connection facilities within Coventry City Centre which separately and collectively will allow passengers to more efficiently shift between different modes of transport.

7.4.5 The bus interchange is compliant with Policy AC4 in that it will provide new footways and make connectivity between the bus interchange and the station more commodious and safer.

7.4.6 The bus interchange is compliant with Policy AC5 in that it is within Coventry City Centre and will allow passengers to more efficiently shift between bus lines, networks and between different modes of transport.

7.4.7 The bus interchange is compliant with Policy AC6 in that it allows pedestrians who are bus passengers to disembark at the interchange and walk perhaps only 30m to the new bay platform for the train service connecting Coventry to Nuneaton. (subject to access points being confirmed).

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

7.4.8 The bus interchange is compliant with Policy R2 in that it is located within the city centre and provides for a high quality aesthetically pleasing and sustainable new facility with access to all.

7.4.9 The bus interchange is compliant with Policy DS3 in that it will provide improved access to rail and cycling transit and modal shift facilities within Coventry City Centre which separately and collectively will allow passengers to more efficiently shift between different modes of transport.

7.4.10 The bus interchange will facilitate other developments to be more accessible. The provision of the bus interchange is therefore a central tenet for the successful implementation of Policies CC1 and CC11.

7.4.11 The bus interchange has been designed to accord with the criteria set out in the policy CC3 and is therefore compliant with the objectives of the Policy.

7.4.12 The bus interchange incorporates both hard and soft landscaping with a palette of materials which is consistent and integrated with the Full Scheme. In my professional view the bus interchange is compliant with Policy CC6.

7.4.13 The bus interchange has been informed by extensive surveys of the ground conditions, potential impacts on noise sensitive receptors and the potential impact on local air quality. The scheme has been designed to ensure that; any ground contamination is remediated; and construction methods mitigate any adverse impact on noise sensitive receptors and local air quality. In my professional view the bus interchange is compliant with Policy CC10.

7.4.14 The bus interchange forms part of the Station Masterplan and is therefore compliant with Policy CC12.

7.4.15 I am of the view that following my assessment above the Bus Interchange (Building, Bus Parking and Manoeuvring) is compliant with the relevant policies in the Local Plan, CCAAP and Station Masterplan.

7.5 Central Six Access Road Improvements etc

7.5.1 The provision for Central Six Road Improvements within the Order Lands is in accordance with the Local Plan and CCAAP as set out Section 5 above. I am of the view therefore that in accordance with Paragraph 106 of the MHCLG Guidance the purpose for which the land is being acquired fits in with the adopted Local Plan for the area.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

7.5.2 It is my view that the Central Six Road Improvements are compliant with the relevant policies in the Local Plan and CCAAP.

7.5.3 The Central Six Road Improvements are compliant with Policy JE1 in that they will improve the accessibility of Coventry City Centre to local people by public transport. As such it is a development which will enable job opportunities in the city centre and beyond to be more accessible for residents. It will also provide more efficient operation of the bus network and improve accessibility to the most deprived areas of the city.

7.5.4 The Central Six Road Improvements are compliant with Policy AC1 in that they will facilitate improved bus and pedestrian facilities within Coventry City Centre which separately and collectively will allow passengers to more efficiently shift between different modes of transport.

7.5.5 The Central Six Road Improvements are compliant with Policy AC4 in that they include the upgrading of the existing footways associated with access to the Central Six Retail Park. New footways will make connectivity between the bus interchange and the station more commodious and safer. The Central Six Road Improvements will also reduce the safety risks for cycle users of Warwick Road, the roundabout and the currently unadopted road into Central Six Retail Park.

7.5.6 The Central Six Road Improvements are compliant with Policy AC5 in that they allow the construction of the bus interchange and in so doing allow passengers to more efficiently shift between bus lines, networks and between different modes of transport.

7.5.7 The Central Six Road Improvements are compliant with Policy DS3 in that they will provide improved and safer access to rail, bus and cycling transit and modal shift facilities within Coventry City Centre which separately and collectively will allow passengers to more efficiently shift between different modes of transport.

7.5.8 The Central Six Road Improvements are compliant with Policy CC6 in that they will incorporate soft landscaping with a palette of materials which is consistent and integrated with the Full Scheme.

7.5.9 I am of the view that following my assessment above, the proposals for the Central Six Road Improvements are compliant with the relevant policies in the Local Plan, CCAAP and Station Masterplan.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

7.5.10 I am of the view that following my assessment above, the proposals for the Central Six Road Improvements are compliant with the relevant policies in the Local Plan and CCAAP.

7.6 A new bay platform for Coventry Station

7.6.1 The provision of a new bay platform is in accordance with the Local Plan and CCAAP as set out Section 5 above. I am of the view therefore that in accordance with Paragraph 106 of the MHCLG Guidance the purpose for which the land is being acquired fits in with the adopted Local Plan for the area.

7.6.2 It is my view that the new bay platform is compliant with the relevant policies in the Local Plan and CCAAP.

7.6.3 The new bay platform is compliant with policy JE1 in that it will improve the accessibility of Coventry City Centre to local people by public transport. As such it is a development which will enable job opportunities in the city centre and beyond to be more accessible for residents. It will also provide more efficient operation of the bus network and improve accessibility to the most deprived areas of the city.

7.6.4 The new bay platform is compliant with policy AC1 in that it will provide additional rail facilities within Coventry City Centre which separately and collectively will allow passengers to more efficiently shift between different modes of transport.

7.6.5 The new bay platform is compliant with policy AC5 in that it will provide a new platform within Coventry City Centre. This will allow passengers to more efficiently shift between networks and between different modes of transport.

7.6.6 The new bay platform is compliant with policy AC6 in that it will provide direct passenger access to the station. It also allows pedestrians who are bus passengers to disembark at the interchange and walk only approximately 30m to the new bay platform for the train service connecting Coventry to Nuneaton (subject to access points being confirmed).

7.6.7 The new bay platform is compliant with policy R2 in that it is located within the city centre and provides new rail services between Nuneaton and Coventry. As such the new bay platform assists in making Coventry more accessible for all.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

7.6.8 The new bay platform is compliant with policy DS3 in that it will provide improved access for rail, bus and cycling transit and modal shift facilities within Coventry City Centre which separately and collectively will allow passengers to more efficiently shift between different modes of transport.

7.6.9 The new bay platform is one of those developments cited in policy CC1 which will allow other developments to be more accessible. The provision of the new bay platform is therefore a central tenet of the Policy. In my professional view the new bay platform is compliant with Policy CC1.

7.6.10 The new bay platform is one of those developments cited in policy CC11 which will allow other developments to be more accessible. The provision of the new bay platform is therefore a central tenet of the Policy. In my professional view the new bay platform is compliant with Policy CC11.

7.6.11 The new bay platform is compliant with policy CC10 in that it has been informed by extensive surveys of the ground conditions, potential impacts on noise sensitive receptors and the potential impact on local air quality. The scheme has been designed to ensure that; any ground contamination is remediated; and construction methods mitigate any adverse impact on noise sensitive receptors and local air quality. In my professional view the CPO Scheme is compliant with Policy CC10.

7.6.12 The new bay platform is compliant with policy CC12 in that it will establish the NUCKLE platform in accordance with the Station Masterplan.

7.6.13 I am of the view that following my assessment above, the proposals for the new bay platform are compliant with the relevant policies in the Local Plan, CCAAP and Station Masterplan.

7.7 Station car parking

7.7.1 The Station car parking is an existing established use within the Order Lands. The works to the Station car parking as part of the CPO Scheme reduces the overall number of parking places from 236 to 70. This loss is more than compensated for by the construction of the Temporary car park for the duration of the construction period. When the MSCP is completed then the total provision will exceed the existing provision. The new MSCP includes 10 places for disabled users. The CPO Scheme

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

also upgrades the highway access and provides for step free access for users of the car park.

7.7.2 The provision of upgraded Station car parking within part of the Order Lands is in accordance with the Local Plan and CCAAP as set out Section 5 above. I am of the view therefore that in accordance with Paragraph 106 of the MHCLG Guidance the purpose for which the land is being acquired fits in with the adopted Local Plan for the area.

7.7.3 It is my view that the upgrading of the Station car parking is compliant with the relevant policies in the Local Plan and CCAAP.

7.7.4 The Station car parking is compliant with Policy JE1 in that it will improve the accessibility of Coventry City Centre to local people. It will also provide more efficient operation of the bus network and improve accessibility to the most deprived areas of the city.

7.7.5 The upgrading of the Station car parking is compliant with Policy AC1 in that it will improve pedestrian facilities within Coventry City Centre which separately and collectively will allow passengers to more efficiently shift between different modes of transport.

7.7.6 The upgrading of the Station car parking is compliant with Policy AC4 in that it will upgrade the existing footways associated with the car park and improve connectivity between with the bus interchange and the station.

7.7.7 The upgrading of the Station car parking is compliant with Policy DS3 in that it will provide improved access to rail, bus and cycling transit and modal shift facilities within Coventry City Centre which separately and collectively will allow passengers to more efficiently shift between different modes of transport.

7.7.8 The upgrading of the Station car parking is compliant with Policy CC3 in that it has been designed to accord with the criteria set out in the policy and will facilitate the modal shift from private cars to public transport.

7.7.9 The upgrading of the Station car parking is compliant with Policy CC6 in that it incorporates soft landscaping with a palette of materials which is consistent and integrated with the Full Scheme.

7.7.10 The upgrading of the Station car parking is compliant with Policy CC10 in that it has been informed by extensive surveys of the ground conditions, potential impacts on noise sensitive receptors and the potential impact on local air quality. The scheme has been designed to

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

ensure that; any ground contamination is remediated; and construction methods mitigate any adverse impact on noise sensitive receptors and local air quality.

7.7.11 The upgrading of the Station car parking is compliant with Policy CC12 in that it is in accordance with the Station Masterplan.

7.7.12 I am of the view that following my assessment above the proposed upgrading and works to the Station Car Park are compliant with the relevant policies in the Local Plan, CCAAP and Station Masterplan.

7.8 Assessment of the CPO Scheme against the NPPF

7.8.1 I have set out in section 5 my view that both the Local Plan and the CCAAP remain fully up to date with the revised version of the NPPF. I have set out in section 5.7.7 my view that one change made to the NPPF in 2018 strengthens the policy value and importance of the outcomes from the CPO Scheme (and Full Scheme).

7.8.2 I have carried out a review of the extent to which the NPPF provides support as part of the overall planning policy framework for the CPO scheme (and Full Scheme). I have set out my findings in the following paragraphs.

7.8.3 The implementation of the CPO Scheme (and the Full Scheme) reflects the demonstrable commitment of the City Council and its strategic partners to ‘consider transport issues from the earliest stages of plan- making and development proposals’ as required by the NPPF (paragraph 102).

7.8.4 The CPO Scheme (and the Full Scheme) have been designed to realise the City Council’s ambition of having a transport interchange which satisfies the criteria set out in paragraph 102;

 the potential impacts of development on transport networks can be addressed;  opportunities from existing or proposed transport infrastructure, and changing transport technology and usage, are realised – for example in relation to the scale, location or density of development that can be accommodated;  opportunities to promote walking, cycling and public transport use are identified and pursued;  the environmental impacts of traffic and transport infrastructure can be identified, assessed and taken into account – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains; and

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

 patterns of movement, streets, parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places.

7.8.5 I am of the view that in selecting the location for the bus interchange and new bay platform the City Council has acted in accordance with the requirements of Paragraph 103 that both are important in order to ‘actively manage patterns of growth in support of achieving the outcomes set out in paragraph 102’.

7.8.6 I am of the view that in conceiving of the Coventry Station Masterplan and selecting the Order Lands for the implementation of the CPO Scheme the Council has acted in accordance with the requirements of (the second part of) Paragraph 103 where the council is ‘expected to direct significant development towards locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes’.

7.8.7 The Local Plan and the CCAAP policies aim to bring significant residential and commercial development into the Station Masterplan Area. This is ‘significant development’ as set out in paragraph 103 and is compliant with the focus of the paragraph in that it is a ‘location which… can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes’. The paragraph then confirms the range of public benefits that can accrue from such development and transport provision; ‘This can help to reduce congestion and emissions and improve air quality and public health’.

7.8.8 I am of the view that in conceiving of the Coventry Station Masterplan and selecting the Order lands for the implementation of the CPO Scheme the Council has acted in accordance with the requirements of Paragraph 104 and is seeking ‘to minimise the number and length of journeys needed for employment, shopping, leisure, education and other activities’.

7.8.9 The Local Plan includes a set of sustainable development and travel policies which are designed to enable a greater availability of viable travel choices that can also promote healthier lifestyles, improved air quality and increased access to services, training, skills and education. These, along with high technology solutions to enable agile and home/remote working, are expected by the plan to reduce the car mode share for all trip purposes from 61% to 51% in the morning peak period. (Table 10.2 Coventry Local Plan). The Local Plan and CCAAP have a suite of policies designed to minimise the number and length of

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

journeys. Central to delivering this 10% reduction objective is the CPO scheme, in particular the Bus interchange and the new bay platform.

7.8.10 I am of the view that the Council has successfully established a clear strategic policy framework for the works proposed for the CPO Scheme (and Full Scheme) as required by Paragraph 104 (b). This requires planning authorities to prepare policies with the active involvement of local highways authorities, other transport infrastructure providers and operators and neighbouring councils, so that strategies and investments for supporting sustainable transport and development patterns are aligned.

7.8.11 I have considered the evidence of the actions of the Council and am of the view that the outcomes which the CPO Scheme will provide for Coventry are identified as critical to achieving the economic and transport ambitions of both the city and the West Midlands.

7.8.12 The outcomes which are needed from the CPO and Full Schemes are identified in three policy documents that have been adopted by a consortium of local and strategic planning, economic and transport authorities. The documents are: Midlands Connect: Our Routes to Growth, The 2026 Delivery Plan for Transport by the WMCA, and the TfWM Movement for Growth Strategic Transport Plan for the West Midlands (2017). I am of the view that this evidence demonstrates that there is a clear local, sub regional and regional policy framework which justifies the Order.

7.8.13 I have considered the evidence of the actions of the Council with regard to the CPO Scheme (and Full Scheme) and I am of the view that these are in accordance with Paragraph 104 (c). This requires planning authorities to identify and protect. sites which could be critical in developing infrastructure to widen transport choice and realise opportunities for large scale development.

7.8.14 In my view the Council has been proactive as required by paragraph 104 (c) in their actions to protect and secure the Order Lands for the purpose of providing the critical infrastructure needed to achieve the objectives of the Local Plan and CCAAP. I am of the view that the actions of the Council in securing partnerships, funding and planning permissions for the CPO Scheme has acted in accordance with the guidance in paragraph 104(c).

7.8.15 I have considered the evidence of the actions of the Council with regard to the CPO scheme (and Full Scheme) and I am of the view that these

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

actions are in accordance with Paragraph 104 (e). This requires planning authorities to provide for any large-scale transport facilities that need to be located in the area, and the infrastructure and wider development required to support their operation, expansion and contribution to the wider economy. In designing the CPO Scheme, the Council is working as required by paragraph 104 (e - footnote) in “collaboration between strategic policy-making authorities and other relevant bodies”.

7.8.16 The Council in preparing the evidence base for the Local Plan and CCAAP demonstrated the need for the Coventry Station Masterplan to both the Inspector and stakeholders.

7.8.17 It is my view therefore that the CPO Scheme and Full Scheme are important facilities which can provide the City of Coventry with ‘appropriate opportunities’ to promote sustainable transport modes’

7.8.18 It is important to note that the CPO Scheme has been designed to satisfy many of the accessibility and equality of opportunity objectives contained within the Local Plan and CCAAP. The implementation of these designs and objectives are only possible with the confirmation of the Order for the CPO Scheme which will allow the Full Scheme to implemented. Taken together the two schemes are in accordance with Paragraph 108 (b). This requires planning authorities when determining applications to ensure that safe and suitable access to the site can be achieved for all users.

7.8.19 I conclude from my assessment that the NPPF provides strong national policy support for the CPO Scheme as part of the overall planning policy framework.

7.9 Assessment of the scheme against Regional Policies

7.9.1 My evidence above at section 5.9 describes the ways in which the outcomes of the CPO Scheme (and the Full Scheme) are cited in three regional policy documents.

7.9.2 The achievement of the objectives and outcomes in the; TfWM Movement for Growth Strategic Transport Plan for the West Midlands (2017), the 2026 Delivery Plan for Transport by the WMCA and Midlands Connect: Our Routes to Growth is in part dependent upon the confirmation of the CPO order and the implementation of the CPO Scheme. The three policy documents demonstrate how the outcomes of

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

the CPO Scheme will contribute to the achievement of sub-regional and regional economic and transport objectives.

7.9.3 I am of the view that there is a clear interrelationship and interdependency between the elements of the CPO Scheme and the three regional policy documents.

7.9.4 I conclude from my assessment that for the CPO Scheme at a regional policy level there is the necessary clear strategic framework as required by the Guidance.

7.10 Conclusion

7.10.1 All of the works proposed to be undertaken upon the Order Lands, for which the Order is required are compliant with, and directly supported by, relevant polices in the Local Plan and the CCAAP. The policies in the Local Plan and the CCAAP are up to date with the National Planning Policy Framework.

7.10.2 All of the works proposed to be undertaken upon the Order Lands, for which the Order is required have been either granted conditional planning permission or have been granted prior approval.

7.10.3 The proposed acquisition of the Order Lands will allow the assembly of the land necessary to undertake the works to implement the CPO Scheme.

7.10.4 The implementation of the CPO Scheme will in turn allow the Full Scheme to be implemented.

7.10.5 The Local Plan and the CCAAP provide an up to date planning policy framework supporting the CPO Scheme, which includes detailed land use; environmental; economic development; transport and other policies. This local and city-wide framework of polices forms part of a wider strategic framework, as the City Council’s ambition to deliver the CPO scheme, the Full Scheme and the Coventry Station Masterplan is shared by Transport for the West Midlands and Midlands Connect. Both organisations have reflected this shared ambition in the publication of their strategic regional and sub regional economic development proposals.

7.10.6 My evidence in this section demonstrates how the requirements set out in Paragraph 104 of the MHLCG Guidance are satisfied because the programme of land assembly is a set within (and clearly supported by) a clear strategic framework. That framework is founded on an appropriate

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

evidence base, and has been subjected to consultation processes, including consultation with those whose property is directly affected.

7.10.7 The adopted local planning policy framework has been used to determine and grant permissions for the CPO Scheme. All the necessary planning permissions have been granted which will allow the implementation of the CPO Scheme.

7.10.8 Paragraph 106 of the Guidance indicates that one of the factors which the Secretary of State will take into account in deciding whether to confirm an order under section 226(1)(a) will be whether the purpose for which the land is being acquired fits in with the adopted Local Plan for the area.

7.10.9 In my professional opinion the land uses proposed for the Order Lands are compliant with the development plan policies and as such “fits in with the adopted Local Plan for the area”.

7.10.10 Section 6 includes the detailed evidence that justifies that all the requisite planning permissions have been granted and that there are no planning impediments to the implementation of the CPO Scheme. In this regard my evidence addresses paragraph 106 of the MHCLG Guidance.

7.10.11 Section 6 includes the evidence which demonstrates how the Council has taken into account the National Planning Policy Framework in the conceiving of the CPO Scheme. I consider that the evidence demonstrates that the NPPF provides the necessary support for the confirmation of the Order as part of the overall planning policy framework. In this regard my evidence takes account of Paragraph 106 of the MHCLG Guidance.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

8.0 Planning Benefits of the CPO Scheme

8.1 Introduction

8.1.1 This section describes the planning related public interest benefits that will arise from the implementation of the CPO Scheme, and thus from confirmation of the Order.

8.1.2 It also identifies the benefits which will arise as a result of the Order being confirmed by virtue of the fact that other elements of the Full Scheme can then be completed or implemented.

8.1.3 It also identifies where the realisation of the full benefits of the Full Scheme depend upon the implementation of the CPO Scheme.

8.1.4 Works to construct the Warwick Road pedestrian underpass have started. None of the other physical works associated with the CPO Scheme have been started. However, a significant proportion of the preparatory and design works have been completed to allow the CPO Scheme to be implemented.

8.2 Full Scheme – Completed works

8.2.1 Some of the Full Scheme works have been completed. These include the following:

a. Acquisition and demolition of the Rocket Public house: this acquisition will allow the construction of the new road to allow access directly from the station to the Warwick Road roundabout.

b. Construction of the temporary car park on land off Westminster Road: this will provide car parking which will replace the existing car parking that is to be lost during construction of the bus interchange and new station entrance building /MSCP.

8.2.2 Although the public house has been acquired and demolished the public benefits cannot accrue until the Full Scheme modifications and improvements are made to the Warwick Road. The improvements to highway safety and the highway connectivity for the station cannot be made until the Council has control over the Order Lands, and in particular control over the access road to Central Six Retail Park.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

8.2.3 The provision of the new car parking at Westminster Road is already of benefit to both commuters and visitors to the city centre. However, it has created a surplus in local car parking capacity and will remain underutilised until the works to construct the bus interchange start and the current surface car park on the Order Lands is no longer available. As such the car park is an underutilised resource.

8.2.4 Some of the Full Scheme works have started. These include the construction of the Warwick Road underpass and landscaping improvements to the public realm. However, the public benefits of these works cannot be fully realised until the works to implement the CPO Scheme are completed.

8.2.5 Works to construct the Warwick Road underpass have started in order to deliver step free access across the site and from the existing station car park though to the station building. However, the underpass cannot be completed or ‘broken through’ until the Order Lands are under the control of the Council.

8.2.6 The benefits arising from the implementation of the CPO Scheme will accrue to a diversity of individuals and protected communities who are both resident in Coventry and visiting the city. However, these protected groups and in particular disabled users will continue to be disadvantaged whilst; the existing station car park does not include parking for disabled users; and step free access is not available from the car park to the station.

8.2.7 The benefits arising from the confirmation of the Order and the implementation of the CPO Scheme will be experienced as each element of the CPO Scheme and Full Scheme is implemented. Taken together there will be significant long-term public benefits.

8.2.8 These benefits for the future of the city will be economic, social and environmental as set out in this section and in the evidence of Mr Colin Knight at section 9.6.

8.2.9 The centrality of the CPO Scheme and the Full scheme to delivering the ambitions of the Council for the 2021 City of Culture Programme are explained in the evidence of Mr Colin Knight at section 3.9.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

8.3 Highways and Transport Connectivity

8.3.1 The implementation of the CPO Scheme will allow the Highways and Transport Connectivity benefits of the Full Scheme (as approved by the Planning permissions and Prior approvals) to be realised.

8.3.2 The CPO Scheme provides Highways and Transport Connectivity benefits including the construction of a bespoke dedicated bus interchange for the City. The additional bus services which the new interchange will facilitate and the co-location of these with the station will be more visible and accessible for bus travellers. This will assist in achieving the Local Plan and Council’s ambition of shifting mode to rail and vice versa.

8.3.3 The implementation of the CPO Scheme will allow the improvements to be made to the highway network for vehicles accessing the station forecourt and the new MSCP. The CPO Scheme will allow the construction of the New Station building and MSCP.

8.3.4 The implementation of the CPO Scheme will enable the construction of the new bay platform. In so doing, this will allow additional train services to be operated from Coventry Station. The additional platform and additional train services will improve the operational capacity of the Station to accommodate the predicted growth in passenger numbers.

8.3.5 Further information regarding the highway and connectivity benefits of the scheme are presented within the Evidence of Mr Knight.

8.4 Regeneration

8.4.1 The implementation of the CPO Scheme will assist in the economic and physical regeneration of; the CPO Lands; the area of the Full scheme; and the City Centre more widely. The replacement of the unkempt and inefficient spaces (which make up some of the Order Lands and the land for the Full Scheme) with new public realm and transport infrastructure will stimulate interest in the regeneration of the City Centre.

8.4.2 Confirmation of the Order will remove uncertainty as to the timescale and likelihood of the bus interchange and bay platform being completed. This certainty will provide confidence to the local development and property market. It is anticipated that the completion of the CPO Scheme will therefore contribute to a ‘kick start’ for brownfield developments in and around the station including those plots within the Friargate Masterplan and Station Masterplan.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

8.4.3 The CPO and Full Schemes are essential to the delivery of the transport infrastructure required to attract inward investment, create employment opportunities and encourage further economic growth in Coventry.

8.4.4 Taken individually or together, the CPO and Full Schemes will increase the ability of residents and local people to gain access to employment and training opportunities, local services and amenities. This will be through improvements to public transport infrastructure and capacity and the specialist provision of access for disabled users.

8.4.5 The CPO and Full Scheme taken together will provide a safe pedestrian environment with a hierarchy of defensible spaces. This will replace the existing unattractive and inefficient uses and spaces. The improvements will encourage all segments of the community to use the transport services and the CPO Scheme in particular.

8.4.6 The implementation of the CPO and Full Schemes will result in significant economic benefits to the local and regional economy. These benefits will start to accrue as soon as elements of the CPO Scheme are completed and as each element is completed, they will have a multiplying benefit to the local economy. Details of these long-term benefits are set out in the evidence of Mr Colin Knight at section 9.6.1.

8.5 Urban Design

8.5.1 The new bus interchange will provide a welcoming new gateway and arrival into the city for visitors by long distance coach and local bus. The improvements to the public realm proposed to be delivered by both the CPO and Full Scheme are designed to encourage those arriving by rail and bus to walk around the city centre. This is by virtue of replacing broken and unkempt street furniture, the installation of new signage, the removal of steps and the introduction of new surfaces. Both schemes implement policies within the CCAAP which are designed to increase the attractiveness of the city centre for pedestrians.

8.5.2 The CPO and Full Schemes both individually and taken together will deliver environmental and physical improvements to the public realm and this gateway into the city, in doing so it will improve perceptions of the area and of Coventry.

8.5.3 The CPO Scheme will allow the Full scheme to be implemented. Both the CPO and the Full Scheme have been sympathetically designed. Taken together, they conserve and enhance the cultural heritage of this

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

sector of the city to the planned programme for the city of Culture in Coventry. The bus interchange has been designed to be sympathetic to the setting of the Grade II listed railway station.

8.5.4 Careful consideration has been given to the design of the Full Scheme and the CPO Scheme. In so doing the approved designs respect the setting of the listed Railway station building whilst introducing exciting contemporary materials and building forms. The CPO and Full Schemes include landscaping which will celebrate the setting of and approaches to the listed building.

8.5.5 The new station building / MSCP and bus interchange have been designed to complement and integrate with the Friargate Masterplan by virtue of their massing and building typology. The two buildings are different in scale and mass, but similar in the drivers used for their design and architecture. This typology is reflected in the strong vertical element of the lift shaft to the bus interchange which creates a sense of stepping between the MSCP to the east and bus apron to the west.

8.5.6 The design of the new bus interchange reflects the architectural language of the existing railway station through the use of large glazed elements, canopies and solid forms. The architecture of the bus interchange responds to both the existing and future context of the site. The Friargate Masterplan will lead to significant redevelopment and change, providing offices, hotels and two new residential areas. The approved planning permissions for both the CPO and Full Schemes respect the plot boundaries and proposed highway works in the approved Friargate Masterplan. In so doing both the CPO and the Full Schemes do not prejudice the significant investment being made by the Friargate Masterplan into creating a unique architectural and urban design identity for the Friargate quarter.

8.5.7 The officer’s report for the planning application for the CPO Scheme states that: “the new bus interchange would provide some presence from Warwick Road. The proposed building would have an elegant sculpted roof, which would provide a welcome addition to the street- scene.”

8.5.8 The CPO and Full Schemes include the replacement of all street and public realm lighting. This will include energy efficient modern luminaires and attractive columns and installations. Taken together this will provide attractive safe spaces and routes with no light pollution and reductions in carbon emissions.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

8.6 Accessibility

8.6.1 The CPO Scheme has been designed to afford step free movement across the Order Lands and connecting into the New Station Building and MSCP. The bus interchange in combination with the proposed Station Building and MSCP allows this to extend from the Western Car Park through to the new Boulevard in front of the existing station building.

8.6.2 The pedestrian access to and within the bus interchange has been designed to be accessible for all users, especially those with visual and physical limitations.

8.6.3 The CPO Scheme will allow the Warwick Road pedestrian access tunnel to be opened. In so doing it will provide a direct link between the new station building and the bus interchange. This will provide for safe and easy connectivity between bus, train, and taxi modes for wheelchair users, people with limited mobility and passengers with buggies etc.

8.6.4 Taken together the CPO and Full Schemes will provide attractive and safe pedestrian connectivity between the railway station, bus interchange and the city centre.

8.6.5 The CPO Scheme will provide safe and defensible spaces which will encourage all parts of the community to use the transport services and the interchange.

8.6.6 The improved accessibility of bus services as part of the CPO Scheme will facilitate strong, vibrant and healthy communities by improving the accessibility of local services.

8.7 Environmental benefits

8.7.1 Carbon Emissions – the CPO and Full schemes form an important part of the Council’s ambitions to deliver a 10% modal shift from private fossil fuelled vehicles to sustainable public transport modes. This forms part of the Council’s suite of measures designed to reduce carbon emissions and the contribution of the city to climate change. (Table 10.2 Coventry Local Plan)

8.7.2 The CPO and Full Scheme will allow the Council to make provision for the extension of the district heat network to the west of Warwick Road within the new link road. The extension of the that network to the west of Warwick road will only be possible if the Council can undertake the works to the Warwick Road. The district heat network is designed to

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

reduce carbon emissions from buildings within the city by providing a low carbon heat source.

8.7.3 Air Quality – the CPO Scheme and the Full Scheme are both within the Coventry Air Quality Management Area (AQMA). Within this area there are occasions when the emissions from vehicle traffic leads to reductions in the quality of the local air. The Department of Environment, Food and Rural Affairs has published data on the correlation of poor air quality with vehicle congestion (Core Document C9). The AQMA identifies that the implementation of the Coventry Station Masterplan (CPO and Full Schemes) will reduce emissions from congestion generally and buses in particular, whilst also facilitating the desired modal shift from private cars (Measure 5.4).

8.7.4 The highway improvements which form part of the CPO Scheme (and Full Scheme) are designed to smooth traffic flows along Warwick Road and reduce the incidence of congestion in the vicinity of the Station.

8.7.5 The provision of the bus interchange is one of a city-wide suite of measures designed to reduce the incidence of poor-quality air. The provision of a bus interchange is specifically designed to provide additional public transport capacity. The CPO Scheme is designed to make public transport simpler and easier to use. This is expected to lead to a modal shift from cars to public transport and improvements in local air quality.

8.7.6 Modelling of the contribution that the city-wide suite of proposed measures to improve air quality has been undertaken. However, it is not possible to disaggregate from the model the contribution individual measures will make to improving local air quality. As such the measures in the CPO and Full Schemes can be expected to assist in reducing the emissions from vehicles and the pollution load in the air, both in the immediate vicinity of the site and in the city centre more widely, but the actual contribution cannot be stated.

8.7.7 Remediation of Contaminated Land- both the Full Scheme the CPO Scheme are being implemented on land which has been identified with the potential to host unexploded ordnance and other contamination. A desk-based assessment, prepared in support of the planning application, of the potential for unexploded ordnance indicated that there was the potential for the site to be contaminated. The construction of both schemes will ensure that any ordnance or contamination is remediated and made safe.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

8.7.8 Sustainable Drainage – the CPO and Full Schemes include the installation of a sustainable urban drainage systems (“SuDs”). Current surface water drainage systems in the Friargate and Station Masterplan area have a higher risk of flooding than is recommended for critical infrastructure.

8.7.9 The new SuDs will alleviate flooding and allow the immediate area to accommodate extreme rainfall events with less risk of adverse impacts on business continuity.

8.7.10 Habitat Creation and Landscaping – the CPO and Full Scheme deliver a net increase in the area of native shrub and tree planting with consequential improvements in the value of the landscaping for local biodiversity.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

9.0 Equalities Act

9.1 Introduction

9.1.1 This section describes the measures that have been taken by Coventry City Council to discharge their duties with respect to the Equality Act 2010.

9.2 The Duty

9.2.1 Section 149 of the Equality Act 2010 sets out a public sector equality duty that is applicable to all their functions, including CPO. Subsection (1) states that “A public authority must, in the exercise of its functions, have due regard to the need to:

eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under this Act;

advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;

foster good relations between persons who share a relevant protected characteristic and persons who do not share it.”

9.2.2 In the context of exercising compulsory purchase powers, the acquiring authority will be expected to have regard to the effect of any differential impacts on groups with protected characteristics.

9.3 Consultation

9.3.1 Coventry City Council have undertaken extensive consultation with stakeholders in advance of the submission of the various planning and Listed Building applications for the CPO and Full schemes. This pre- submission consultation took place with Network Rail, Virgin Trains, Standard Life (leaseholder), Central Six Tenants, local people the Disability Equalities Access Panel and the Access Development Group.

9.3.2 The Disability Equalities Access Panel (“DEAP”) is a ‘standing group’ which includes representatives from local charities and interested organisations to which have implications for people with disabilities are presented for comment.

9.3.3 The Access Development Group (“ADG”) includes representatives from the public sector as well as charities and provides specialist guidance on the ways in which schemes can be adapted to facilitate ‘access for all’.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

9.3.4 A presentation of the proposed CPO and Full Schemes was given to both groups. The proposals were well received with questions of clarification being answered by the officers. There will be ongoing engagement with the ADG during the implementation of the CPO and Full Schemes.

9.3.5 The pre-submission consultation with landowners focussed on confirming the ownership of various land parcels, understanding the regulatory requirements for the changes to the station lease area required for the bus interchange, MSCP and new station building, and the structure required for the scheme to progress as well as options for alternative future ownership. During the course of these meetings and in subsequent correspondence none of the stakeholders raised issues pertaining to equalities.

9.3.6 Subsequent consultation with stakeholders was through the provision of information on the Council’s website; together with exhibitions at six ‘drop in’ sessions. These sessions were designed to enable local people to view information about the CPO scheme, the Full Scheme and the overall development ambitions contained within the Coventry Station Masterplan. Consultants and staff from the Council were in attendance at the sessions to answer questions and gather feedback.

9.3.7 The Consultation sessions were held at the Central library in the city centre, three at the rail station and two at Central Six Retail Park close to the station. Approximately 200 people attended these sessions. No matters were raised by respondents pertaining to the obligations of the Council with respect to the Equalities Act.

9.4 Equality and Consultation Analysis

9.4.1 Subsequent to the consultation Coventry City Council have used the feedback from the consultation to undertake an Equality and Consultation Analysis (ECA”).

9.4.2 A summary of the ECA is as follows;

9.4.3 Age - The proposed improvements to the rail station would affect children, adults and older people who currently use the rail station. The improved access would benefit all users and make travelling to and through the station easier and safer.

9.4.4 Disability - Some of the users of the rail station will have a disability. The new station building has lifts and the access tunnel provides a safe

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

flat entrance to the new building. All platforms will be accessible without having to use stairs. The new station building will have a changing places facility. Safe crossing points will be provided, along with tactile paving and kerbs. Appropriate provision of reserved parking in the new MSCP will help to improve access to the rail station for blue badge holders. The new platform will have a wheelchair ramp to enable access to trains. Comments from the DEAP and ADG were supportive of the proposals and it was agreed that ADG would continue to be involved in the CPO and Full Schemes to ensure that the provisions of the Equalities Act continued to be taken into account.

9.4.5 Gender – There are no impacts in relation to gender.

9.4.6 Gender Re-assignment - There are no impacts in relation to gender reassignment.

9.4.7 Marriage/Civil Partnership - There are no impacts in relation to marriage/civil partnership.

9.4.8 Pregnancy/Maternity – The new station building will have designated baby changing facilities and appropriate parent/child parking spaces will be provided in the MSCP.

9.4.9 Race – There are no impacts in relation to race.

9.4.10 Religion/Belief - There are no impacts in relation to religion/belief.

9.4.11 Sexual Orientation – There are no impacts in relation to sexual orientation.

9.4.12 The ECA concludes that the CPO Scheme, the Full Scheme and the Proposals contained within the Coventry Station Masterplan will improve facilities for all the above groups. It concludes that the two Schemes will provide specific benefits to some of these groups who presently may be disadvantaged by current facilities. This will be by providing step free access and additional and improved facilities for the disabled, elderly and mothers of babies and young children.

9.4.13 The ECA has concluded that the CPO Scheme will actively deliver the ambitions of the Equality Act.

9.5 Equalities Act – Conclusion

9.5.1 In my opinion the Council have acted in a manner that is consistent with the need to devise a process which promotes equality of opportunity and

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

the overarching requirement to act in accordance with the equality duty set out in Section 149 of the Equality Act 2010.

9.5.2 I am of the view that works to implement the CPO Scheme on the Order Lands and the works to implement the Full Scheme will have a positive impact for protected groups and minorities as their interests have been actively taken into account in the design of the Schemes.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

10.0 Summary and Conclusions

10.1 Qualifications, Experience and Introduction

10.1.1 Section 1 confirms that I am a qualified Chartered Planner with 37 years’ relevant experience and this proof of evidence presents the planning related facts relating to the Order Lands and the CPO Scheme.

10.2 The Order Lands and Surroundings

10.2.1 Section 3 provides a detailed description of the current uses of the Order Lands, the physical characteristics, main features and topography and this includes reference to photographs and plans. The section also describes the uses, characteristics features and topography of the surrounding lands.

10.3 The CPO Scheme and the Full Scheme

10.3.1 Section 4 contains a full description of each of the elements which together form the CPO Scheme and the Full Scheme.

10.3.2 It also explains that the success and full realisation of the public benefits of the Full Scheme and the Coventry Station Masterplan are dependent upon the implementation of the CPO Scheme.

10.4 Planning Policy Context

10.4.1 Section 5 describes the guidance provided by MHCLG on the planning related evidence and the justification which is required for the confirmation of an Order.

10.4.2 This section describes the Planning Policy Framework for the CPO Scheme and the Full Scheme. It explains that the policies in the Local Development Plan have been holistically conceived, subjected to consultation with affected stakeholders and landowners; subjected to examination by an Inspector on behalf of the Secretary of State, modified to take account of both representations from landowners and the findings and recommendations of the Inspector; found to be ‘sound’ and adopted in accordance with relevant legislation.

10.4.3 This section includes my assessment of the extent of the compliance of each of the four principle elements of the CPO Scheme (Bus Interchange, Central Six Access Road Improvements, A new bay platform for Coventry Station, Station car parking) with specific policies of the Local Plan and the CCAAP.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

10.4.4 This section describes the changes that have been made to the NPPF and NPPG subsequent to the adoption of the Local Plans. It demonstrates that the Local Plans remain up to date with the NPPF and the NPPG.

10.4.5 The Council’s objectives and ambitions for the CPO Scheme are fully in alignment with the NPPF.

10.4.6 The section describes the regional level policies which are contained within three up to date plans. It presents evidence that the achievement of the objectives and ambitions of the three plans is (in part) dependent upon the implementation of the CPO Scheme and Full scheme.

10.5 Planning History

10.5.1 Section 6 describes planning permission (FUL/2018/1733) and prior approval (PA/2018/2938) which have been granted for the CPO Scheme. It presents evidence showing how that the planning application was determined to be in accordance with the up to date Local Plan and CCAAP and in accordance with the NPPF.

10.5.2 In the section I describe the decision-making process undertaken by the Council and the opportunities provided to landowners and affected parties to make representations. The planning application was considered to be uncontroversial by virtue of the fact that there were only two representations made in relation to the application. It was found to be in accordance with the development plans and in the absence of any significant level of objection could be and was determined by officers under delegated authority. I explain that the imposition of only one pre-commencement condition reflects the fact that the CPO Scheme is entirely compliant with the principles and detail of both local and national planning policy.

10.5.3 In this section I explain that there are no planning impediments to the implementation of the CPO Scheme.

10.5.4 Section 6 describes the planning permissions, listed building consents and prior approvals which have been granted for the Full Scheme. It describes the permitted development rights which are available to the Council in its capacity as Highway Authority to implement elements of the Full Scheme.

10.5.5 The section presents evidence showing how the applications for planning permission and Listed Building Consent were determined to be

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

in accordance with the up to date Local Plan and CCAAP and in accordance with the NPPF.

10.5.6 I describe the decision-making processes undertaken by the Council, and the opportunities provided to landowners and affected parties to make representations to all of the applications which together comprise the Full Scheme. The section includes my view that the applications for the New Station Building and MSCP are very widely supported, reflected in the fact that there were only six objections. None of these were considered by the officers or the Planning Committee to be sufficiently material to overcome the presumption in favour of the application. I explain that no representations were made to the application for the Temporary Car Park and no objections have so far been made to the application for the New Link road.

10.5.7 I conclude there are no planning impediments to the implementation of the CPO Scheme.

10.5.8 I conclude that both the CPO and Full Schemes can be implemented without prejudice to the implementation of the Friargate Scheme.

10.6 Assessment of the CPO Scheme

10.6.1 Section 7 demonstrates that all the works proposed to be undertaken upon the Order Lands, for which the Order is required, are compliant with relevant polices in the Local Plan and the CCAAP. The policies in the Local Plan and the CCAAP are up to date with the NPPF.

10.6.2 The proposed acquisition of the Order Lands will allow the assembly of the land necessary to undertake the works to implement the CPO Scheme.

10.6.3 My evidence shows that the Local Plan and the CCAAP provide an up to date planning policy framework supporting the CPO Scheme, which includes detailed land use; environmental; economic development; transport and other policies.

10.6.4 The local and city-wide framework of polices forms part of a wider strategic framework, as the Council’s ambition to deliver the CPO Scheme, the Full Scheme and the Coventry Station Masterplan is shared by Transport for West Midlands and Midlands Connect. I confirm in Section 7 that both organisations have reflected this shared ambition in the publication of their strategic regional and sub regional economic development proposals.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

10.6.5 My evidence confirms that the requirements set out in Paragraph 104 of the MHCLG Guidance are satisfied in so far as the programme of land assembly is set within a clear strategic framework, and that this is founded on an appropriate evidence base, and has been subjected to consultation processes, including those whose property is directly affected.

10.6.6 My evidence confirms that the approved local planning policy framework has been used to determine and grant permission for the CPO Scheme. All the necessary planning permissions have been granted which will allow the implementation of the CPO Scheme.

10.6.7 Paragraph 106 of the Guidance indicates that one of the factors which the Secretary of State will take into account in deciding whether to confirm an order under section 226(1)(a) will be whether the purpose for which the land is being acquired fits in with the adopted Local Plan for the area.

10.6.8 In my professional opinion the CPO Scheme is compliant with the development plan policies and as such “fits in with the adopted Local Plan for the area”.

10.6.9 All the requisite planning permissions have been granted, and there are no planning impediments to the implementation of the CPO Scheme (see paragraph 106 of the MHCLG Guidance).

10.6.10 Account has been taken of the NPPF in determining the planning application for the CPO Scheme (and Full Scheme). The NPPF provides strong support for both Schemes as part of the overall planning policy framework (see paragraph 106 of the MHCLG Guidance).

10.6.11 The CPO Scheme is compliant with the relevant polices in the two Development Plans.

10.7 Planning benefits of the scheme

10.7.1 Section 8 includes details of the planning and environmental benefits which will accrue as a consequence of the implementation of the CPO Scheme and the Full Scheme.

10.7.2 I make reference in my evidence to the significant public benefits arising to the Highway Network, Transport Connectivity, Economic Regeneration, Urban Design, Air Quality, Habitat creation and landscaping, and the remediation of Contaminated Land which will arise from the implementation of the CPO Scheme.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

10.8 Equalities

10.8.1 Section 9 of this proof describes the measures which have been taken by the Council to promote and protect the interests of ‘protected groups’.

10.8.2 The section includes my assessment of this evidence and I conclude that the CPO Scheme has been designed and will be implemented in ways that will protect and further the interests of protected groups.

10.9 Conclusion

10.9.1 The above evidence demonstrates that the CPO Scheme which will be delivered as a result of the acquisition of the Order Lands is entirely in conformity with planning policy.

10.9.2 I therefore contend that the CPO Scheme for which the land is being acquired fits in with the adopted Local Plans for the area (the Coventry Local Plan and the City Centre AAP) and the National Planning Policy Framework in accordance with paragraph 106 of the Ministry of Housing, Communities & Local Government ‘Guidance on Compulsory purchase process and The Crichel Down Rules’.

10.9.3 The scheme will deliver the bus interchange, new Bay Platform, New access road and new station car park. The scheme will facilitate the delivery of the Warwick Road improvements and the new rail station and multi storey car park, as well as the wider regeneration of the Station area. As such it will clearly achieve the promotion and improvement of the economic, social and environmental well-being of Coventry and its citizens.

10.9.1 Funding for the delivery of both the CPO scheme and the Full scheme is in place, as set out in Mr Knight’s evidence. Overall the focus on the area and the collaborative working between the various public agencies and other stakeholders has enabled a comprehensive approach to be taken to maximise the opportunity to transform the station area.

10.9.2 It is clear given the scale and importance of the proposals, and the diversity of ownerships and occupations, that the CPO Scheme can only be delivered in a timely way through the use of compulsory purchase powers. There is also a need to act quickly and decisively to secure the land and property under the Council’s control so that the CPO Scheme can be implemented comprehensively and expeditiously. The Secretary of State is therefore asked to confirm the Order without modification.

Proof of Evidence of Allen Creedy: The Council of the City of Coventry (Coventry Station Warwick Road Car Park and Adjacent Land City Centre) Compulsory Purchase Order 2019

11.0 Declaration

11.1 The evidence which I have prepared and provide for this inquiry in this proof of evidence is true and has been prepared and is given in accordance with the guidance of my professional institution and I confirm that the opinions expressed are my true and professional opinions.