Testun llawn:
We are writing to make comment and respond regarding the New Local Plan and the related consultation process.
We have attempted to use the on-line response process and registered, but this failed.
Below are comments and input specifically related to sections 8.33 and 8.34 of the draft New Local Plan.
Existing Sections of Draft Local Plan
8.33. Coventry Gateway - The Coventry and Warwickshire LEP is committed to the identification of a site of regional importance for employment to serve the needs of the Coventry and Warwickshire sub region and have indicated that land at Coventry and Warwickshire Gateway (see Map 3) could be a suitable site. It has the potential to provide in the region of 14,000 jobs as well as facilitate major improvements to the transport network. The Council is supportive in principle but considers that further work is needed to justify the identification of this site:
* To demonstrate that there are not any other preferable and suitable sites
within the sub-region,
* To understand the local impacts of a major development at the Gateway
in relation to housing and employment need and the District's transport
infrastructure
* To explore the case for releasing land in the green belt
1) The Coventry and Warwickshire LEP is committed to the identification of a site of regional importance
The key ambitions of the LEP are clearly stated in section 8.18 of the draft local plan. These do not include the identification of 'a site of regional importance'.
The words 'committed to the identification of a site of regional importance' should be removed as this does not align with the key ambitions stated in section 8.18, this is not stated in the vision of the LEP and is not stated in the strategies of the LEP, which were only updated in March 2012. The LEP strategies can be found at http://www.cwlep.com/cwlep-strategy
There is a clear conflict of interest in having this statement within the Local Plan, as a board member of the LEP (Sir Peter Rigby) is also the land owner for land within project and has also formed a joint venture between 'Rigby Family Holdings Ltd' and 'Roxhill Developments', which is the developer behind this proposal. This 50/50 joint venture being Coventry & Warwickshire Development Partnership. There is a material interest referring to the LEP within the Local Plan
This statement should also not rule out or eliminate the use of multiple or existing sites.
2) It has the potential to provide in the region of 14,000 jobs
This is inaccurate and misleading, specifically in relation to planning within Warwick District Council. Part of this proposal and 4,000 of the potential jobs are within the Coventry City Council boundary, it already has planning permission and is already being developed. This is currently named 'Whitley Business Park.
The WDC Local Plan should specially refer to potential jobs related to development within WDC boundary only.
3) facilitate major improvements to the transport network.
This is inaccurate and misleading as the Highways Agency has already identified and scheduled the major road improvements around Tollbar Island (A45/A46) and has committed to proceed in 2013. Commencement of the Highway Agencies improvements is not conditional to the Coventry Gateway proposal.
This proposal will NOT facilitate any major improvements to the road network, but will only add more traffic at these already congested points.
There is no evidence or rational to support this statement, thus it should be removed from paragraph 8.33.
4) The Council is supportive in principle but considers that further work is needed to justify the identification of this site
This sentence should be modified to include 'or use of multiple sites'
Additionally, rather than just supporting in principle, the council should also state its preference which should include the use of existing brownfield sites within the sub-region or other developed land before using green belt land.
This should be modified to state 'The Council is supportive in principle, but its preferred options remain the use of existing brownfield sites and other already approved or developed sites within the sub-region. Further work is required to justify the identification of a suitable sites or use of multiple sites'
5) To demonstrate that there are not any other preferable and suitable sites within the sub-region,
The word 'preferable' should be removed from this bullet and this is subjective, not quantifiable and does not state to whom it must be preferable.
This bullet point should also be extended to
a) Include a review of all existing developed land within the sub-region, with the sub-region noted as Warwickshire County Council & West Midlands
b) Include usage of multiple sites, existing developed land, sites which are already approved for development and land already developed under permitted development rights (i.e. Land within the Coventry Airport boundary itself)
As this proposal is for 3 phases and 1 part of this is already approved and within Coventry City Council's boundary, suitable alternatives within the sub-region should be considered by phase only.
6) To understand the local impacts of a major development at the Gateway in relation to housing and employment need and the District's transport infrastructure
This bullet totally fails to address the impacts to the environment or wildlife.
7) To explore the case for releasing land in the green belt
This should be modified to state 'To explore and justify the case for releasing land within the green belt when existing brownfield and approved sites for development within the sub-region remain under-utilized and unoccupied'.
8) Additional bullets that should be added are:
* To justify the potential job opportunities, how many will be transferred from existing employment areas and assess the impact on the area's/developments from which the jobs will transfer.
* Explore the potential to utilize the land within the existing airport boundary for this development, as this is already developed under permitted development rights and would prevent further encroachment onto green belt land that has not been developed.
8.34. The Council is working with partners on the CWLEP and neighbouring local authorities to undertake this research.
Please clarify which neighbouring local authorities are involved in undertaking this research?
Rugby Borough Council should be a key partner in this research, as they have 2 sites (Ansty Business Park & the Peugeot Ryton site) already approved as a Technology Park and a Logistics Park (with existing road infrastructure) which would be impacted by this proposal.
Again, there is a conflict of Interest in this statement and the CWLEP cannot be deemed independent in any research or evaluation (see section 1 above).
Any research should be conducted by an independent 3rd party without material interest in the proposal.
Thank you for taking the time to read this letter and the points outlined.
Please return correspondence noting that you have received this letter and will consider for inclusion into the final Local Plan.