South Warwickshire Local Plan

Gwrthwynebu

Publication Draft

ID sylw: 65122

Derbyniwyd: 23/06/2014

Ymatebydd: Bubbenhall Parish Council

Cydymffurfio â’r gyfraith? Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Ydi

Crynodeb o'r Gynrychiolaeth:

The employment land required for Warwick District is assessed as 66 hectares (paras 2.26-7) and has been met in the provisions of this draft Local Plan.

The Joint Employment Land Review (JELR para 2.71) is NOT in the public domain. There are therefore no means to enable legitimate assessment of the claims made in 2.71.

There are existing sustainable alternative sites in the area with infrastructure in place, to satisfy existing and future employment land requirements. There are no very special circumstances to justify development on Green Belt land. The proposal is therefore inconsistent with the National Planning Policy Framework.

Testun llawn:

The employment land required for Warwick District has been assessed as 66 hectares (paras 2.26-7) and has been met in the provisions of this draft Local Plan
Warwick District Council officials have confirmed that the Joint Employment Land Review (JELR) referred to in para 2.71 has Not been completed and is NOT in the public domain. The evidence base is therefore incomplete. There are no means to enable legitimate assessment of the claims made for example in 2.71.
There are as yet NO 'objectively assessed development and infrastructure requirements' (para 1.8) for employment land from outside Warwick District. Therefore 'unmet requirements from neighbouring authorities' (para 1.8) CANNOT form the basis for policies in this draft local plan.
The plan is NOT JUSTIFIED. The proposed sub regional employment site is NOT the most appropriate strategy when considered against reasonable alternatives, for the following reasons:
There are existing SUSTAINABLE ALTERNATIVE sites in the area with infrastructure in place, to satisfy existing and future employment land requirements. The Plan fails to meet the requirements specified in the National Planning Policy Guidance that "the sustainability appraisal needs to compare all reasonable alternatives...and assess these against the baseline environmental, economic and social characteristics.
The proposed site is NOT located close to areas of significant economic deprivation in Coventry and Warwickshire (para 2.73) so as to generate employment for the sub-region. Other alternative sites are better located in this regard.

The planning application for the proposed 'Coventry and Warwickshire Gateway' (para 2.75) is currently the subject of an ongoing Public Inquiry. Evidence submitted to the Inquiry challenged comprehensively the deliverability of that project, the size of the claimed jobs and other benefits to the local communities, the damage to landscape and heritage assets and the supposedly positive environmental impact of the development. Hence the claims made in particular in 2.75 remain contentious and contested and subject to a judgment by the Planning Inspector.
The proposed Sub-Regional Employment Site is in Green Belt. Because there are alternative sites available there are NO VERY SPECIAL CIRCUMSTANCES to justify development on this Green Belt land. The proposal is therefore INCONSISTENT with the National Planning Policy Framework.