Testun llawn:
I wish to raise a number of objections to CT7 in the Local Plan.
First I think it is a mistake to link Warwick Castle and Warwick Racecourse into one clause, as they are so different.
Warwick Castle is privately owned and has 800000+ visitors, half from outside the West Midlands and employs more than 250 FT staff, open daily.
Whilst Warwick Racecourse only has a short lease on part of a public asset, will in 2014 only have 16 days of racing, has a max of 30000 visitors according to published data ( in a good year), all from the West Midlands and only employs about 9 FT staff.
There are therefore far more important visitor attractions in WDC area yet they do not warrant a separate clause in the Local Plan?
Perhaps it would be better to have a general clause dealing with publicly owned parks in warwick district and include within it St Mary Lands? Given the planned for rapid population growth, surely the need for free access to recreation spaces such as parkland is essential for public health , well being and recreation. I suggest all identified in the recent topen space audit carried out by WDC are included and listed as areas of planning restraint where development would only be allowed in exceptional circumstances.
In earlier consultations ( town centre plan) the general public was asked if Warwick Racecourse should be treated as a special planning case and this was rejected by an overwhelming majority, so it is bizarre that it has reappeared at a late stage into the local plan?
I note this clause does not seem to have been discussed with either the Town Council or Ward Councillors for Warwick West.
More specific objections to CT7:
St Mary Lands already has a comprehensive management plan from 2005, there is no explanation why a new "master plan" is required, or why it should be part of the Local Plan, or how it will be constructed, or why a single tenant ( whose tenancy runs out before the end of the local plan) is being given a privileged position on input? Or how the obvious conflicts of interest this could create would be mitigated?
In 3.142 should not all users of St Mary Lands be part of the input into a new "master plan" as they were in drafting of the current plan?
Why is "visitor accommodation" mentioned there isn't any presently on St Mary Lands and a proposed hotel was rejected by the planning committee as the site was unsuitable, and the applicant did not use their right of appeal?
This therefore appears to be a form of predetermination and undermines the Council's own planning committee decision from 2012, without out any justification?
There is no shortage of hotels in Warwick District or in Warwick with a recent large hotel opening within 1 mile of this site and planning permission for 120 bedroom one beside Morrison's which has not yet been built. Further budget hotels would in fact damage the visitor economy , and lead to smaller hotels and guest house closing. ( The Jockey Club in objecting to the Premier Inn stated there was no enough demand for more than one large budget hotel in Warwick). Evidence at planning was presented demonstrating that additional hotels were merely likely to be part of an economic substitution effect. Therefore why is the District Council wishing to favour one private potential operator over existing businesses?
If the council is committed to "economic vitality" of the visitor accommodation sector, surely any master plan for St Mary Lands which includes a controversial hotel should seek to examine the likely economic impact on existing businesses. If not why are the needs of the Jockey Club rather than local independent businesses felt to be of more importance to WDC?
Given that many local hotels have closed or might be in economic difficulty, should there not be a clause in the local plan stating that no additional large hotels ( more than 50 bedrooms) would be permitted without an economic impact study?
CT7 mentions economic vitality of the racecourse, yet all the published public evidence in the form of a BHA report on Horse Racing and the Jockey Club accounts demonstrates five years of record profits and turnover. What evidence has been presented of pressing economic need to hand over areas of public park to Jockey Club control - given Jockey Club is already making record profits ( and does not publish the data or accounts for Warwick Racecourse which does not appear to be managed as a separate unit, but is rather a subsidiary of Cheltenham Racecourse)?
There is no mention of the Warwick District Council Act 1984, half of which specifically deals with St Mary Lands, this omission is bizarre. Some of the proposals in CT7 appear to be in conflict with the Act of Parliament - specifically the requirement to keep 25 hectares undeveloped and available for public access and recreation.
I suggest an additional line that no development or masterplan would be allowed which was in conflict with the Warwick District Council Act 1984, might solve the issue?