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Gwrthwynebu

Publication Draft Local Plan: Focused Consultation

ID sylw: 67303

Derbyniwyd: 12/12/2014

Ymatebydd: CPRE WARWICKSHIRE

Cydymffurfio â’r gyfraith? Heb nodi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Heb nodi

Crynodeb o'r Gynrychiolaeth:

The consultation process is flawed as the policies that are dependent on the SEP are not justified and the focussed change consultation is too narrow in scope to address this (no mention of the SHMA Addendum). This means the proposals are unsound and are not justified.

the recommended scenario of the Employment Land Study is based on CWLEP prediction of jobs. It therefore depends on a circular argument since the SEP was based on the ELR. Different scenarios yield hugely different employment land requirements and this is not adequately explained. The recommnended scenario is significantly higher than Experian's used in the JSHMA addendum.

the proposed approach is predicated on unsubstantiated claims that City Deal will yield 8,800 new jobs. So the employment land requirements are recommended for no better reason than it is what the CWLEP would like to see.

On the supply side, invalid discounts/reductions are applied to employment land and also fails to take account of the 100ha site at Gaydon.

The selection criteria for evaluating strategic employment sites omits green belt - meaning these sites are precluded from the presumption in favour of sustainable development. Direct rail connection is also omitted from the criteria - important for logistic sites. Site Appraisal Assessment Methodology depends on very selective and short-sighted measures. This highly questionable methodology results in good assessments for sites in the south of the area regardless of how ill-served they are by public transport from the area of greatest socio-economic need in the north.

Based on its methodology, the SELS claims that "Coventry and Warwickshire Gateway (Zones A and B) in particular satisfies all the strategic sites criteria." This amazing claim is despite the fact that:
* It is in the Green Belt;
* Access requires extensive off-site highway improvements;
* There is no direct rail link;
* There is serious contamination;
* There is currently poor provision of facilities and amenities;
* There is currently poor public transport accessibility to the site;
* At best, there would be only moderate access to A roads (from Zone A in particular);
* Emergency access (to Zone A) is very restricted in a cul-de-sac passing directly adjacent to Coventry Airport's runway end;
* It is not in the north of the CWLEP area where socio-economic need is greatest;
* It has negative environmental impact.

Twelve of the SELS's Potential Strategic Employment Sites are identified as being a good match to the CWLEP's strategy, all offering good alternatives to the Gateway. Additionally, key strategic sites on the periphery of the CWLEP area, such as DIRFT, the MIRA Enterprise Zone and Blythe Valley Business Park, are omitted without justification. Put simply, there is no shortage of alternative sites.

The recently published version of the SELS has clearly been written with a view to providing, for the already 7-month-old SEP, post-hoc justification for a stream of questionable assertions and heroic assumptions in the SEP, which reflects long-held aspirations. The SELS is nowhere near good enough or cohesive enough to meet even that very limited objective. Its many technical weaknesses and its inherent bias mean that it cannot be taken seriously as an independent assessment of the need for, and supply of, employment land in the CWLEP area. It does not provide a valid justification for development of the Gateway site.

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