BASE HEADER

Gwrthwynebu

ID sylw: 70053

Derbyniwyd: 22/04/2016

Ymatebydd: CPRE WARWICKSHIRE

Cydymffurfio â’r gyfraith? Nac Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Heb nodi

The changes now proposed to the Green Belt represent a very substantial departure from previous plan proposals. This adds greatly to our concerns, as previously submitted, about the impact on the Green Belt. The proposed new and amended housing applications amount to an additional 500 hectares of Green Belt land to be taken in addition to earlier proposed removals such as the proposed removal of 124 hectares of Green Belt for the proposed Sub-Regional Employment Site (Policy DS16). Even more land is proposed for removal through policies DS NEW1, DS NEW2 and DS NEW4. The cumulative impact of this excessive development in the Green Belt would be immense and is not justified.
The evidence from the JGBS 2015 are ignored. The Joint Green Belt Study assessed parcels of land for their performance in terms of the national policy, specifically rating them against the five purposes defined in the NPPF. These parcels were also grouped into broad areas which were assessed for their strategic Green Belt designation. The proposed sub-regional employment site covers parcel C10 and the proposed King's Hill housing site covers parcel C14, all within Broad Area 3. Broad Area 3 is assessed as making a considerable contribution to all the purposes of the Green Belt . C10 and C14 are both rated as important in green belt terms fulfilling several of the purposes. The JGBS notes "there remain some significant areas of previously used land in the urban areas". Development in the Green Belt is excessive and is not justified, particularly when the chosen sites are some of the most sensitive. . There is no evidence that these sites, driven in part by excessive demands arising outside Warwick District, have been selected as the best available after a top-down sustainability assessment for the whole Coventry and Warwickshire Local Enterprise Partnership area and Strategic Housing Market area. Brownfield sites and other sites outside the Green Belt are suitable alternatives.

Public consultation on these proposals has been constrained solely to the issues of soundness. There has been no adequate public consultation on these key proposals at a stage when the Council was open to considering changes to its proposals. The consultation process has not allowed effective engagement of interested parties. This process is seriously flawed and does not comply with the necessary procedures for preparation of a Local Plan. Lack of adequate consultation renders the plan legally non-compliant.