CBRE Limited writes on behalf of a third party client who wishes to remain unnamed at this stage. These representations should therefore be registered under CBRE Limited.
Our client is a major land owner and occupier in the City and is also a key service provider falling within Class D1 of the Use Classes Order. Our client is in the early process of giving very serious consideration to relocating an important part of their operations to another site within the city. We are not able, at this stage, to identify that potential relocation site, however, suffice to say that it is a brownfield site and is not a Green Belt location. In summary therefore, our client is a key stakeholder locally, a key service provider and an important local employer. These representations are submitted in that context.
We set out below our comments relative to the corresponding paragraphs in the Revised Consultation Development Strategy document:
Paragraph 3.4
We support the overall aims and objectives of the Revised Strategy as stated. However, we consider that the District Council should clear and specific in relation to the need for more homes (including affordable homes) with a strong and implicate emphasis on the re-use of brownfield urban land in preference to greenfield land.
Paragraph 3.5
We agree with the aims set out in paragraph 3.5 however there is no reference to the need to support (and enhance) existing service provision at the local level in addition to the need to provide new service provision as part of larger new development allocations.
Paragraph 4.3
We note the broad location of proposed housing development set out in RDS3 and whilst it may be clear to Council officers that there will be a focus on the re-use of brownfield sites (including conversion of premises), this objective should be stated clearly as part of the first bullet point.
Paragraph 4.3.2
We note that there has been considerable concern by stakeholders previously at the proposed identification of Metropolitan Green Belt to deliver significant growth of new development. The Council's revised strategy should be strongly focussed on the need to better utilise existing brownfield sites within the urban areas to deliver new jobs, homes, and community services, prior to the release of either Greenfield or Green Belt land.
Paragraph 4.3.9
We note the high level of vacancy attributed to some of the towns existing industrial/commercial estates (for example at Warwick Technology Park). We believe very strongly that the Council should state what action they intend to take to resolve such vacancy. Specifically we would want the Strategy to allow for a flexible policy approach which considered a wider array of uses (and occupier types) in such estates. This could include non traditional B class uses (subject to criteria) including local community services, health care use and education uses to name just a few. The Council needs to ensure that its policy approach is flexible, commercial, and innovative to ensure that employers and businesses can utilise existing premises and land resources. Many non pure B-Class uses generate employment and deliver associated benefits to the local economy and to the area generally. Policies should be sufficiently flexible to allow non office uses to maximise existing commercial premises and land which is (or has remained) vacant or under-used.
Paragraph 4.5.3
We agree that the Government's NPPF provides significant weight to the need to provide for sufficient employment land during a Plan period. However, we are concerned that the Council's Revised Development Strategy appears to focus completely on the need to unlock new land and there is no guidance or view expressed on the need to support and facilitate growth of existing services and facilities (see our comment to paragraph 4.3.9 above). A significant element of economic growth is generated through changes of use and the optimisation of existing land and premises. In this important respect, the Council's strategy is silent. Indeed, the NPPF is clear that LPA's should work to build 'strong competitive local economies' and yet this key consultation document forming part of the Local Plan contains very little substance to explain or justify how the LPA will use its development and planning strategy to help existing businesses, employers and service providers to expand and adapt their offer through the planning system.
Paragraph 5.61 - 5.6.4
We agree with the Council's in-principle statements, however, developer contributions and mitigation needs to be viewed and assessed in the context of financial viability. The Revised Strategy document appears to be silent on the issue of viability and this important factor should be referred to by the Council (in accordance with the advice set out in the Government's NPPF).
Summary and Conclusions
The Revised Consultation Strategy document represents a very positive and useful discussion paper and sets out a range of very laudable aims and objectives as part of the Council's emerging LDF. In particular, we are pleased to read the positive statements regarding the need to promote and support development growth, and the need to support the local economy, create new jobs, and deliver new homes in the district's main settlements. We are also highly encouraged to read positive statements regarding the need to deliver new 'infrastructure' locally.
However, the consultation document appears to miss an opportunity in relation to the need to support, nurture, and enhance existing community services and existing businesses through the planning and development system. In this respect, the consultation document appears to be overly focussed on the delivery of new land rather than existing land and existing uses. The majority of wealth and job creation in Warwick will be generated through 'churn' (the use, re-use, and adaptability of existing premises), not just through the provision of new land.
We also note that the consultation document provides a very narrow view of 'employment' generating uses (B1, B2 and B8). Active thriving economies need support for a wide range of employment types including uses falling outside the traditional B Class uses. For example, service providers in the education and health sectors (Use Class D1) are vital contributors to the local economy and yet there is nothing in the Strategy document to acknowledge this factor and no reference to the need to ensure that existing social infrastructure and services will be supported and encouraged through the planning system.
In this respect, the consultation strategy discusses the need (at some length) for developers to provide new infrastructure as part of larger new development allocations but it is largely silent on the need to improve, enhance, and support existing community infrastructure and service provision at the local level (e.g. existing schools, health facilities, community uses etc). Such uses are important sources of job and wealth creation in their own right. Such uses may need to significantly expand or relocate during the Plan period in order to improve their service provision and/or meet necessary statutory standards. What view does the Council have on this? It is silent on these points.
Whilst we fully acknowledge that new large-scale development should mitigate the impacts of the local community, we note that the consultation document is also largely silent on the critical issue of financial viability and the absolute need to ensure that development is not discouraged with the excessive burdens of financial and other obligations (in line with advice contained in the NPPF).
I trust that these representations will be considered carefully and brought to the attention of Members.
Should you wish to discuss the contents of this letter in more detail please contact me direct.

Dear Sir/ Madam

REPRESENTATIONS TO THE WARWICK DISTRICT REVISED DEVELOPMENT STRATEGY - JUNE 2013

CBRE Limited writes on behalf of a third party client who wishes to remain unnamed at this stage. These representations should therefore be registered under CBRE Limited.

Our client is a major land owner and occupier in the City and is also a key service provider falling within Class D1 of the Use Classes Order. Our client is in the early process of giving very serious consideration to relocating an important part of their operations to another site within the city. We are not able, at this stage, to identify that potential relocation site, however, suffice to say that it is a brownfield site and is not a Green Belt location. In summary therefore, our client is a key stakeholder locally, a key service provider and an important local employer. These representations are submitted in that context.

We set out below our comments relative to the corresponding paragraphs in the Revised Consultation Development Strategy document:


Paragraph 3.4

We support the overall aims and objectives of the Revised Strategy as stated. However, we consider that the District Council should clear and specific in relation to the need for more homes (including affordable homes) with a strong and implicate emphasis on the re-use of brownfield urban land in preference to greenfield land.

Paragraph 3.5

We agree with the aims set out in paragraph 3.5 however there is no reference to the need to support (and enhance) existing service provision at the local level in addition to the need to provide new service provision as part of larger new development allocations.





Paragraph 4.3

We note the broad location of proposed housing development set out in RDS3 and whilst it may be clear to Council officers that there will be a focus on the re-use of brownfield sites (including conversion of premises), this objective should be stated clearly as part of the first bullet point.

Paragraph 4.3.2

We note that there has been considerable concern by stakeholders previously at the proposed identification of Metropolitan Green Belt to deliver significant growth of new development. The Council's revised strategy should be strongly focussed on the need to better utilise existing brownfield sites within the urban areas to deliver new jobs, homes, and community services, prior to the release of either Greenfield or Green Belt land.

Paragraph 4.3.9

We note the high level of vacancy attributed to some of the towns existing industrial/commercial estates (for example at Warwick Technology Park). We believe very strongly that the Council should state what action they intend to take to resolve such vacancy. Specifically we would want the Strategy to allow for a flexible policy approach which considered a wider array of uses (and occupier types) in such estates. This could include non traditional B class uses (subject to criteria) including local community services, health care use and education uses to name just a few. The Council needs to ensure that its policy approach is flexible, commercial, and innovative to ensure that employers and businesses can utilise existing premises and land resources. Many non pure B-Class uses generate employment and deliver associated benefits to the local economy and to the area generally. Policies should be sufficiently flexible to allow non office uses to maximise existing commercial premises and land which is (or has remained) vacant or under-used.


Paragraph 4.5.3

We agree that the Government's NPPF provides significant weight to the need to provide for sufficient employment land during a Plan period. However, we are concerned that the Council's Revised Development Strategy appears to focus completely on the need to unlock new land and there is no guidance or view expressed on the need to support and facilitate growth of existing services and facilities (see our comment to paragraph 4.3.9 above). A significant element of economic growth is generated through changes of use and the optimisation of existing land and premises. In this important respect, the Council's strategy is silent. Indeed, the NPPF is clear that LPA's should work to build 'strong competitive local economies' and yet this key consultation document forming part of the Local Plan contains very little substance to explain or justify how the LPA will use its development and planning strategy to help existing businesses, employers and service providers to expand and adapt their offer through the planning system.

Paragraph 5.61 - 5.6.4

We agree with the Council's in-principle statements, however, developer contributions and mitigation needs to be viewed and assessed in the context of financial viability. The Revised Strategy document appears to be silent on the issue of viability and this important factor should be referred to by the Council (in accordance with the advice set out in the Government's NPPF).

Summary and Conclusions

The Revised Consultation Strategy document represents a very positive and useful discussion paper and sets out a range of very laudable aims and objectives as part of the Council's emerging LDF. In particular, we are pleased to read the positive statements regarding the need to promote and support development growth, and the need to support the local economy, create new jobs, and deliver new homes in the district's main settlements. We are also highly encouraged to read positive statements regarding the need to deliver new 'infrastructure' locally.

However, the consultation document appears to miss an opportunity in relation to the need to support, nurture, and enhance existing community services and existing businesses through the planning and development system. In this respect, the consultation document appears to be overly focussed on the delivery of new land rather than existing land and existing uses. The majority of wealth and job creation in Warwick will be generated through 'churn' (the use, re-use, and adaptability of existing premises), not just through the provision of new land.

We also note that the consultation document provides a very narrow view of 'employment' generating uses (B1, B2 and B8). Active thriving economies need support for a wide range of employment types including uses falling outside the traditional B Class uses. For example, service providers in the education and health sectors (Use Class D1) are vital contributors to the local economy and yet there is nothing in the Strategy document to acknowledge this factor and no reference to the need to ensure that existing social infrastructure and services will be supported and encouraged through the planning system.

In this respect, the consultation strategy discusses the need (at some length) for developers to provide new infrastructure as part of larger new development allocations but it is largely silent on the need to improve, enhance, and support existing community infrastructure and service provision at the local level (e.g. existing schools, health facilities, community uses etc). Such uses are important sources of job and wealth creation in their own right. Such uses may need to significantly expand or relocate during the Plan period in order to improve their service provision and/or meet necessary statutory standards. What view does the Council have on this? It is silent on these points.

Whilst we fully acknowledge that new large-scale development should mitigate the impacts of the local community, we note that the consultation document is also largely silent on the critical issue of financial viability and the absolute need to ensure that development is not discouraged with the excessive burdens of financial and other obligations (in line with advice contained in the NPPF).

I trust that these representations will be considered carefully and brought to the attention of Members.
Should you wish to discuss the contents of this letter in more detail please contact me direct.

see attached

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.

Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.

Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.

The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.

It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.

The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.

The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.