BASE HEADER
DS16 Sub-Regional Employment Site
Gwrthwynebu
Publication Draft
ID sylw: 64487
Derbyniwyd: 21/05/2014
Ymatebydd: Don Thomas
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Ydi
Dyletswydd i gydweithredu? Ydi
The Gateway site provides for 236 hectares of employment land.Please explain why this is needed when the required employment land for 2011-30 in Warwickshire is 66 hectares, which in itself is probably overstated.
Gwrthwynebu
Publication Draft
ID sylw: 65075
Derbyniwyd: 26/06/2014
Ymatebydd: The Community Group
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Policy DS16 Sub-Regional Employment Site is unsound, it contravenes the NPPF (National Planning Policy Framework); there has been no consultation with the local community and other stakeholders concerning the removal of this land from Green Belt; the Sub-Regional Employment Site is NOT the most appropriate strategy when considered against reasonable alternatives.
There is neither objectively assessed need for the policy nor any consideration against reasonable alternatives subject to sustainability appraisals. The policy should be based upon evidence including the production of a sub-regional strategy. The evidence should not be prepared retrospectively in an attempt to justify the 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
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.
Gwrthwynebu
Publication Draft
ID sylw: 65129
Derbyniwyd: 23/06/2014
Ymatebydd: Mr Tony Robinson
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Land used for employement adjacent to Coventry will be ill served by major homes expansion South of Warwick. This fails the sustainability test
Gwrthwynebu
Publication Draft
ID sylw: 65144
Derbyniwyd: 24/06/2014
Ymatebydd: Sport England
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Ydi
Dyletswydd i gydweithredu? Ydi
D2 uses have the potential to create employment and training opportunities and should be viewed along side traditional modes of employment.
Gwrthwynebu
Publication Draft
ID sylw: 65364
Derbyniwyd: 26/06/2014
Ymatebydd: Warwickshire Wildlife Trust
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
The Trust believes that there is insufficient evidence to justify the allocation of the Coventry Gateway scheme in the Local Plan. We are concerned that:
a) There is limited up-to-date ecological information to determine the environmental impacts of the Coventry Gateway scheme and other alternatives within the Local Plan evidence base
b) The provisions of policy DS16 have not been assessed within the 2014 Habitat Regulations Assessment
c) The Sustainability Appraisal omits an assessment of the Coventry Gateway scheme against the District's Sustainability Objectives and fails to conclude why the site is promoted in the plan over other reasonable alternatives
Gwrthwynebu
Publication Draft
ID sylw: 65404
Derbyniwyd: 27/06/2014
Ymatebydd: Stoneleigh & Ashow Parish Council
Asiant : Parklands Consortium Ltd
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
Stoneleigh and Ashow Parish Council considers Policy DS16 is unsound as it contravenes the NPPF: There has been no Public consultation with the local community and other stakeholders concerning the removal of this land from the Green Belt.
There is no policy for a Sub Regional Employment site which is not the most appropriate strategy when considered against reasonable alternatives.
No objectively assessed need for the policy has been established or consideration undertaken for reasonable alternatives subject to sustainability appraisals. This policy should be based upon evidence including the production of a sub-regional strategy, not be justified by retrospective evidence
Gwrthwynebu
Publication Draft
ID sylw: 65728
Derbyniwyd: 27/06/2014
Ymatebydd: Mr David A Ellwood
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Paragraph 2.69 does not mention that the whole of the site is in the Green Belt and the consequent presumption against development and the need to prove exceptional circumstances. The policies map does not make this clear either because it shows the bulk of the site as not being in the green belt. Paragraphs 2.26 and 2.71 refer to a Joint Employment Land Study carried out for the LEP on behalf of its local authorities. References refer to it being published in March 2014 however on enquiry to the Council reveals it has not been published due to it not being completed. two consequences arise from this - that the consultation is defective and the decision to designate the sub regional site relys on the GL Hearn reports prepared in connection to the planning applications for the site. The applications were subject to Secretary of State call in and Public inquiry and were subject to strong opposition by the three Parish Councils most affected , the community group, CPRE and 1000 others. The G L Hearn reports considered alternative sites but only in the context of the application not the area as a whole. Paragraph 2.75 dismisses local concerns. The strong opposition should have informed the LEP and Council that it would be premature and presumptious to designate the site in advance of the SofS decision particularly without the Joint employment land review and statements in other local plan evidence documents. The LEP's approach is contrary to the NPPF which makes it clear that Local authorities and the LEP should work together to prepare and maintain a robust evidence base to understand business needs. The SEP identified the Daw Mill Colliery as a future priority sub regional employment site. Lead in time for the Gateway has been estimated at three years due to the extent and nature of remediation needed. The Highways improvements at Toll Bar are already causing major disruption and the Gateway scheme will need to carry out other significant works. Once built Gateway traffic would inevitably mean the junction would be overrun once more. Flood risk modelling was inaccurate. In contrast no reason that the lead in for Daw Mill Colliery would be anywhere near as long. Local plan states that the Gateway is close to areas of some of the most significant economic deprivation. This is misleading as the greater deprivation is to the north and, particularly, the north east of the city. Nuneaton and Bedworth, to the north west of Coventry, also suffers similarly (the SEPs SWOT confirms this). The Gateway is beyond the southern boundary therefore if it is to play a part a large number of employees will have to travel from the far side of the city or beyond. Concerns over the process of allocating the site.
Gwrthwynebu
Publication Draft
ID sylw: 65981
Derbyniwyd: 25/06/2014
Ymatebydd: Coventry and Warwickshire Development Partnership (Mr David Keir )
Asiant : Oxalis Planning
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
Supports the allocation of a major employment site of sub-regional importance at land in the vicinity of Coventry Airport. Sets out in detail the reasons why the allocation and its removal from the green belt should be supported. Considers however that the wording of DS16 should be modified to allow the incorporation of ancillary facilities such as a hotel and minor retail space
Gwrthwynebu
Publication Draft
ID sylw: 66056
Derbyniwyd: 27/06/2014
Ymatebydd: Lenco Investments
Asiant : RPS Planning & Development
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Ydi
Dyletswydd i gydweithredu? Ydi
RPS has set out objection to the strategy of the plan and the interrelationship between housing and employment, including the Duty to Cooperate, particularly in respect of the sub-regional employment allocation. However, the allocation in DS16 as it stands is soundly based, however, the implications of it and the manner in which it is accommodated in the wider strategy and sub-region is not.
Gwrthwynebu
Publication Draft
ID sylw: 66340
Derbyniwyd: 20/06/2014
Ymatebydd: Cllr Ann Blacklock
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The plan is unsound and fails 3 of the 4 tests of compliance because this element - removing a very large area from Green Belt -
Is not positively prepare in that it is unreasonable to be meeting the unmet employment need of a neighbouring authority when it requires sacrificing Green Belt land and destroying the character of historic villages.
Is not consistent with national policy on Green Belt and the 5 criteria for maintain designated Green Belt areas [ NPPF section 9 para 80] and is not consistent with the principle of sustainable development.
Is not justified in that there are reasonable alternative available in the sub region.
This measure was added to Draft Publication Plan at the 11th hour; there was NO prior consultation: no consultation with neighbouring residents, nor with ward councillors, nor with the Member's Policy Review Group. It therefore fails to meet the requirements of the SCI.
Gwrthwynebu
Publication Draft
ID sylw: 66409
Derbyniwyd: 27/06/2014
Ymatebydd: Hazel and Robin Fryer
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Proposal to remove area from the green belt is based on a claimed sub regional need and in compliance with sub regional strategy. This strategy has not been published and no public consultation has been undertaken for it. Use of unpublished strategies to circumvent scrutiny is undemocratic. Justification claimed is that it complies with the RSS evidence base. This is false as the evidence directed employment to the adjoining MUA and regeneration zone of Nuneaton and North Coventry. City unemployment is 9.5% compared with Warwick District of 3.5%. provision of a major warehouse development is also against the RSS evidence base that required logitics to be served by a rail link. The health of Baginton residents has been ignored in proposing this location. Development of this size in a rural village with less than 2,000 residents does not constitute sustainable development. The failure of the SA to consider this issue is inadequate. The plan does not provide any of the exceptional circumstances to remove this area from the green belt. While this development is supported by the LEP they are an unelected, undemocratic and unaccountable group and many have financial vested interests which act against community values. Warwick District has not embraced principles of localism.
Gwrthwynebu
Publication Draft
ID sylw: 66414
Derbyniwyd: 27/06/2014
Ymatebydd: CPRE WARWICKSHIRE
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
As described in our response to Policy DS16, the addition of an exception for Sub-Regional Employment needs is not justified. The justification is based on the SEP, but both the SEP and the WDC draft plan depend on a "Joint Employment Land Review, March 2014" but this report has not been made available. The evidence base is incomplete and there has been no opportunity for consultation or engagement of interested parties on this evidence.
There is no evidence to establish the justification for a sub-regional employment site being located within Warwick District. There has been no sustainability appraisal of alternative sites showing why the proposed site should be developed instead of existing or potential alternative sites.
Environmental impacts have not been sufficiently taken in to account. This is not consistent with the NPPF.
There is no evidence of exceptional circumstances for green belt release other than that put forward in the Gateway Inquiry. the Plan is unsound because Policy DS16 is not justified and reasonable alternatives to the Gateway have not been considered.
The Policy also conflicts with the rationale for Policy EC1.
Changes to Plan:
Delete the exception relating to sub-regional employment
Gwrthwynebu
Publication Draft
ID sylw: 66476
Derbyniwyd: 27/06/2014
Ymatebydd: Friends of the Earth
Nifer y bobl: 4
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
We do not support the current proposals for the sub-regional employment site at Coventry Airport.
However the results of a planning inquiry are currently awaited. If the development does go ahead, we support the proposal for a masterplan to be prepared. In particular, we support the proposals in paragraph 2.75.
Gwrthwynebu
Publication Draft
ID sylw: 66721
Derbyniwyd: 26/06/2014
Ymatebydd: Baginton Parish Council
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
A. Insufficient consideration of alternatives and no consultation of latest proposals.
Policies DS 8 Employment land & DS16 Sub-Regional Employment Site are unsound as there has been insufficient sub regional consultation. There is reference within the Local Plan to a Joint Employment Land Review. However, it is understood that this has not been published and that it does not adequately consider alternative proposals.
BPC believes that exceptional reasons do not exist for proposing that the land shown on the policy Map 8 is
removed from the Green Belt.
As such BPC believes that the lack of adequate consideration of the proposals renders the Local Plan
unsound.
Furthermore, the Local Plan is unsound as the Sub-Regional Employment Site is not the most appropriate strategy when considered against reasonable alternatives, which have not been given adequate consideration. Some alternatives have been proposed in previous BPC correspondence opposing the
Gateway.
Furthermore BPC and others have no visibility of the review and have not been consulted on its proposals. BPC believes this lack of transparency, consultation and lack of alternatives renders the Local Plan unsound.
B. No account of desires of local communities.
In previous draft report section 5.5.5 it states:-
"In the 2012 Preferred Options the Council committed to exploring the case for land at the Coventry and Warwickshire Gateway to be identified to provide a major employment site that could meet these needs.
Since then, a planning application has been submitted. Although this application has yet to be formally
determined by the Council, the evidence would support the identification of land in this area for a major
employment use of sub-regional significance."
You have our letter L090 response to that consultation dated 18.7.12. Many of the points made in that letter
remain applicable.
Your policy DS16 Sub Regional Employment Site ignores our previous requests therefore is unsound.
C. No consultation with local communities on removal of Green Belt.
The previous Revised Development Strategy specifically maintained the Gateway development area in the
Green Belt. BPC have received previous assurance that this remained the intention of WDC. However,there has been a volte-face with the Local Plan as now presented, with the area suddenly removed from the Green Belt. Post public consultation. Yet there has been no consultation with our and other Parish Councils, our and other local communities and other stakeholders concerning the removal of this land from Green Belt.
We believe that it is unsound, unreasonable and possibly illegal for WDC to change their mind on such a fundamental issue without adequately consulting the local community. The Local Plan policies DS8, DS16 and DS19 are therefore unsound.
D. Contrary to the NPPF.
BPC remain wholly opposed to the Sub-Regional Employment Site (Gateway Development) for all the legitimate planning reasons given in our extensive correspondence objecting to the development and lodged on the WDC website along with over 800 other objectors against planning application W12/1143.
In summary, the Sub-Regional Employment Site Gateway is unsustainable and inappropriate development of the Green Belt with no very special circumstances and is ruinous to the openness and rural character of our Parish. The open fields also act as a vital barrier against urban sprawl. The proposal will not support regeneration within the Coventry & Nuneaton Regeneration Zone, as it would directly compete with established underutilized sites with extant planning permission such as that at Ansty. There are many
suitable alternative sites outside the Green Belt and no preferential sites within the Green Belt. Development
can and should be carried out on existing sites with hundreds of acres of already available land.
The Gateway application has been subject to a Public Inquiry, which has just closed. The PI has written to
us advising that the SoS is due to make a decision on or before 5th December 2014.
BPC and Parishioners continue to vociferously object to any mention of the Sub-Regional Employment Site Gateway in the Local Plan. BPC requests that the Local Plan be withdrawn and amended to remove all references to the Gateway, with all its projections amended accordingly.
BPC is of the view that policy DS16 is fundamentally flawed as it is contrary to the NPPF for all the reasons
given in previous representations; hence the Local Plan is unsound.
Furthermore the Local Plan must not be concluded until the SoS has completed his deliberations following the recently completed Public Inquiry. As such the Local Plan as written can be seen to be prejudging the outcome of this inquiry and is unsound.
E. Based on out of date excessive growth projections.
As such we believe that the Local Plan is fundamentally flawed as it is based on out of date information. Had
it been based on the latest predictions there would be further demonstration that there is no need for the
Gateway (or for the proposed level of increase in housing across the District). As the Local Plan is based on
very significantly higher population growth this is unsound.
On 29.5.2014 the ONS published the mid-2012 based population projections for all local authorities in
England & Wales. This shows that in Warwick District, the population growth by 2029 will be about 29% less
than anticipated by the Joint SHMA which was predicated on the mid-2011 ONS projections.
At the Council meeting on the 23rd April, when it was decided that the publication draft should proceed to a
public consultation on its soundness, the Chief Executive, in answering a question from a Councillor said,
that if these anticipated projections demonstrated a significant change to the provision in that plan, then the
situation would need to be reviewed.
Cefnogi
Publication Draft
ID sylw: 66761
Derbyniwyd: 27/06/2014
Ymatebydd: Coventry City Council
CCC and WDC have undertaken significant levels of joint working alongside the C&W LEP to support and promote the current development proposal referred to as the Coventry and Warwickshire Gateway. As such, CCC supports the allocation of this area as a sub-regional employment site in Policy DS16. The proposed development offers an opportunity for significant economic investment in the sub-region, creating new jobs and generating economic growth.