Warwick District Council Local Plan Consultation:
Response from Coventry and Warwickshire Local Enterprise Partnership

Thank you for inviting the CWLEP to comment on your Local Plan consultation.

The CWLEP notes that the Local Plan submission draft has been positively prepared and supports the growth ambitions of the C&W SEP for growth and investment. However more reference should be made to the overarching framework for growth and positive statements toward achieving inward investment and economic growth in line with the NPPF.

The CWLEP recognises that the pre submission Local Plan makes strong connection between the need for employment growth and housing growth. However, the CWLEP questions whether the plan makes adequate provision for new employment land, in terms of quantum, location and choice. Policy DS8 states the Council will provide for a minimum of 66 hectares and paragraph 2.29 says there is a need to allocate 19 to 29 hectares of new employment land. However Policy DS9 only allocates 19.7 hectares (plus an allowance for local needs at the sub-regional site). Furthermore both Policy DS8 and DS9 are framed to meet 'local needs' whereas an objective of the SEP is to also encourage and support inward investment. The policies need to be flexible and to enable the decision-taker to be responsive to meeting business needs. The CWLEP would advise that strong consideration should be given to the employment land study (the Atkins study).

The allocation of land in the vicinity of Coventry Airport as a sub-regional employment site (Policy DS9) supports the SEP. However Policy MS2: Major Sites in the Green Belt does not support the SEP. The local plan should take a more positive stance to the sites identified, which includes Honiley Airfield at Fen End, rather than merely comment that "there may be very special circumstances to justify further development." If this were to be the case there would be no need for the policy at all as further development could be allowed under existing Green Belt policy. The policy should identify the sites for development and set down development management criteria, which should include for flexibility in proposed uses.

Policy EC1 fails to comply with the policies of the NPPF in relation to opportunities for SMEs. The NPPF provides for the conversion of existing buildings (not just as part of a farm diversification scheme) plus the erection of well-designed new buildings within rural areas. The NPPF also provides for the replacement of a building. These forms of development do not appear to be provided for in the plan (except in the Green Belt). There should also be no need in EC1 - In rural areas, criterion e) to limit support to just the growth and expansion of 'existing rural businesses and enterprise'. In line with the SEP and NPPF the policy should allow for new business start-ups and enterprises moving into the area. The provision and effect of the policy is inconsistent with the explanation to it.

The CWLEP considers that there are a number of potential missed opportunities:

* Rail links - Warwick Parkway/Leamington stations should be identified and the implications should be considered. There could be opportunities to encourage sustainable interchange facilities and at Leamington there could be issues associated with the gyratory at Old Warwick Rd/Bath St/Spencer St/Lower Avenue.

* Employment sites - Notwithstanding the Green Belt issues at Fen End, Stoneleigh Park and Thickthorn the document is a bit cautious in tone. In addition, there should be a commitment for the monitoring and alignment of employment with the needs of business and investment, which should be based on evidence of revised economic forecasts.

* Kenilworth Station - a bit cautious in tone

* High Employment/housing ratio - This is potentially quite difficult in that it raises long term development issues that could lead to housing choices needing to be made in the future presenting WDC with some very difficult strategic housing land decisions about the whole balance of the development of Warwick/Leamington. This could eventually lead to a need to consider Green Belt releases to the north.

* Policy EC1 could be more positively worded, for example, it could be amended to read "It is not clear whether Policy EC1 applies equally within and beyond the Green Belt"?

* Monitoring and review - there should be a commitment from each Council and the C&W LEP area on monitoring and alignment employment. This monitoring data would identify the needs of business and investment should be based on evidence on revised economic outlook/forecasts and current market conditions. This data will also help to guide the alignment between housing and employment land provision for the sub-region.



CWLEP Planning Business Group, June 2014.

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Please see the below e-mail sent on behalf of the CWLEP:

Please note that the response submitted on behalf of the CWLEP to the WDC Local Plan contained a minor error - please disregard the suggestion that policy EC1 should be more positively worded.

Kind regards

Lizzie