Revised Development Strategy

Object

Representation ID: 55478

Received: 22/07/2013

Respondent: The Campbell Partnership

Agent: Hancock Town Planning

Object to non-allocation of land adjacent to Tournament Fields (Campbell Land), Warwick on following grounds:

1-Lack of detailed appraisal of previous representations on the Preferred Options:

There is no written record of any considered assessment of our PO submission, or of officer response being reported to the Council's Executive. The Draft Plan cannot therefore be considered to be 'sound' as per the requirements of the NPPF.

2-Potential for noise disturbance:
Previous PO response included a detailed noise assessment which concluded: "On the basis of this assessment, and providing the recommended mitigation measures are implemented, it is considered that noise should not pose a constraint to development. "

Subsequently understand that Council's Environmental Health Officer has advised officers that "would not encourage an application for housing on this site" but there is no formal objection/ response..

With an appropriate approach to design, confident that the Tournament Fields site could meet the relevant guidelines on noise (specific detailed mitigation measures set out)

Requests this issue to be specifically and comprehensively addressed by the Council in any report responding to representations received during public consultation on the RDS.

3-Quality of the land as an employment site:
There is no record of any officer response to the particular characteristics of the site as set out in July 2012 PO representation, in particular its unsuitability for B2 and B8 use.

However, understand that officers have assumed that the generic conclusion of the GL Hearn Employment Land Review (ELR) 2013 applies equally to every parcel of land within the overall development.

This approach is inappropriate and is too 'broad brush'. The outcome of the 'scoring system' which GL Hearn applied the Tournament Fields site would be very different if applied to the site in isolation.

On the basis of recent planning application and appeal decisions (details set out in representation) it is argued that the site has little employment value.

It is also noted that the Council has recently granted planning permission for a continuing care retirement community on allocated employment land at Gallagher Business Park, application reference W13/0464.

The Committee report on this application refers to part of the justification for the development for non-Class B use is that the site adjoins a residential area (as is the case with this site)

Given that the Gallagher site is better located than the land, but has not secured any office development since its allocation, cannot see how it is logical for the Council to insist that the Campbell land should be retained for office use

4-Over-supply of employment land:
Paragraph 6.32 of the ELR notes that the average rate of employment land completions since 2008 is only 0.5 ha per annum. Yet, the draft RDS identifies a total supply of 71 ha (see Table 4 of RDS: 48.5 ha supply + 22.5 ha of new allocations).

Even allowing for the 13.5 ha allowance for the redevelopment of existing employment areas, this is equivalent to over 100 years supply of land at recent average take-up rates.

Moreover, this is before any consideration is given to the Coventry Gateway development.

It also appears that the figure for forecast demand of employment land include two separate 'flexibility allowances'. Table 4 of the RDS identifies a 16.5 ha flexibility margin (equivalent to 46% of the forecast demand), and an additional 5 ha has been added on to the balance to be allocated figure of 17.5 ha to increase the allocations total to 22.5 ha.

Therefore, a total of 21.5 ha has been added on to the forecast employment land demand figure of 36 ha.

The result of the above factors means that the Draft RDS proposes a significant oversupply of employment land.

The effect of this oversupply - which is proposed to include very high quality strategic allocations of land adjacent to Warwick Technology Park - is that the Campbell land is unlikely to be developed for office use over the lifetime of the plan.

A new use therefore needs to be found for the site.

5-Proposed Green Belt release:
It is difficult to argue that Green Belt land which forms a much-valued setting to the Leamington and Kenilworth conurbations should be developed (as proposed in the RDS) when available and very well-located non-Green Belt development land exists within southwest Warwick and which has lain undeveloped for many years.

6-Conclusions:
In accordance with NPPF (Paragraph 22) and given the unsuitability of the Campbell land for B2 I B8 development, and that housing within Chase Meadow is similarly sited within close proximity to the A46, argues that sensitively designed residential development of the land offers an appropriate way of providing modest additional housing on an available site within a sustainable location.

Also suggest that the SHLAA is not the most appropriate forum for deciding on the merits of potential housing use of the site.

A holistic overview is required, taking into account wider planning issues such as the supply of employment land, the quality of the site as employment land and the preference (or otherwise) for Green Belt release.

Therefore, formally request a that detailed written assessment and response to this representation be presented to the Executive and available for public review.