Publication Draft Local Plan: Focused Consultation

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Object

Publication Draft Local Plan: Focused Consultation

1 - DS9

Representation ID: 67177

Received: 12/12/2014

Respondent: Wm Davis and Hallam Land Management

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Representations have been made to the proposed deletion of the employment allocation on this site (known as Land North of Gallows Hill) on the basis that it is not justified, in that it is not the most appropriate strategy when considered against the reasonable alternatives and the associated evidence; hence the Plan is not sound. Not only is the site to the north of Gallows Hill eminently suitable site for employment purposes but as such, it should form an intrinsic part of the sustainable urban extension to the south of Warwick.

Full text:

Deletion of E1 : Land North of Gallows Hill, Warwick

The land north of Gallows Hill was allocated for employment purposes in conjunction with, and as part of, the allocation of the Strategic Urban Extension to the south of Warwick and Leamington. (Paragraph 2.39 of the Publication Draft Local Plan refers.) William Davis and Hallam Land Management object to the deletion of this site for employment purposes for the following reasons:

1. The site was assessed as part of the Strategic Employment Land Study (October 2014) and is included as one of the 'Potential Strategic Employment Sites' (Appendix B refers). Of the criteria against which the site's suitability was assessed it had a significant number of high scores, as summarised below:

High: o suitability of site for intended use;
o suitability of site for targeted growth sectors;

Good: o accessibility to strategic transport network;
o links/proximity to areas of high unemployment;

Positive: o neighbouring uses;

Reasonable: o accessibility by public transport;
o relationship to strategic corridor.

1. In conclusion, it was stated the site was "Excellent location for research and development and IT companies but relatively small in size" (although as large or larger than the other two employment allocations). In these circumstances, and in view of the policy imperative to support economic growth by ensuring that sufficient land of the right type is available in the right places and at the right time, it is not considered that such an eminently suitable site for employment should be de-allocated. On this basis, it is considered that the Plan, as proposed to be changed, is not sound because it is not consistent with national policy nor is it justified as it is not the most appropriate strategy when considered against reasonable alternatives.

2. If the justification for the site's re-designation as a residential allocation arises as a result of the Council's recognition of the case made on behalf of William Davis and Hallam Land Management in their representations to the Publication Draft (that additional land needs to be allocated for housing in sustainable locations), there are other more suitable sites available, not least of which is the land south of Gallows Hill. The suitability of this site was recognised in earlier stages of the Local Plan's preparation and has been expanded upon in submitted representations.

3. If the deletion of this allocation proceeds, the strategic urban extension to the south of Warwick will not deliver a sustainable community providing not just the homes, services and facilities which people require but also the jobs which residents should be able to easily access by sustainable modes of transport.

The "justification" for the allocation of the land at Stratford Road for employment purposes is that it is an alternative employment option to the land north of Gallows Hill. It is therefore reasonable to presume that it would have been assessed as such. However, by reference to the Strategic Employment Land Study (October 2014), there is no reference to the site. Without any assessment of the site's potential for employment, it is impossible to compare and contrast its suitability for this purpose. Some information is provided in the Sustainability Appraisal of the site but, in comparison to that contained within the Strategic Employment Land Study, it appears to be based on a subjective premise that it "is not being allocated for housing as it is considered to be more suitable for employment" which cannot be described as a ringing endorsement of the site's suitability for development.

One aspect of the site's assessment which appears to be lacking is that in respect of Heritage. In view of the acknowledged proximity of the site to some Listed Buildings, a Registered Park and Garden, Warwick Conservation Area and a Scheduled Ancient Monument, it is reasonable to expect that this matter would have been given more attention in the supporting evidence even if there are "significant" barriers between the development site and the historic assets, including the river.

For this reason it is not considered that the allocation of the land at Stratford Road for employment purposes is sound as it is not justified as it is not the most appropriate strategy when considered against the reasonable alternatives.




Site H01 : Land West of Europa Way, Warwick

Representations have been made to the proposed deletion of the employment allocation on this site (known as Land North of Gallows Hill) on the basis that it is not justified, in that it is not the most appropriate strategy when considered against the reasonable alternatives and the associated evidence; hence the Plan is not sound. Not only is the site to the north of Gallows Hill eminently suitable site for employment purposes but as such, it should form an intrinsic part of the sustainable urban extension to the south of Warwick.

It therefore follows that objections are raised to the re-designation of the site from employment to housing to form an enlarged allocation for housing to the west of Europa Way.

For the avoidance of doubt, William Davis and Hallam Land Management are of the opinion that the provision of additional housing to the south of Warwick is justified for the reasons given in their representations to the Publication Draft Local Plan.

Object

Publication Draft Local Plan: Focused Consultation

1 - DS9

Representation ID: 67201

Received: 12/12/2014

Respondent: Wm Davis and Hallam Land Management

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The proposed employment site has not been assessed as part of the SELS. It is therefore impossible to contrast and compare its suitability for this purpose. In particular it is considered that the site's proximity to a number of heritage assets necessitates a Heritage Assessment.

it is not considered that the allocation of the land at Stratford Road for employment purposes is sound as it is not justified as it is not the most appropriate strategy when considered against the reasonable alternatives.

Full text:

The "justification" for the allocation of the land at Stratford Road for employment purposes is that it is an alternative employment option to the land north of Gallows Hill. It is therefore reasonable to presume that it would have been assessed as such. However, by reference to the Strategic Employment Land Study (October 2014), there is no reference to the site. Without any assessment of the site's potential for employment, it is impossible to compare and contrast its suitability for this purpose. Some information is provided in the Sustainability Appraisal of the site but, in comparison to that contained within the Strategic Employment Land Study, it appears to be based on a subjective premise that it "is not being allocated for housing as it is considered to be more suitable for employment" which cannot be described as a ringing endorsement of the site's suitability for development.

One aspect of the site's assessment which appears to be lacking is that in respect of Heritage. In view of the acknowledged proximity of the site to some Listed Buildings, a Registered Park and Garden, Warwick Conservation Area and a Scheduled Ancient Monument, it is reasonable to expect that this matter would have been given more attention in the supporting evidence even if there are "significant" barriers between the development site and the historic assets, including the river.

For this reason it is not considered that the allocation of the land at Stratford Road for employment purposes is sound as it is not justified as it is not the most appropriate strategy when considered against the reasonable alternatives.

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