Q-E8.1: Do you agree that the existing employment allocations, including the revisions to Atherstone Airfield, should be carried over into the SWLP?
4.21 We are supportive of the principle of the allocations being carried over into the SWLP as this provides an important starting point in meeting the identified needs. However, it is important to note that the site that is the subject of these representations is currently a substantial part (90ha) of the 100ha allocation that is specifically for the use of Jaguar Land Rover under policy GLH in the Core Strategy. 4.22 This allocation, uniquely, is solely for Jaguar Land Rover’s benefit despite them having no commercial control of the majority of the allocation. Furthermore, there are no review mechanisms in-place within the Core Strategy for this to be released to the open-market. The allocation was specifically identified for Jaguar Land Rover as a consequence of representations made to the Core Strategy about the critical importance of the allocation to the operation of JLR, with the interim Inspectors report (para 125) confirming that “JLR told the Hearing that the allocation being sought in the CS is ‘…about keeping JLR in the UK’”. 4.23 Despite these representations, since the examination in 2015 and the adoption of the Core Strategy in 2016 (nearly 7 years ago), no such proposals have been submitted to Stratford-on-Avon District Council by Jaguar Land Rover. 4.24 Therefore, it is considered that the user-specific nature of this allocation needs to be re-considered with the userspecific restriction removed. Without this user-specific reference being re-considered there is a considerable risk that the allocation could actually be harmful to the local economy through stifling the opportunity for furthereconomic growth and inward investment in this sub-regionally significant and accessible location, therefore undermining the spatial and economic strategy of the plan. Furthermore, reviewing the role of allocations is recognised in the NPPF (para 122) where land should be re-allocated to a more deliverable use if it is not going to come forward for its identified use. 4.25 The removal of the user specific policy restriction would not prejudice the ability of Jaguar Land Rover to secure land within the allocation, should land be needed. As noted above, JLR have invested heavily in the creation ofnew warehouse and manufacturing space elsewhere within the region on land not specifically allocated for this purpose. 4.26 As part of this process, the Council’s are urged to consider the potential of the site to provide opportunities for further unrestricted development given the proximity to the Upper Lighthorne New Settlement which these representations have confirmed benefits from strong housing delivery, a range of services and facilities and will have the equivalent of Main Rural Centre status. Aligning jobs and housing growth has the benefit of further enhancing this area as a sustainable location for strategic growth and would take forward the original concept when it was first promoted by CEG as part of the Core Strategy process in 2012/13. This was reflected in the ‘Core Strategy - New Proposals consultation’ (August/September 2013).
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Yes. We consider that it is appropriate for small scale development to come forward outside of the chosen strategy. This allows for unidentified development (windfall) to come forward over the plan period, which has the potential to support the vitality and viability of existing communities. New development in this circumstance should not be determined by a threshold. By setting a threshold, the suggestion would be that any specific settlement has some form of capacity or limit, and therefore any development exceeding the notional threshold would be inconsistent with the plan strategy. That cannot be the case. The ability for a settlement to accommodate new development will change over time (and noting that the plan period for the SWLP is extensive, to 2050), new development has the potential to increase the ability for a settlement to absorb growth (for example bringing with it new facilities, either on site or via the S106 regime). In any event development requirements should be expressed as a minimum with no ceiling or cap.
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Claverdon is content with the current framework.
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Q-E8.3: Only where appropriate
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The framework which is currently applied by SDC is generally satisfactory but also flexible to respond to the local situation. The JPC is satisfied to continue with this approach.
Issue E8: Existing Employment Sites. Q-E8 .1.E-8.2-8.4As noted throughout this representation we fully support the protection of employment land assets of all types and sizes. However, the Chamber is concerned with the proposal to simply “roll forward “ all existing employment allocations without any evidence that these have been reviewed and fully understood. There area number of prominent sites where we see no evidence that the sites are likely to come forward. Therefore retention of such sites as part of the overall employment allocations is, in effect, reducing the quantum of allocated land. We do not wish to go into great detail on each of these sites but sites at Kenilworth, Stratford Road Warwick, and the JLR “reserve “ at Gaydon -all good examples where there is no apparent evidence related to likely timing.In terms of the latter site, as recognized in the text this site /location represents a highly significant potential land resource alongside the M40 motorway. The land offers great potential for a wide range of commercial and employment uses. Continuing to “reserve ‘ the land for one particular user and in which JLR have no legal interest seems wrong. In contrast the proposals set out to review and maintain a modified Atherstone Airfield allocation appear appropriate and are supported (ref Q-E8.1).
(Q-E8.3, 8.4) In terms of testing retention of business premises and land against marketing, viability and alternative tests we support this type of policy. There are examples across much local plan area of these policies and it is apparent that some policies are more effective than others. It is noted have noted above that the adopted Rugby BC local plan contains in Policy ED1 (Protection of Rugby’s Employment Land) a comprehensive “test “ based policy that appears robust and effective in protecting employment land and sites. The Chamber would strongly advocate more research and liaison with local authorities that have operated this type of policy. For example, different degrees of rigor in terms of marketing time periods are evident in the policy examples and it seems essential that marketing evidence is properly documented and carried out of a reasonably long period of time .The Chamber would be happy to discuss this further with local planning authorities.
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The framework which is currently applied by SDC is generally satisfactory but also flexible to respond to the local situation. The JPC is satisfied to continue with this approach.
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Marketing for a minimum of 12 months would seem to be appropriate.
This approach will provide investment certainty and ensure that we can continue to grow the local economy. If existing allocations are not included, we will need to find alternative sites across South Warwickshire to meet our employment needs.
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QE8.3 The Parish Council supports this proposal as essential to protect assets QE.8.4 The framework which is currently applied by SDC is generally satisfactory but also flexible to respond to the local situation.
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Q-E8.3: NWBC Response – Agree, but aware that current NPPF guidance and permitted development right changes may make this approach difficult to achieve/implement.