Employment Land Allocation in WDC's Draft Local Plan
RDS6
I suspect that that you will have lost most commentators on this one. Patently, there is already a gross over-supply of employment land available, so how is it that WDC can possibly have come up with any credible logic in an attempt to bolster the unsupportable assertion that there is a lack of employment land available ?
The only reason that there is any question at all regarding the amount of employment land available is brought about solely by WDC's unjustifiable, idiosyncratic, and frankly bizarre, assessment of their Employment Land Requirements. This inflated guesstimate of "requirements" miraculously manages to turn a proven and substantial over-provision of employment land into an unjustified deficit. As a result, your policy RDS6 tries to claim that an additional 22.5 hectares of new employment land needs to be set aside between 2011 and 2029. What is particularly annoying (and under the circumstances, ludicrous), is that most of this "requirement" will of course be provided by our ever-dwindling reserves of green-belt. In the latest Sunday Times, there was a long article about a current government backbench revolt concerning this very matter - of needlessly, thoughtlessly and unjustifiably squandering valuable & irreplaceable green-belt.
Your Table 4, in section 4.5.7, is entitled "Calculating the employment land requirement" and this apparently attempts to justify the fantastical and fatuous deficit claim :-
The Supply Demand Balance Hectares
Demand
A. Net Employment land requirement 2011 - 2030 36
B. Margin to provide flexibility of supply 16.5
C. Potential re-development of existing employment areas 13.5
D. Total gross employment requirement (demand) 66
Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5
H. Balance to be allocated 17.5 (15 - 25)
Subsequently, in section 4.5.8, you take the 17.5ha of the last item H. ("Balance to be allocated") and arbitrarily and randomly inflate it by a completely unjustified 5ha (a 29% increase !) to 22.5ha in order "To allow for flexibility and the assumptions used in modelling and forecasting".
What on earth is the 16.5ha of item B. ("Margin to provide flexibility of supply") designed for IF NOT "To allow for flexibility and the assumptions used in modelling and forecasting" ?
The stated reason for adding in this unjustifiable 5ha has already been taken into account within the definition of item B. It is ridiculous for WDC to double-bubble this figure by re-including the same thing again. Presumably this is a try-on designed to artificially inflate these numbers to suit WDC's aims over those of its ratepayers and parish councils ? The whole rationale behind "a margin of error" is that it is a plus or minus figure - it can go up or down (and should be thus marked) - but in WDC's case, it only ever works in the one direction - and that is always to the detriment of our environment and green-belt.
What is even harder to take is that you then add to this nonsense by attempting to claim that "it is reasonable to provide an additional 22.5 hectares of employment land" ! Certainly, in this particular case, under no circumstances whatsoever is this a "reasonable" or a justifiable thing to do. This claim is an entirely false construct, based on an entirely false premise, and it is entirely and demonstrably unreasonable.
This becomes an even more blatant attempt at distorting the truth when you consider that the 16.5ha of item B. ("Margin to provide flexibility of supply") is already an enormous 46% margin over and above requirements - being the 36ha of item A. ("Net employment land requirement"). Adding in WDC's newly dreamt-up double-accounting 5ha (thus effectively taking item B. up to 21.5ha) instantly inflates this already huge "margin of flexibility" up to 60% ! If WDC cannot operate without allowing margins of this order of magnitude, then something is dreadfully wrong with the forecasting at Riverside House.
We cannot afford for Warwickshire's ever-diminishing green-belt to be squandered in such a wasteful, unaccountable and profligate fashion. Rather than the 16.5ha to 21.5ha that WDC currently propose, a much more reasonable, justifiable and acceptable item B. ("Margin to provide flexibility of supply") would be around 1.8ha to 3.6ha (5% to 10%), but certainly no more,.
There is a further item which is of major concern within the current plan, and that involves taking areas previously identified as "Employment Land" out of that use, and instead allocating them to WDC's vastly excessive and wasteful house building plans. I am aware that this attempt at a gross over-provision of housing within the current plan is being dealt with - as a matter of some urgency - by a large number of local and parish councils, and I would just like to comment that I completely agree with their criticisms and arguments.
This is also a matter which is deeply implicated in the arguments within your Table 4 (above). There, on the "Demand" side of Table 4. we find 13.5ha of land is identified as item C. ("Potential re-development of existing employment areas"). Yet again, this figure has been brought about solely because of WDC's convoluted but erroneous logic. It is only necessary to include it now because of the unjustified and arbitrary "change of use" of existing employment land to housing use. Subsequent sections spell out in detail how WDC are in fact planning to remove a total of 19.5ha of existing employment land, in order to replace it with 13.5ha of new employment land elsewhere.
However in section 4.3.9, and despite the use (twice) of the word "some", and the specific inclusion of "and employment use", nowhere in this section does it mention WDC's actual intention, which is to take all of this land out of employment use. Employment land should be redeveloped as employment land - as was intended and envisaged originally. We are left to conclude that WDC are themselves not convinced that the demand for employment land is there. Certainly your previous attempts at justification for this topic (Gateway) are terminally weak (as we hope a planning inquiry may soon demonstrate).
It is completely unacceptable to take brownfield land out of employment use and then immediately replace it with employment greenfield land, especially when much of this will be green-belt land.
RDS7
It is completely unacceptable to then use this counterfeit deficit (detailed above) in an effort to go on to attempt to justify developments in RDS7 (section 4.6) of 14.5ha of new employment land in the green-belt, being Thickthorn (8ha) and a chunk of "the employment site of sub-regional significance" (6.5ha). The "employment site of sub-regional significance" being part of the "coalescence" that is the Gateway of course (itself being a part of the abolished RSS RIS).
RDS8
The RSS provisions continue to march forward within WDC, much like zombies - despite it being abolished by the government quite some while ago now. The so-called "Sub-Regional Employment Site" in this section is clearly still the RIS of RSS "Coventry & Warwickshire Regeneration Zone" fame, but merely with a change of name. As part of the "smoke and mirrors" that pervades this document, the vague, business-speak appellation of "Sub-Regional" is never actually explained, defined, or proven to be necessary - why not ?
Surely, any valid definition of a "sub-region" would include at least Coventry, Nuneaton and Bedworth, being the area with the worst employment problems, which MIRA is ideally set up to help to solve due to its geographical proximity to the problem.
In contrast, RDS8 appears designed to work counter to any hope of employment expansion since it will take jobs away from these areas of greatest need and increase still further the excess of employment land in WDC's area. Additionally, it will also increase travel by car from towns to the rural area to be blighted by this development, thus scuppering any chance of the urban regeneration which the area is crying out for.
All the previous economic/employment forces in this area have clearly been usurped by the undemocratic CWLEP with its still outstanding and unanswered questions about corporate governance - including the role of the Chairman of the LEP. It was noticeable that at the Scrutiny Committee meeting on 9th July, Cllr. Caborn (apparently acting as the CWLEP's cheer-leader) flatly refused to answer Cllr. Dhillon's perfectly logical questions about this matter. What an affront to democracy WDC and the CWLEP is turning out to be, with what appear to be cosy cabals apparently operating with impunity and able to dodge important issues raised by elected representatives.
It is also notable that within the "Revised Development Strategy", dated May this year, section 3.5 covers WDC's sustainable development principles, which includes "avoiding coalescence". However, the current plan directly contradicts this supposedly "sustainable" aim, as the (abolished) RSS based RIS - the "Sub-Regional Employment Site" (Gateway) - will be directly responsible for the coalescence of Baginton merging into Coventry, and to a degree Bubbenhall as well. Furthermore, the Thickthorn housing development (and its employment allocation) will of course dramatically reduce the already vanishing separation between Kenilworth and Leamington.
By leaving existing identified areas of employment land alone, and employing reasonable and common-sense assessments of the levels of flexibility and error-margins required, there is already more than enough employment land available to WDC, without having to undertake further development in the green-belt.
The NPPF requires planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the green-belts around them". Policy RDS8 fails this test on every level, and it should be removed.
The employment land proposals within the New Local Plan (RDS6, RDS7 & RDS8) are not coherent, necessary, or sustainable. They should all be removed.