Object

Representation ID: 65728

Received: 27/06/2014

Respondent: Mr David A Ellwood

Legally compliant? No

Sound? No

Duty to co-operate? No

Paragraph 2.69 does not mention that the whole of the site is in the Green Belt and the consequent presumption against development and the need to prove exceptional circumstances. The policies map does not make this clear either because it shows the bulk of the site as not being in the green belt. Paragraphs 2.26 and 2.71 refer to a Joint Employment Land Study carried out for the LEP on behalf of its local authorities. References refer to it being published in March 2014 however on enquiry to the Council reveals it has not been published due to it not being completed. two consequences arise from this - that the consultation is defective and the decision to designate the sub regional site relys on the GL Hearn reports prepared in connection to the planning applications for the site. The applications were subject to Secretary of State call in and Public inquiry and were subject to strong opposition by the three Parish Councils most affected , the community group, CPRE and 1000 others. The G L Hearn reports considered alternative sites but only in the context of the application not the area as a whole. Paragraph 2.75 dismisses local concerns. The strong opposition should have informed the LEP and Council that it would be premature and presumptious to designate the site in advance of the SofS decision particularly without the Joint employment land review and statements in other local plan evidence documents. The LEP's approach is contrary to the NPPF which makes it clear that Local authorities and the LEP should work together to prepare and maintain a robust evidence base to understand business needs. The SEP identified the Daw Mill Colliery as a future priority sub regional employment site. Lead in time for the Gateway has been estimated at three years due to the extent and nature of remediation needed. The Highways improvements at Toll Bar are already causing major disruption and the Gateway scheme will need to carry out other significant works. Once built Gateway traffic would inevitably mean the junction would be overrun once more. Flood risk modelling was inaccurate. In contrast no reason that the lead in for Daw Mill Colliery would be anywhere near as long. Local plan states that the Gateway is close to areas of some of the most significant economic deprivation. This is misleading as the greater deprivation is to the north and, particularly, the north east of the city. Nuneaton and Bedworth, to the north west of Coventry, also suffers similarly (the SEPs SWOT confirms this). The Gateway is beyond the southern boundary therefore if it is to play a part a large number of employees will have to travel from the far side of the city or beyond. Concerns over the process of allocating the site.