Object

Representation ID: 66721

Received: 26/06/2014

Respondent: Baginton Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

A. Insufficient consideration of alternatives and no consultation of latest proposals.
Policies DS 8 Employment land & DS16 Sub-Regional Employment Site are unsound as there has been insufficient sub regional consultation. There is reference within the Local Plan to a Joint Employment Land Review. However, it is understood that this has not been published and that it does not adequately consider alternative proposals.
BPC believes that exceptional reasons do not exist for proposing that the land shown on the policy Map 8 is
removed from the Green Belt.
As such BPC believes that the lack of adequate consideration of the proposals renders the Local Plan
unsound.
Furthermore, the Local Plan is unsound as the Sub-Regional Employment Site is not the most appropriate strategy when considered against reasonable alternatives, which have not been given adequate consideration. Some alternatives have been proposed in previous BPC correspondence opposing the
Gateway.
Furthermore BPC and others have no visibility of the review and have not been consulted on its proposals. BPC believes this lack of transparency, consultation and lack of alternatives renders the Local Plan unsound.
B. No account of desires of local communities.
In previous draft report section 5.5.5 it states:-
"In the 2012 Preferred Options the Council committed to exploring the case for land at the Coventry and Warwickshire Gateway to be identified to provide a major employment site that could meet these needs.
Since then, a planning application has been submitted. Although this application has yet to be formally
determined by the Council, the evidence would support the identification of land in this area for a major
employment use of sub-regional significance."
You have our letter L090 response to that consultation dated 18.7.12. Many of the points made in that letter
remain applicable.
Your policy DS16 Sub Regional Employment Site ignores our previous requests therefore is unsound.
C. No consultation with local communities on removal of Green Belt.
The previous Revised Development Strategy specifically maintained the Gateway development area in the
Green Belt. BPC have received previous assurance that this remained the intention of WDC. However,there has been a volte-face with the Local Plan as now presented, with the area suddenly removed from the Green Belt. Post public consultation. Yet there has been no consultation with our and other Parish Councils, our and other local communities and other stakeholders concerning the removal of this land from Green Belt.
We believe that it is unsound, unreasonable and possibly illegal for WDC to change their mind on such a fundamental issue without adequately consulting the local community. The Local Plan policies DS8, DS16 and DS19 are therefore unsound.
D. Contrary to the NPPF.
BPC remain wholly opposed to the Sub-Regional Employment Site (Gateway Development) for all the legitimate planning reasons given in our extensive correspondence objecting to the development and lodged on the WDC website along with over 800 other objectors against planning application W12/1143.
In summary, the Sub-Regional Employment Site Gateway is unsustainable and inappropriate development of the Green Belt with no very special circumstances and is ruinous to the openness and rural character of our Parish. The open fields also act as a vital barrier against urban sprawl. The proposal will not support regeneration within the Coventry & Nuneaton Regeneration Zone, as it would directly compete with established underutilized sites with extant planning permission such as that at Ansty. There are many
suitable alternative sites outside the Green Belt and no preferential sites within the Green Belt. Development
can and should be carried out on existing sites with hundreds of acres of already available land.
The Gateway application has been subject to a Public Inquiry, which has just closed. The PI has written to
us advising that the SoS is due to make a decision on or before 5th December 2014.
BPC and Parishioners continue to vociferously object to any mention of the Sub-Regional Employment Site Gateway in the Local Plan. BPC requests that the Local Plan be withdrawn and amended to remove all references to the Gateway, with all its projections amended accordingly.
BPC is of the view that policy DS16 is fundamentally flawed as it is contrary to the NPPF for all the reasons
given in previous representations; hence the Local Plan is unsound.
Furthermore the Local Plan must not be concluded until the SoS has completed his deliberations following the recently completed Public Inquiry. As such the Local Plan as written can be seen to be prejudging the outcome of this inquiry and is unsound.
E. Based on out of date excessive growth projections.
As such we believe that the Local Plan is fundamentally flawed as it is based on out of date information. Had
it been based on the latest predictions there would be further demonstration that there is no need for the
Gateway (or for the proposed level of increase in housing across the District). As the Local Plan is based on
very significantly higher population growth this is unsound.
On 29.5.2014 the ONS published the mid-2012 based population projections for all local authorities in
England & Wales. This shows that in Warwick District, the population growth by 2029 will be about 29% less
than anticipated by the Joint SHMA which was predicated on the mid-2011 ONS projections.
At the Council meeting on the 23rd April, when it was decided that the publication draft should proceed to a
public consultation on its soundness, the Chief Executive, in answering a question from a Councillor said,
that if these anticipated projections demonstrated a significant change to the provision in that plan, then the
situation would need to be reviewed.