This is a further representation on this part of the Local Plan following publication of new information by the District Council.

The consultation process for Warwick District Council's Publication Draft Local Plan is seriously flawed. As we highlighted in our response to the previous consultation, policies that depend on the Strategic Economic Plan ('SEP') are not justified because key evidence was missing. The current 'focused consultation' is far too narrow to make good these fundamental flaws.

For example, the current consultation document makes no mention of the Strategic Housing Market Assessment ('SHMA') Addendum dated September 2014. This is a critical document that should inform the local plan and its omission renders the current consultation unsound. It appears that WDC is misleading potential consultees, resulting in an unsound local plan - it is not justified.

This consultation response outlines objections to new material and its relationship to earlier material:
1. Summary of issues with the Strategic Employment Land Study ('SELS');
2. Issues with the SHMA Addendum;
3. Issues with the Sustainability Appraisal ('SA'), including the recent SA addenda.

This focused consultation response adds more weight to our previous submissions that the proposed local plan is unsound and it policies are not justified.
Summary of Issues with the Strategic Employment Land Study
The SELS claims that it provides a robust evidence base for the Strategic Economic Plan ('SEP') produced by the Coventry and Warwickshire Local Enterprise Partnership ('CWLEP'). However, the SELS's recommended scenario is based on the CWLEP's own prediction of new jobs. The SELS is neither independent nor robust evidence - it depends on circular arguments. Its call for two or three new sub-regional sites is based on impressions of the chosen consultees rather than substantiated evidence.

The SELS's forecasts of demand for employment land yield vastly differing results with the highest figure being nearly 6 times the magnitude of the lowest. There is no satisfactory explanation for either this very wide disparity or for other conflicting trends across forecasts. The chosen forecast is likely to prove wildly inaccurate.

The SELS forecast based on Cambridge Econometrics' Baseline requires 201 hectares and is stated to be the minimum amount of employment land to meet the CWLEP's plans. The SELS ignores the fact that this forecast is significantly higher than the alternative forecast (Experian's) used in the SHMA Addendum.

In contrast, the SEP claims that the Employment Land Review recommends 250ha. Yet the SELS now recommends that its 'growth figure' of 326ha should be used as a minimum estimate of need. The SELS 'growth figure' is predicated purely on the CWLEP's unsupported prediction that its City Deal would create 8,800 new jobs in advanced manufacturing and engineering by 2025. The SELS takes this figure at face value, without subjecting it to any form of independent verification, and compounds it with unvalidated assumptions. The SELS thus alights on the resulting number as its recommended demand figure, apparently for no better reason than it is what the CWLEP would like to see in order to promote its interests. No justification is given for compounding high growth on a highly optimistic/risky forecast of demand.

On the supply side, SELS starts with a figure of 353ha of available employment land and applies invalid discounts and unjustified reductions until this figure is reduced below the now grossly inflated demand figure. This artificially shrunken supply figure still fails to take proper account of the planned new 100ha employment site at Gaydon. Despite all of these highly dubious exclusions, the SELS still acknowledges that 197ha of employment land is available.

When evaluating strategic employment sites in the LEP area, the SELS acknowledges that planning policy such as Green Belt is relevant but then the skewed selection criteria chosen by SELS omit this key consideration. For example, the SELS does not even mention that Green Belt is precluded from a presumption in favour of sustainable development. Also omitted is another key criterion for large strategic employment sites, particularly logistics sites: namely, direct rail connection. The SELS grossly undervalues rail-connected sites such as DIRFT3, Birch Coppice and Daw Mill.

Despite recognising that the greatest socio-economic need is in the north of the CWLEP area, the SELS uses a Site Appraisal Assessment Methodology that depends on very selective and short-sighted measures. This highly questionable methodology results in good assessments for sites in the south of the area regardless of how ill-served they are by public transport from the area of greatest socio-economic need in the north.

Based on its methodology, the SELS claims that "Coventry and Warwickshire Gateway (Zones A and B) in particular satisfies all the strategic sites criteria." This amazing claim is despite the fact that:
* It is in the Green Belt;
* Access requires extensive off-site highway improvements;
* There is no direct rail link;
* There is serious contamination;
* There is currently poor provision of facilities and amenities;
* There is currently poor public transport accessibility to the site;
* At best, there would be only moderate access to A roads (from Zone A in particular);
* Emergency access (to Zone A) is very restricted in a cul-de-sac passing directly adjacent to Coventry Airport's runway end;
* It is not in the north of the CWLEP area where socio-economic need is greatest;
* It has negative environmental impact.
Additionally, twelve of the SELS's Potential Strategic Employment Sites are identified as being a good match to the CWLEP's strategy, all offering good alternatives to the Gateway. However, even this list of 12 alternatives is an under-estimate because others sites are unjustifiably criticised. Additionally, key strategic sites on the periphery of the CWLEP area, such as DIRFT, the MIRA Enterprise Zone and Blythe Valley Business Park, are omitted without justification. Put simply, there is no shortage of alternative sites.

The recently published version of the SELS has clearly been written with a view to providing, for the already 7-month-old SEP, post-hoc justification for a stream of questionable assertions and heroic assumptions in the SEP, which reflects long-held aspirations. The SELS is nowhere near good enough or cohesive enough to meet even that very limited objective. Its many technical weaknesses and its inherent bias mean that it cannot be taken seriously as an independent assessment of the need for, and supply of, employment land in the CWLEP area. It does not provide a valid justification for development of the Gateway site.

The new evidence does not provide a robust evidence base for the proposed policies in the emerging WDC Local Plan. Multiple forecasts are provided in the various new reports and these forecasts diverge greatly. The SHMA Addendum has one forecast - by Cambridge Econometrics - that is 45% higher than the other (Experian's). The SELS is based on the higher of these forecasts but then it chooses an even higher forecast - its higher growth forecast that is 62% higher again - as the basis of its recommendations. None of these choices of forecast is justified adequately.

The recommendations in the SELS are based on the LEP's prediction of jobs growth; the SELS is neither independent nor robust evidence. The LEP's SEP claims to be supported by the SELS even though the SEP pre-dates the final version of the SELS by 7 months. Such circular arguments are fatally flawed.

The SA makes it clear that the policy to create a new Sub-Regional Employment Site is dependent on the claimed economic benefits. Such claimed benefits are highly speculative. Site selection ignores key constraints such as Green Belt. The SA is unsound and proposed policies are not justified.

The further information we have provided in this focused consultation response adds weight to our previous submissions that the proposed local plan is unsound and it policies are not justified. In particular, it adds to our previous submissions that proposed policies DS16, DS8, DS9, DS19, EC1 and EC3 are unsound and unjustified; the remedies remain as we have previously submitted.