RDS1: The Council is adopting an Interim Level of Growth of 12,300 homes between 2011 and 2029

Dear Sirs,
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.

Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.

Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".

The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.

The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.

It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.

Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.

The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.

The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs,
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) to be incorrect because of the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.

Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.

Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".

The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.

It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.

Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.

The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.

The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs/Mesdames
I write to express my concern about the rationale of the Revised Development Strategy (RDS).
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.


Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.


Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a
66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".


The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
Part of the Gateway site (6.5ha) around Baginton and Coventry
Airport; [Green Belt]
And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]


The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.


The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.


It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.


Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment.
Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed.
By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.


Instead WDC projections provide space for 10,200 new jobs to be created.
Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.


The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.


The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbersare not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
*    Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
*    Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
*    And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn puts further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030. 48ha of available employment land already exists so there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound. Additionally, there are huge implications for existing infrastruscture as well as schools, access to GPs etc., as well as housing.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply.
All the above points mean that the RDS should be completely revised in order to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require 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". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I am writing to voice my objections to the new local plan proposals.

I am a young resident of Warwick and an asthma sufferer. As such, I am particularly concerned about the significant decrease in air quality that the very large development would bring to this relatively small town. Data on pollution available online up to 2010 show that the AQS objective for nitrogen dioxide, a direct result of traffic pollution, is consistently exceeded in many areas of Warwick, by up to 154% (Progress Report 2011, Warwick District Council, April 2011). The addition of such a large development to the town would increase traffic into the centre and increase the pollution levels. A link between pollution and chronic obstructive pulmonary disorder (COPD) (which I am already at a higher risk of developing as an asthma sufferer) has been firmly established (Yang and Holgate, 2013). Furthermore, a link between pollution and lung cancer and asthma have also been suggested, although there is not yet enough evidence to firmly establish this as fact. The cost of COPD alone to the NHS is £1.3 million per 100,000 people (NICE clinical guideline 101, 2011). Thus, any further increase in pollution would not only be a personal cost to individuals involved, but also a major cost to the local NHS. There is a legal requirement for the air quality in Warwick to be improved and this cannot be achieved when adding to the traffic burden of the town. A health impact assessment for this development is of critical importance, before anything goes any further.

Furthermore, statistics were given at a recent local meeting which firmly stated that the projected housing need of 12,300 new homes by 2029 has been massively inflated. It was suggested that the 5,400 new homes needed over the next 5 years could all be built on brownfield sites. In addition, there are currently 1350 homes in Warwick standing empty (www.emptyhomes.com), which have not been included in these calculations. A local planner with an understanding of the local area would not have suggested such a large development in a greenfield site. While the National Planning Policy Framework requires the approval of 'sustainable development' which meets an established housing need, planning applications already made or imminent for much of the land meet neither of these criteria. A realistic forecast of need would mean that the District already has the required five-year supply of sites, balancing housing with employment growth and matching the housing market.

The land is not greenbelt, but really should be. This rural and agricultural land is important to the county and provides habitats for species of special interest, such as the great crested newt (http://www.ues.org.uk). The area also clearly delineates the boundary between Leamington Spa and Warwick, preventing the urban sprawl that greenbelts were designed to prevent.

Traffic around this area is also particularly problematic. My husband took nearly an hour to travel less than a mile down Myton Road one weekend and queues in this area are the norm. This increased traffic may also damage the local economy as people are prevented from accessing the shops and amenities in town centres. An historic city such as Warwick cannot be allowed to turn into a ghost town. The additional measures needed - traffic lights and signage - would also be an eyesore in this beautiful, old town, particularly around Castle Bridge.

It is my firm belief that the employment opportunities for residences do not exist in the local area. On top of this, Stratford upon Avon District Council also have plans to build a large development of 4600 homes at Lighthorne Heath, some 8 miles from Warwick. This development is better situated, as residents may find employment locally at Jaguar-Landrover. This may reduce the need for housing in Warwick further and should be taken into account when making the projections.

Furthermore, we do not have the infrastructure in terms of water supply, sewage and drainage and the historic town of Warwick cannot be damaged for the sake of this unnecessary development, which in essence is just lining the pockets of the developers and not in Warwick's best interest. A recent development at Warwick Gates did not include the primary school provisions promised, so we are left with little assurance that the school and healthcare facilities can be provided for this new development. Concerns have been raised by people at Myton School and Warwick Hospital as to the sustainability of this development.

I do believe that there are better alternatives to this development, including lowering the housing numbers to meet local needs. Our community is thriving, but there is a need for more affordable homes. However, the town cannot support further in-migration. A better alternative would therefore to be to build small, affordable developments of family homes on brownfield sites. Homes should be situated near to employment, schools, shops and railway stations. Finally, neighbouring local authorities must be consulted and a plan developed that can enhance the local area and not be of great detriment, as, having read this, I am sure that you would agree that this development would be.

I am deeply concerned with the proposed development in Warwick and surrounding areas.

I have lived in Warwick since 1992, firstly in Myton road and for the last 13yrs at the above address, near Myton Hospice. During that time the amount of development has increased significantly e.g. the Moorings, Warwick Gates, Hatton, Chase Meadow and Myton Road (on the Catholic School site) to name but a few.

These developments have brought with them increased traffic, increased pressure on the hospital and schools to the point of bursting.

There are times of the day when I already feel "trapped" in my home and know that to venture out by car/public transport I would have to allow at least an extra 30mins just to get to the other side of Warwick. In view of the proposed plans journeys would become even slower and congestion worse - with pollution a major health concern to local residents.

The plan drafted by the Council would encourage more people to move into the District, destroying the advantages which might attract them: the housing forecast is double what we need and would build far too many houses on greenfield sites.

Warwick, Leamington and Whitnash would become a sprawl of housing estates losing precious agricultural land. The greenfield development would be car-dependant and unsustainable.

New houses are needed, but in the right numbers and places with the infrastructure necessary for sustainable lifestyles, and without awful damage to the life of the town and its existing residents.

I feel very strongly that it is not in the best interests of Warwick and its residents and strongly object to these plans.

I believed that WDC should be acting in the best interest of their residents, who voted for them, and not against their wishes.

Dear District Council
We wish to object to the proposed local plan on the following grounds:
* There is excessive new housing. The housing allocations in the plan should cater for "indigenous" growth, perhaps with a small growth for economic growth purposes. But not this huge amount of new housing.
* The land proposed for employment is also excessive, especially given the amount of vacant employment sites, some of which have been vacant for many years.
* The plan does not take into account the proposed growth outside of the district in the Lighthorne/Gaydon/Kineton area.
* The plan concentrates housing to the south of Warwick and Leamington. No consideration has been given to minor modifications to the green belt to provide a more equitable distribution of growth to the north and south of these two town centres.
* The impact on transport north-south through Warwick and Leamington will be severe, especially given the limited number of river crossings.
* Warwick and Leamington town centres will suffer from congestion and poor quality air. This will make them less attractive to visitors and shoppers.
* The proposed gypsy/traveller sites are,again, concentrated to the south of Warwick and Leamington rather than being distributed more evenly through the district.

I have been instructed by my client The Rosconn Group, to respond to the recent publication of the Core Strategy Consultation and would make the following comments.

We are in general support of the overall approach taken within the plan but would question the total number of dwellings required especially in relation to the creation of 10,200 new jobs. We have read and understand how the figure of 12,300 new homes has been arrived at, however with the ambition to create so many new jobs, coupled with changing demographics and in-migration we believe this number needs to be higher.

We welcome the allowance for development in rural areas both in terms of Primary and Secondary service villages as well as feeder villages and Hamlets. We believe that this will allow for economic and social sustainability within these areas and sustain the wider rural communities.

With regard to the Primary and Secondary Villages we believe it is important to draft the village envelopes as a matter of urgency and that these envelopes need to be genuine village envelopes rather than being drawn with pre conceived ideas of where development will go. The same is true for the feeder villages and Hamlets. Further detail needs to be provided as to how these settlements might be grouped together in hubs or networked clusters. There should be further consultation on these aspects.

Further clarification needs to be given in relation to what 'proportional' means in terms of numbers or scale of development. Will this be a percentage of units in the village; will it be a maximum amount of units etc.? We consider a critical mass of units is required to ensure there is a realistic chance of these villages regenerating and becoming economic and socially sustainable.

It is important to avoid a "free for all" or "a first come, first served" approach to development. Having given the issue much consideration and having looked at examples in other areas we believe that development should meet one of the following four criteria.
* Be on previously developed land
* Be community led
* Be for an identified local need, or
* Should demonstrate a business case that development will help a local service or amenity




















The other aspect, which we have concern about, is the definition of infill or small group of dwellings? Concern is related back to needing a critical mass to ensure that local facilities continue to operate. Three new units built as infill development is unlikely to keep a school open for example. Critical mass will be the key to the survival of some rural areas.

We look forward to receiving acknowledgement of receipt and receiving your feedback and comments in due course.

I just want to register my disapproval to all of the important measures put down in the latest draft local plan. It is an absolute DISGRACE, for instance, that you are considering building all the houses South of Warwick. Why on earth did you not put housing where the new Morrisons is? Apart from which, it is absolute drivel, as the Warwick Society have proved, for you to say there is a need for all this development. I want to see Warwick, Kenilworth and Leamington thrive as someone who depends on footfall, but I certainly do not want my business to prosper at the expense of the complete destruction of the whole nature of these wonderful towns. You should be ashamed that you have not more integrity to build on what is good, and not try to introduce wholesale unnecessary change.

Similarly with these points raised by Sue Butcher...
* Do you realise that they plan to put traffic lights on Castle Hill roundabout, Myton Road roundabout and the foot of Smith Street?
* Do you realise they plan to create a no right turn from Smith Street into St Nicholas Church Street?
There is absolutely no need for these measures whatsoever.

What you should be looking at is the whole question of parking, and treating it as a means of getting people into our towns to shop, instead of treating it as a cash cow. When retail is totally run into the ground in all our towns and High Streets it will be short-sighted Councils like yours that will be to blame, and you should be ashamed of your lack of a decent strategy.

The point is WHY DON'T YOU LISTEN? The Warwick Society and the Chamber of Commerce have both spoken out as representing large considered bodies of opinion and you appear to totally disregard them. Your consultation will no doubt be shown as the usual travesty. Listen before it is too late.

As a local resident, I am absolutely appalled at the proposed housing developments being suggested for the South of Warwick. The impact of this on traffic, schools, medical facilities, pollution, water provision and control, the character of Warwick as a town is all detrimental.

It is the kind of planning that gives planning a bad name. The number of new houses proposed exceeds our needs. The original exhibition at Myton School in March 2013 about the scale and impact of the development.was economical with the truth. As a result I find myself being suspicious of developers and distrustful of planners and their motivations.

Given the current comments by the Council for the Protection of Rural England and others that the precious, inspirational and irreplaceable English countryside is in danger of being eroded by poorly (some might say lazy) planned developments; it seems my views are justified.

I urge you to rethink, to scale down substantially this development, to take more notice of local feeling, to find alternative locations (preferably brown-field sites to infill), to recognize the constraints on development imposed by schools, traffic congestion, etc. That would be what I would call planning.

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see attached

see attached

This is not a plan or a Consultation Document it is a mish-mash of isolated ideas and unconnected thoughts without any joined up thinking. I am repeating what I said at the meeting held at Hill Close Gardens a year ago. Fundamentally my views have not changed.

My major objections are as follows:

1. There cannot be any development in this area without the building of

* A new hospital which is fit for purpose as Warwick Hospital cannot cope with potentially 20,000 - 30,000 new patients
* Two new secondary schools need to be built and I can only see a site for "possible Secondary School". This has other implications on both schools in the area and on traffic flows at peak times.
* Where are these people going to work? Is it Sir Peter Rigby's new Gateway scheme that the WDC planners are so keen on?

2. No traffic assessment can have been done because if that is the case then the overwhelming case cannot be in favour of bringing traffic over a Grade II listed bridge that is already crumbling as the 7.5 tonne weight limit is regularly ignored. You only have to stand at the end of Myton Road between 8.00am and 9.00am or between 5.00pm or 6.00pm and you can see the effect. Warwickshire County Council's record in traffic management schemes is not one to have confidence in considering the mess they made of the recent "improvements" to the High Street and Jury Street. Indeed if these plans come to fruition then many of the streets in Warwick and surrounding environs will be just be arteries and I think here of Smith Street, St Nicholas Church Street, Bridge End, Myton Road, High Street, Jury Street, Castle Hill, Europa Way etc. The list is almost endless.

It has been suggested that the junctions become traffic light signal controlled. If they are anything like the new scheme that has been put in place at Princess Drive and the Recycling Centre then they will be an accident waiting to happen. It also adds nothing to the traffic flow and is far too complicated.

If the Gateway scheme is to be the major employer then again it is naïve on the part of the traffic planners to say there will be little impact on traffic flows. Most people will therefore be making their way to the A46 Trunk Road and either Avon Bridge or Europa Way will become very congested indeed. It is already indicated that traffic at the morning peak will be moving at less than 5mph. This means maximum pollution for very little reward.

3. At a previous meeting at Hill Close it was indicated that traffic issues at peak times would be a real problem issue due, in part, to school starting and finishing times. It was suggested that schools could be spoken to stagger their start and finish times. This I felt was naïve in the extreme as many parents drop their children off on the way to their place of work and this will not change. Thus that will not improve.

4. Developers will only build houses if they can sell them. Do people want to buy them and are they affordable. However once planning permission is in place then it is very difficult to stop it. This will be like having the 'Sword of Damocles' hanging over us.

5. Surely 12,000 houses are excessive. I would have thought a maximum number of half that amount is what is actually required which would have a dramatic effect on the plan. Why is the vast majority of the development on Greenfield sites and not Brownfield ones. I understand that only 9% of Britain is developed but when cuts out most of Scotland, Wales some areas of Derbyshire, Yorkshire, Northumberland, Cumberland and others then the picture looks vastly different. We are already overcrowded as an island. Why must the residents of Warwick (mainly) and Leamington be made to suffer?

I am not a 'serial' objector but a very concerned resident of what is a jewel in the crown of Warwickshire that is likely to be desecrated by this plan.

As residents of Bishops Tachbrook, I write with concern over the proposed development plans for the areas around the village.

My husband and I attended the recent consultation meeting in the village. After listening to the Council representative, and villagers views and concerns, we came away with the strong feeling that this is already a 'done deal'. The meeting was for the purpose of letting the villagers and those affected close by, know what was to happen to the land surrounding Bishops Tachbrook and Whitnash. It was a marketing ploy aimed at selling us on the 'proposed' developments.

We came to live in Bishops Tachbrook 10 years ago as we wanted to live in the village, experience life in the village community, a semi rural location. We paid a premium for our property to do this.

Why is there such a need to develop every piece of green field, build housing estates on them and let the local residents views become obstructed with bricks and mortar??? Where is the respect for the local residents?

Our farmland is set to become a mass of building developments, and we object to it!

Why so many houses? With banks and mortgage market being slow to respond to demand for borrowing, and so many young people unable to get onto the mortgage ladder, who will occupy these houses? We understand that there will be social housing, and this in itself, sadly brings concerns with it.

Now, it appears, that in a few short years, this will all change, and for us personally, not for the better. The 'village' will no longer be. With the proposed building of approx 3,500 new homes, what can the residents expect?

Our concerns are that:

1. With the proposal of approx 3,500 new homes comes the prospect of approx. 7,000 more vehicles within this villages boundaries. In today's lifestyle, rarely does each home have less than 2 vehicles. Volume of traffic increases significantly where schools are located.
2. This alone presents a real concern, as increased traffic indicates increased air pollution. People living in this area will rely on transportation.
3. The main road through the village becomes a short cut for an increased number of motorists trying to get to the Banbury Road/M40. This affects those who live in the village that also have a need to access these roads, resulting in further delays in commuting to from/work.
4. Employment Land - the suggestion was made that this would be to the benfit of local people by encouraging companies to locate to the area. In our experience, people commute to/from their workplace even if it relocates
5. Residents of Bishops Tachbrook do commute to areas outside of Leamington Spa/Warwick etc., and always will do. We have to go where the work is and some don't have the luxury of choosing where they work!
6. Travel time to/from our place of work increases with the increase in traffic.
7. The value of our homes will reduce if/when proposing to sell
8. Within the next few years, Bishops Tachbrook will become like Whitnash, now a part/extension of Leamington Spa
9. Proposed Primary & Secondary Schools/Local Centre/Medical Centre and certainly a Park & Ride facility? These do not suggest that Bishops Tachbrook will not be affected greatly by the proposals
10. How does the council propose that Warwick hospital will cope with the extra demands on it's already stretched services?
11. Who pays for the sizeable infrastructure required?
12. How will the residents of Bishops Tachbrook benefit from this?
13. How will this new home 'proposal' be policed?
14. Residents express a concern over personal safety/security. How will this be addressed?
15. How will the 999 services cope with the extra demand when they are under manned and already suffering as a result of governmental/council cutbacks?