RDS6: The Council is proposing to make provision for 22.5 hectares of new employment land

4.5.12 Estimates 10,200 new jobs will be created over the Plan period. This equates to approx. 700 new jobs per year. This is based on forecasts that I suggest are out of date as growth is not meeting previous projections made. How many jobs were created in the district over the past 5 years?

This is excessive and is not supported by any sensible facts - employment should be driven by clear demand from industry/commerce not fanciful desk top thinking - the tables show quite clearly that of the 17.5 hectares balance to be allocated, fully 16.5 are there only as "margin to provide flexibility of supply". This is wasteful use of valuable and productive land and must be reduced.

However alternate uses at Common Lane Industrial Estate can only be considered if adequate provision is made for employment land - B1/2/8 uses that currently exist at Common Lane on the Thickthorn site. Financial support may be required to facilitate these existing employers in town to relocate and keep their workforce in the town

Grossly overstated - too much 16.5/17.5ha relate to flexibility not need - better planning could drastically reduce this to the benefit of all.

Current land next to Warwick Gates is presently allocated as employment land and is standing empty. There is no requirement for this.

This expansion and use of land which could otherwise be used for say housing is ridiculous and will only generate a need for more houses and infrastructure. If housing numbers were kept at a realistic level for the district this would not be necessary

I object the amount required is over estimated, there has been industrial land empty for 15 years, and now we are told we need to allocate more ?

Stagecoach Midlands has no comment to make.

The scale of this development is totally inappropriate, not wanted by local residents and must be stopped.

The plan doesn't seem to include any commercial development within any of the villages where residential property is planned - surely trying to include a modest level of development in these location would be beneficial

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.

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

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 Sir,

I wanted to write to you regarding the Revised Development Strategy (RDS). I consider the strategy irrational due to the excessive amount of employment land allocated and the inclusion of the sub-regional employment site.

I am a UK Director of the largest global logistics company, and know that within this geographic area there is an excessive amount of land already available and that within the sector, many of the existing warehouses are far from being fully utilised. Therefore making the employment claims within the various reports especially the GL Hearn report on the 'Sub-Regional Employment Site' spurious at best.

Another objection I have is that this plan is contrary to NPPF policies on Urban Regeneration and the logical focus on making 'brownfield' sites a priority versus designated greenbelt areas, which is not reflected in the 'Sub-Regional Employment Site'. The RDS fails on many counts to follow the principles of the NPPF policies. Therefore I believe that the RDS should be revised to reflect that actual situation that exists within the local area and provide an accurate reflection of future requirements.

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.

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.

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 Cllr Doody
Revised Development Strategy 2013
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.

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.

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.