RDS 8: Sub Regional Employment Site

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

I am writing to formally object to the planning proposals set out in the following development proposals for Baginton Village.

I will try to describe within this letter what I believe are compelling reasons not to over develop the area in and around the Village of Baginton, and in particular the following three developments proposed namely:
1. The Gateway Project
2. The proposed 80-90 houses
3. The Gypsy & Traveller site
I believe all three developments are non-beneficial for the village of Baginton, I hereby ask the WDC to reconsider the proposals based on my comments below:


1. The Gateway Project
I am formally against the gateway project.
I am astonished at the way this project proposal has been manipulated and do not feel happy with the process that it has undergone in order to reach a state of "go ahead", however I will again list this time in brief why I feel this project should not go ahead.
I believe that the gateway project is an unsustainable development of precious green belt, the proposal being supported by little or no circumstance \ evidence that make it a more appropriate site than the many others suggested, the sheer scale of the proposed development is both out of character and destructive to the local area,
All Industrial sites will in the future need modernising perhaps even demolishing; when has this ever been the case with green belt and wildlife, the presence of green belt and wildlife is quite literally timeless.


2. The proposed 80-90 houses
I am formally against the proposed development of 80 - 90 houses in Baginton.
I understand that the Paris Councils "Housing Needs Survey" discovered that the residents thought that a maximum of 20 New houses should be the maximum; 80 - 90 houses in Baginton is too much for the village to be expected to accommodate and is a disproportionate growth of the village.
Surely the village has some say in how it is developed; it would appear that WDC are not considering its Baginton Parish Councils needs and ultimately its parishioners; instead I suspect they consider the development of an outlying village is of little or no consequence. I hope this isn't the case and would like to see more care being taken of our precious greenbelt with these proposals being tempered to acceptable levels or rejected outright.
3. The Gypsy & Traveller site
I am formally against the development of the Gypsy & Traveller site.
As I have already stated the development of green belt should be avoided where ever possible, to this end the inclusion of a traveller site cannot be allowed to go ahead within Baginton, the loss of the greenbelt and the associated negative effects listed in the consultation documents must be taken into account and an alternative site chosen.
I understand that several traveller sites already exist in close proximity to the ones proposed at Baginton - Siskin drive, Brandon lane and Oxford road. Surely this does not satisfy the Local Plan Strategy of "distributing development across the district" .
Baginton is a village as such it is not serviced as other larger populations are, the availability of doctors, schools, hospitals and public transport are all just adequate, stretching them further would not help anyone receiving these services.
I believe the two sites proposed to the south of Warwick District are preferable options compared with the two in Baginton, they are away from the greenbelt and have better capacity for the amenities required.
I urge Warwick council to reject the planning proposals mentioned above; Baginton is a beautiful village with buildings listed in the doomsday book, including listed buildings, an ancient monument, the remains of a Roman fort and a defined conservation area. These features must be considered in terms of proximity to the proposed developments. We rely on our council to temper these developments and ensure that they manage with a long term view.

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.

see attached

see attached

I wish to object to the Revised Developement Strategy for the Local Plan, as it is would require a very substantial increase in car journeys, which is clearly neither desireable, nor sustainable.

RDS 1 I object to the assesment that 12300 houses are needed in WDC. I accept the need for more houses in our area, if they are to fulfil locally generated needs, not just to create suburbs that will encourage people to move in from other more established areas. A more realistic figure would be about 6500 homes. Much of them one or two bedroomed dwelling, for which there is the greatest need. There are already some 1150 permissions for housing granted by WDC, and the developers have not built more than about 200 per year at best.
Local Authorities have a duty to co-operate with each other in preparing their local plans, what consultation there has been between Coventry City, and Stratford District Councils(SDC) has not led to any agreement as to developements bordering on the boundaries of WDC.

Para5.5.9 Page 52 asseses that Coventry Gateway will become 'a significant creator' of employment. The transport links, already good, will be enhanced. A substantial number of dwellings should be built close by, both on the Coventry side and the WDC side.

Gaydon No mention is made of the current employment at Gaydon, and the projected growth there. Presumably because it is on the Stratford side of the boundary. SDC are planning to build a substantial number of houses, shops, schools etc , close to the Gaydon source of employment. This is an example of developement that wil be 'Sustainable' in the future, not needing long trips by car for work, shops schools etc. WDC should also site a large development near there, in order to make the 'New Town' more viable, and to help to reduce the considerable car traffic that it already causing severe congestion in the area.

Dear Sir/ Madam

REPRESENTATIONS TO THE WARWICK DISTRICT REVISED DEVELOPMENT STRATEGY - JUNE 2013

CBRE Limited writes on behalf of a third party client who wishes to remain unnamed at this stage. These representations should therefore be registered under CBRE Limited.

Our client is a major land owner and occupier in the City and is also a key service provider falling within Class D1 of the Use Classes Order. Our client is in the early process of giving very serious consideration to relocating an important part of their operations to another site within the city. We are not able, at this stage, to identify that potential relocation site, however, suffice to say that it is a brownfield site and is not a Green Belt location. In summary therefore, our client is a key stakeholder locally, a key service provider and an important local employer. These representations are submitted in that context.

We set out below our comments relative to the corresponding paragraphs in the Revised Consultation Development Strategy document:


Paragraph 3.4

We support the overall aims and objectives of the Revised Strategy as stated. However, we consider that the District Council should clear and specific in relation to the need for more homes (including affordable homes) with a strong and implicate emphasis on the re-use of brownfield urban land in preference to greenfield land.

Paragraph 3.5

We agree with the aims set out in paragraph 3.5 however there is no reference to the need to support (and enhance) existing service provision at the local level in addition to the need to provide new service provision as part of larger new development allocations.





Paragraph 4.3

We note the broad location of proposed housing development set out in RDS3 and whilst it may be clear to Council officers that there will be a focus on the re-use of brownfield sites (including conversion of premises), this objective should be stated clearly as part of the first bullet point.

Paragraph 4.3.2

We note that there has been considerable concern by stakeholders previously at the proposed identification of Metropolitan Green Belt to deliver significant growth of new development. The Council's revised strategy should be strongly focussed on the need to better utilise existing brownfield sites within the urban areas to deliver new jobs, homes, and community services, prior to the release of either Greenfield or Green Belt land.

Paragraph 4.3.9

We note the high level of vacancy attributed to some of the towns existing industrial/commercial estates (for example at Warwick Technology Park). We believe very strongly that the Council should state what action they intend to take to resolve such vacancy. Specifically we would want the Strategy to allow for a flexible policy approach which considered a wider array of uses (and occupier types) in such estates. This could include non traditional B class uses (subject to criteria) including local community services, health care use and education uses to name just a few. The Council needs to ensure that its policy approach is flexible, commercial, and innovative to ensure that employers and businesses can utilise existing premises and land resources. Many non pure B-Class uses generate employment and deliver associated benefits to the local economy and to the area generally. Policies should be sufficiently flexible to allow non office uses to maximise existing commercial premises and land which is (or has remained) vacant or under-used.


Paragraph 4.5.3

We agree that the Government's NPPF provides significant weight to the need to provide for sufficient employment land during a Plan period. However, we are concerned that the Council's Revised Development Strategy appears to focus completely on the need to unlock new land and there is no guidance or view expressed on the need to support and facilitate growth of existing services and facilities (see our comment to paragraph 4.3.9 above). A significant element of economic growth is generated through changes of use and the optimisation of existing land and premises. In this important respect, the Council's strategy is silent. Indeed, the NPPF is clear that LPA's should work to build 'strong competitive local economies' and yet this key consultation document forming part of the Local Plan contains very little substance to explain or justify how the LPA will use its development and planning strategy to help existing businesses, employers and service providers to expand and adapt their offer through the planning system.

Paragraph 5.61 - 5.6.4

We agree with the Council's in-principle statements, however, developer contributions and mitigation needs to be viewed and assessed in the context of financial viability. The Revised Strategy document appears to be silent on the issue of viability and this important factor should be referred to by the Council (in accordance with the advice set out in the Government's NPPF).

Summary and Conclusions

The Revised Consultation Strategy document represents a very positive and useful discussion paper and sets out a range of very laudable aims and objectives as part of the Council's emerging LDF. In particular, we are pleased to read the positive statements regarding the need to promote and support development growth, and the need to support the local economy, create new jobs, and deliver new homes in the district's main settlements. We are also highly encouraged to read positive statements regarding the need to deliver new 'infrastructure' locally.

However, the consultation document appears to miss an opportunity in relation to the need to support, nurture, and enhance existing community services and existing businesses through the planning and development system. In this respect, the consultation document appears to be overly focussed on the delivery of new land rather than existing land and existing uses. The majority of wealth and job creation in Warwick will be generated through 'churn' (the use, re-use, and adaptability of existing premises), not just through the provision of new land.

We also note that the consultation document provides a very narrow view of 'employment' generating uses (B1, B2 and B8). Active thriving economies need support for a wide range of employment types including uses falling outside the traditional B Class uses. For example, service providers in the education and health sectors (Use Class D1) are vital contributors to the local economy and yet there is nothing in the Strategy document to acknowledge this factor and no reference to the need to ensure that existing social infrastructure and services will be supported and encouraged through the planning system.

In this respect, the consultation strategy discusses the need (at some length) for developers to provide new infrastructure as part of larger new development allocations but it is largely silent on the need to improve, enhance, and support existing community infrastructure and service provision at the local level (e.g. existing schools, health facilities, community uses etc). Such uses are important sources of job and wealth creation in their own right. Such uses may need to significantly expand or relocate during the Plan period in order to improve their service provision and/or meet necessary statutory standards. What view does the Council have on this? It is silent on these points.

Whilst we fully acknowledge that new large-scale development should mitigate the impacts of the local community, we note that the consultation document is also largely silent on the critical issue of financial viability and the absolute need to ensure that development is not discouraged with the excessive burdens of financial and other obligations (in line with advice contained in the NPPF).

I trust that these representations will be considered carefully and brought to the attention of Members.
Should you wish to discuss the contents of this letter in more detail please contact me direct.

Dear Sir/ Madam

REPRESENTATIONS TO THE WARWICK DISTRICT REVISED DEVELOPMENT STRATEGY - JUNE 2013

CBRE Limited writes on behalf of a third party client who wishes to remain unnamed at this stage. These representations should therefore be registered under CBRE Limited.

Our client is a major land owner and occupier in the City and is also a key service provider falling within Class D1 of the Use Classes Order. Our client is in the early process of giving very serious consideration to relocating an important part of their operations to another site within the city. We are not able, at this stage, to identify that potential relocation site, however, suffice to say that it is a brownfield site and is not a Green Belt location. In summary therefore, our client is a key stakeholder locally, a key service provider and an important local employer. These representations are submitted in that context.

We set out below our comments relative to the corresponding paragraphs in the Revised Consultation Development Strategy document:


Paragraph 3.4

We support the overall aims and objectives of the Revised Strategy as stated. However, we consider that the District Council should clear and specific in relation to the need for more homes (including affordable homes) with a strong and implicate emphasis on the re-use of brownfield urban land in preference to greenfield land.

Paragraph 3.5

We agree with the aims set out in paragraph 3.5 however there is no reference to the need to support (and enhance) existing service provision at the local level in addition to the need to provide new service provision as part of larger new development allocations.





Paragraph 4.3

We note the broad location of proposed housing development set out in RDS3 and whilst it may be clear to Council officers that there will be a focus on the re-use of brownfield sites (including conversion of premises), this objective should be stated clearly as part of the first bullet point.

Paragraph 4.3.2

We note that there has been considerable concern by stakeholders previously at the proposed identification of Metropolitan Green Belt to deliver significant growth of new development. The Council's revised strategy should be strongly focussed on the need to better utilise existing brownfield sites within the urban areas to deliver new jobs, homes, and community services, prior to the release of either Greenfield or Green Belt land.

Paragraph 4.3.9

We note the high level of vacancy attributed to some of the towns existing industrial/commercial estates (for example at Warwick Technology Park). We believe very strongly that the Council should state what action they intend to take to resolve such vacancy. Specifically we would want the Strategy to allow for a flexible policy approach which considered a wider array of uses (and occupier types) in such estates. This could include non traditional B class uses (subject to criteria) including local community services, health care use and education uses to name just a few. The Council needs to ensure that its policy approach is flexible, commercial, and innovative to ensure that employers and businesses can utilise existing premises and land resources. Many non pure B-Class uses generate employment and deliver associated benefits to the local economy and to the area generally. Policies should be sufficiently flexible to allow non office uses to maximise existing commercial premises and land which is (or has remained) vacant or under-used.


Paragraph 4.5.3

We agree that the Government's NPPF provides significant weight to the need to provide for sufficient employment land during a Plan period. However, we are concerned that the Council's Revised Development Strategy appears to focus completely on the need to unlock new land and there is no guidance or view expressed on the need to support and facilitate growth of existing services and facilities (see our comment to paragraph 4.3.9 above). A significant element of economic growth is generated through changes of use and the optimisation of existing land and premises. In this important respect, the Council's strategy is silent. Indeed, the NPPF is clear that LPA's should work to build 'strong competitive local economies' and yet this key consultation document forming part of the Local Plan contains very little substance to explain or justify how the LPA will use its development and planning strategy to help existing businesses, employers and service providers to expand and adapt their offer through the planning system.

Paragraph 5.61 - 5.6.4

We agree with the Council's in-principle statements, however, developer contributions and mitigation needs to be viewed and assessed in the context of financial viability. The Revised Strategy document appears to be silent on the issue of viability and this important factor should be referred to by the Council (in accordance with the advice set out in the Government's NPPF).

Summary and Conclusions

The Revised Consultation Strategy document represents a very positive and useful discussion paper and sets out a range of very laudable aims and objectives as part of the Council's emerging LDF. In particular, we are pleased to read the positive statements regarding the need to promote and support development growth, and the need to support the local economy, create new jobs, and deliver new homes in the district's main settlements. We are also highly encouraged to read positive statements regarding the need to deliver new 'infrastructure' locally.

However, the consultation document appears to miss an opportunity in relation to the need to support, nurture, and enhance existing community services and existing businesses through the planning and development system. In this respect, the consultation document appears to be overly focussed on the delivery of new land rather than existing land and existing uses. The majority of wealth and job creation in Warwick will be generated through 'churn' (the use, re-use, and adaptability of existing premises), not just through the provision of new land.

We also note that the consultation document provides a very narrow view of 'employment' generating uses (B1, B2 and B8). Active thriving economies need support for a wide range of employment types including uses falling outside the traditional B Class uses. For example, service providers in the education and health sectors (Use Class D1) are vital contributors to the local economy and yet there is nothing in the Strategy document to acknowledge this factor and no reference to the need to ensure that existing social infrastructure and services will be supported and encouraged through the planning system.

In this respect, the consultation strategy discusses the need (at some length) for developers to provide new infrastructure as part of larger new development allocations but it is largely silent on the need to improve, enhance, and support existing community infrastructure and service provision at the local level (e.g. existing schools, health facilities, community uses etc). Such uses are important sources of job and wealth creation in their own right. Such uses may need to significantly expand or relocate during the Plan period in order to improve their service provision and/or meet necessary statutory standards. What view does the Council have on this? It is silent on these points.

Whilst we fully acknowledge that new large-scale development should mitigate the impacts of the local community, we note that the consultation document is also largely silent on the critical issue of financial viability and the absolute need to ensure that development is not discouraged with the excessive burdens of financial and other obligations (in line with advice contained in the NPPF).

I trust that these representations will be considered carefully and brought to the attention of Members.
Should you wish to discuss the contents of this letter in more detail please contact me direct.

see atatched

Please see attached documents and plan.