DS8 Employment Land

Support

Representation ID: 65137

Received: 24/06/2014

Respondent: Sport England

In principal Sport England supports this, however any allocation should not result in the loss of any sports facilities/playing fields, unless they are either replaced or shown through the emerging playing pitch strategy and sports strategy that they are surplus to requirements.

Object

Representation ID: 65490

Received: 27/06/2014

Respondent: The Community Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy DS8 is unsound in so far as it does not satisfy the requirement to meet objectively assessed development requirements.

Despite previous objections, the proposed plan persists with the approach on employment land that leads to an excessive allocation of employment land. The figures on employment land make it very clear that the Plan proposes redevelopment of existing employment land and this leads to the excessive amount of new employment land to be allocated. This makes both the proposed Plan and the associated Sustainability Appraisal unsound.

Object

Representation ID: 65657

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concern the council is not meeting the objectively assessed need for employment land through an up to date evidence base.
Employment land calculations include assumptions relating to housing requirements. The Employment Land Review Update (May 2013) evidence base document or employment forecasting have not been updated following the publication of the higher housing figures in the Joint SHMA. The ELR update does not state how the Economic and DEmographic Forecasts study has been used to inform the demographic-based assumptions underlying the employment
forecasting. It is therefore not clear in the ELR Update whether the land being provided for is still appropriate.

Market assessment questions the majority market demand identified by the ELR update for B1a/b on the basis market signals identicate a strong demand for B2/B8 uses and identifies a preference for sites in or on the edge of the town centres. The evidence base informing the Local Plan does not
appear to be responding to the needs of the market, which raises questions over the employment
assumptions being carried forward into the employment figure set out in Local Plan Publication Draft policy
DS8 and explained in supporting paragraphs 2.24-2.29

ELR update makes assumptions about the redevelopment of existing employment areas which WCC considers are ineffective.

Object

Representation ID: 65677

Received: 26/06/2014

Respondent: Baginton Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? No

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

Object

Representation ID: 65860

Received: 27/06/2014

Respondent: Jaguar Land Rover

Agent: Gerald Eve LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

General support is expressed for providing employment land to meet the needs of the district, in accordance with the NPPF. However, given the employment benefits of the Jaguar Land Rover business as one of the largest employers in the region, it is imperative that Jaguar Land Rover's existing operations within Warwick District and the wider region, including neighbouring Stratford on Avon District, are formally recognised. It is key that Jaguar Land Rover's aspirations for further expansion, over the plan period, to facilitate their continued growth in the region are acknowledged.
To safeguard and facilitate continued investment, it is important that Warwick District Council's Local Plan complements the allocation for Jaguar Land Rover's existing Gaydon site and strategic growth and expansion plans at Gaydon.
Support for Jaguar Land Rover and specifically their proposals at Gaydon, and also existing and future locations within Warwick District, would be in accordance with the CWLEP and the SEP. The district-wide support from the CWLEP to Jaguar Land Rover's expansion plans should be mirrored by Warwick District Council in the Local Plan.
Currently the plan is not 'effective' and not 'positively prepared' as it is not based upon effective joint working on cross-boundary strategic priorities.

Object

Representation ID: 66159

Received: 25/06/2014

Respondent: CWLEP Planning Business Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Questions whether the plan makes adequate provision for employment land in terms of quantum, location and choice. DS8 styates there is a need to allocate 19 to 29 hectares of new employment land however policy DS9 only allocates 19.7 hectares plus an allowance of 6.5 hectares for local needs at the sub regional site. Furthermore both Policy DS8 and DS9 are framed to meet 'local needs' whereas an objective of the SEP is to also encourage and support inward investment. The policies need to be flexible to be responsive to meeting business needs. The CWLEP would advise that strong consideration should be given to the joint employment land study.

Support

Representation ID: 66481

Received: 27/06/2014

Respondent: Friends of the Earth

Number of people: 4

Support

Object

Representation ID: 66580

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS8 is unsound - it does not satisfy the requirement to meet objectively assessed development requirements. The plan proposes excessive allocation of employment land. The Plan proposes redevelopment of existing employment land and this is part of the rationale for this. The SA's section on Consultation Responses shows no recognition of CPRE's earlier consultation responses despite claiming positive effects of the ammountof employment land. This makes both the proposed Plan and the associated Sustainability Appraisal unsound.

in summary:
 The margin "to provide flexibility of supply" (16.5ha) is excessive (almost 50% extra on top of the established demand of 36ha) in order to provide 'choice'. In terms of 'additional buffer to ensure choice' for housing, the NPPF proposes a 5% buffer. Even double that buffer (10%) amounts to 3.6ha rather than 16.5ha;
 The addition of a further 13.5ha for "potential replacement for redevelopment of existing employment areas" is also unjustified. This approach conflicts with the 'brownfield first' approach of policies DS4 (Spatial Strategy) and EC3 (Protecting Employment Land). There is no valid justification for releasing existing employment land in urban areas rather than regeneration as employment land, improving effective use of existing urban employment sites.

The established employment land requirement is 39.6ha. The Plan shows that there are 47.55ha of available employment land, confirming that there is an excess supply of employment land.

Object

Representation ID: 66627

Received: 27/06/2014

Respondent: Mr Chris Walkingshaw

Agent: Barton Willmore

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Objects to policy. The Employment Land Review Update (2013) identifies the site as providing 10 hectares of existing employment land but it is not identified as a site available for future employment uses. Also in addition to automotive and motorsport research the extant permission provides for ancillary office and low volume development production. It is considered that there could be greater growth over the plan period and beyond if more of the site was utilised. The site is an important part of the sub-regions plan for economic growth and has a number
of investment initiatives to bring this forward as demonstrated by the inclusion of it in the Economic Plan for Coventry and Warwickshire and City Deal funding secured. The site can contribute significantly to the District employment levels by providing high skilled local jobs

Object

Representation ID: 67224

Received: 27/06/2014

Respondent: Bloor Homes Midlands

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The draft Local Plan has failed to demonstrate:
* it has proactively driven/supported sustainable economic development, and done everything it can to support sustainable economic growth;
* it meets the business needs of the area and delivers homes to support the growth of the local economy;
* it is based on the most up-to-date and robust evidence about the economic prospects and needs of the area; and,
* it integrates the strategic policies for prosperity (Strategic Policies DS1 and DS8) and housing (Strategic Policies DS2 and DS6).
The level of economic growth to be provided for is not defined within the draft Local Plan.
The strategy for prosperity in the draft Local Plan is to provide for the growth of the local and sub-regional economy by ensuring sufficient/appropriate employment land is available to meet the existing/future needs of businesses (Strategic Policy DS1).
Policy DS8 provides for a minimum of 66ha of employment land to meet local need (for the period 2011 to 2030). The strategy for housing is to provide in full the objectively assessed need (Strategic Policy DS2). Policies DS6, DS7 and DS10 provides for 12,860 new homes (for the period 2011 to 2029).
The evidence base fails to support Paragraph 2.7 of the LP that economic growth has been balanced with housing growth, and that meeting the full objectively assessed need for housing will complement and meet the economic and business needs and ambitions of the District.
The evidence can be found within the Economic and Demographic Forecasts Study (EDFS) (December 2012), the Employment Land Review Update (ELR) (May 2013), and its economic ambitions can be found within the Strategic Economic Plan for Coventry & Warwickshire LEP (SEP) (March 2014).
The economic strength of Warwick is undeniable, and is summarised in paragraphs 3.1 to 3.6 of the ELR. Its economy has outperformed the West Midlands and UK in terms of its growth and is forecast to continue that trend (both in terms of GVA and employment) into the plan period. Warwick has an economic structure which is aligned to the future growth sectors, such as professional services, healthcare, and IT.
Warwick also has a particular strength in the automotive/vehicle manufacturing sector, with several major employers including Jaguar Land Rover (JLR) who have facilities located both within and on the edge of the District. Given the significance of JLR to the national economy, it is no surprise that the Vision for Coventry & Warwickshire in 2025 within the SEP is to be recognised as a global hub and a UK Centre of Excellence in the advanced manufacturing and engineering sector. Many of the SEP's priorities and actions are focussed around facilitating the growth of this sector, including investment to deliver new/expanded facilities at several employment sites within and bordering Warwick District. The SEP has estimated its actions alone may generate over 50,000 jobs by 2030 across the sub-region.
It is very clear from the evidence that the Warwick economy is undoubtedly the 'powerhouse' within the sub-region and West Midlands region. Its future economic performance and continued success is therefore critical to the overall performance of the sub-region and regional economy, and the delivery of the ambitions within SEP.
Whilst the availability of suitable employment land is a key factor influencing Warwick's future economic growth and prosperity, it is not the only component that the Local Plan will need to influence.
A key challenges is to ensure that the planned growth of Warwick and the sub-region's economy is not frustrated by lack of access to skilled workforce. To deliver a global hub and national centre of excellence, requires businesses to be able to attract the necessary talent. Providing access to available homes of a high quality is an essential component of the offer. SEP recognises that the shortage of new homes can be a significant barrier to sustainable economic growth.
In this context, it is of concern that the objectively assessed housing need figure chosen by the Council fails to support a growth in labour supply that meets the forecasts for employment growth. The chosen housing figure only supports labour supply growth of 8,996 for the period 2011 to 2031 leaving a shortfall against the forecast of between 1,304 and 1,904 jobs.
This shortfall is likely to be under-estimated as the employment forecasts preceded the publication of the SEP and have not taken account of its potential influence in accelerating the rate of growth of growing sectors within Warwick. Mindful of the growth in housing supply not keeping pace with the economic ambitions for the area, it is noted that the SEP prioritises a review of additional future housing numbers across the sub-region by the end of March 2015 (page 8). The draft Local Plan does state that it has taken account of the SEP, although there is no reference to a review of its housing numbers within the draft Local Plan.
Whilst it is recognised that the shortfall in labour supply growth might be mitigated through people holding down more than one job, or increased in-commuting from outside of the District (as suggested within paragraph 7.28 of the SHMA), it is noted that when recommending the chosen housing figure, the SHMA advised the Council to consider its
alignment with forecast economic growth, and how employment growth will be supported.
It is not clear whether the Council has undertaken this exercise as the draft Local Plan does not explain how the shortfall between growth in labour supply and growth in jobs will be addressed, or what the implications may be. In commuting from outside the District is one possible consequence.
In this context, it is considered that the strategy has not been positively prepared as it has not proactively driven and supported sustainable economic development, or done everything it can to support sustainable economic growth. It does not meet the objectively assessed development requirements as set out in the evidence base, and therefore is not in accordance with the Framework.