DS16 Sub-Regional Employment Site
Object
Publication Draft
Representation ID: 64487
Received: 21/05/2014
Respondent: Don Thomas
Legally compliant? Yes
Sound? Yes
Duty to co-operate? Yes
The Gateway site provides for 236 hectares of employment land.Please explain why this is needed when the required employment land for 2011-30 in Warwickshire is 66 hectares, which in itself is probably overstated.
The Gateway site provides for 236 hectares of employment land.Please explain why this is needed when the required employment land for 2011-30 in Warwickshire is 66 hectares, which in itself is probably overstated.
Object
Publication Draft
Representation ID: 65075
Received: 26/06/2014
Respondent: The Community Group
Legally compliant? No
Sound? No
Duty to co-operate? No
Policy DS16 Sub-Regional Employment Site is unsound, it contravenes the NPPF (National Planning Policy Framework); there has been no consultation with the local community and other stakeholders concerning the removal of this land from Green Belt; the Sub-Regional Employment Site is NOT the most appropriate strategy when considered against reasonable alternatives.
There is neither objectively assessed need for the policy nor any consideration against reasonable alternatives subject to sustainability appraisals. The policy should be based upon evidence including the production of a sub-regional strategy. The evidence should not be prepared retrospectively in an attempt to justify the plan.
Policy DS16 Sub-Regional Employment Site is unsound, it contravenes the NPPF (National Planning Policy Framework); there has been no consultation with the local community and other stakeholders concerning the removal of this land from Green Belt; the Sub-Regional Employment Site is NOT the most appropriate strategy when considered against reasonable alternatives.
There is neither objectively assessed need for the policy nor any consideration against reasonable alternatives subject to sustainability appraisals. The policy should be based upon evidence including the production of a sub-regional strategy. The evidence should not be prepared retrospectively in an attempt to justify the plan.
Object
Publication Draft
Representation ID: 65122
Received: 23/06/2014
Respondent: Bubbenhall Parish Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The employment land required for Warwick District is assessed as 66 hectares (paras 2.26-7) and has been met in the provisions of this draft Local Plan.
The Joint Employment Land Review (JELR para 2.71) is NOT in the public domain. There are therefore no means to enable legitimate assessment of the claims made in 2.71.
There are existing sustainable alternative sites in the area with infrastructure in place, to satisfy existing and future employment land requirements. There are no very special circumstances to justify development on Green Belt land. The proposal is therefore inconsistent with the National Planning Policy Framework.
The employment land required for Warwick District has been assessed as 66 hectares (paras 2.26-7) and has been met in the provisions of this draft Local Plan
Warwick District Council officials have confirmed that the Joint Employment Land Review (JELR) referred to in para 2.71 has Not been completed and is NOT in the public domain. The evidence base is therefore incomplete. There are no means to enable legitimate assessment of the claims made for example in 2.71.
There are as yet NO 'objectively assessed development and infrastructure requirements' (para 1.8) for employment land from outside Warwick District. Therefore 'unmet requirements from neighbouring authorities' (para 1.8) CANNOT form the basis for policies in this draft local plan.
The plan is NOT JUSTIFIED. The proposed sub regional employment site is NOT the most appropriate strategy when considered against reasonable alternatives, for the following reasons:
There are existing SUSTAINABLE ALTERNATIVE sites in the area with infrastructure in place, to satisfy existing and future employment land requirements. The Plan fails to meet the requirements specified in the National Planning Policy Guidance that "the sustainability appraisal needs to compare all reasonable alternatives...and assess these against the baseline environmental, economic and social characteristics.
The proposed site is NOT located close to areas of significant economic deprivation in Coventry and Warwickshire (para 2.73) so as to generate employment for the sub-region. Other alternative sites are better located in this regard.
The planning application for the proposed 'Coventry and Warwickshire Gateway' (para 2.75) is currently the subject of an ongoing Public Inquiry. Evidence submitted to the Inquiry challenged comprehensively the deliverability of that project, the size of the claimed jobs and other benefits to the local communities, the damage to landscape and heritage assets and the supposedly positive environmental impact of the development. Hence the claims made in particular in 2.75 remain contentious and contested and subject to a judgment by the Planning Inspector.
The proposed Sub-Regional Employment Site is in Green Belt. Because there are alternative sites available there are NO VERY SPECIAL CIRCUMSTANCES to justify development on this Green Belt land. The proposal is therefore INCONSISTENT with the National Planning Policy Framework.
Object
Publication Draft
Representation ID: 65129
Received: 23/06/2014
Respondent: Mr Tony Robinson
Legally compliant? Yes
Sound? No
Duty to co-operate? No
Land used for employement adjacent to Coventry will be ill served by major homes expansion South of Warwick. This fails the sustainability test
Land used for employement adjacent to Coventry will be ill served by major homes expansion South of Warwick. This fails the sustainability test
Object
Publication Draft
Representation ID: 65144
Received: 24/06/2014
Respondent: Sport England
Legally compliant? Yes
Sound? Yes
Duty to co-operate? Yes
D2 uses have the potential to create employment and training opportunities and should be viewed along side traditional modes of employment.
I am concerned over the narrow field WDC places on the definition of employment.
Sport's contribution to the English economy reached £20.3 billion in 2010, 1.9% of the England total.
This placed sport up in the top 15 industry sectors in England above motor vehicles, telecoms services, legal services, accounting, publishing, advertising and the utilities.
The economic benefits of sport in the West Midlands is also recognised and a Sport England survey in 2008, showed continued growth from 2002 with over £2.1 billion spent on sport-related goods and services in the region in 2008. In the same year, consumer expenditure on sport accounts for 2.9% of the total expenditure in the region, the highest percentage among the English regions. Compared with 2005, there is a 39% increase in sport-related consumption. During the period 2003-2008, the proportion of total consumer spending on sport has increased from 2.4% to 2.9%.
Sport and associated industries are estimated to employ 54,200 people in the West Midlands. This represents an increase of 23% over the period 2005-2008. During the aforementioned period, the percentage of sport related employment in the region increased from 1.8% to 2.2%. Employment linked to the sport-retailing sector increased very strongly during the 2005-2008 period, reaching 5,400 people employed. The region bucked the recession trend in all sport related indicators. Sport therefore plays a vital role in the economy in the West Midlands and in particular in Warwick DC
Object
Publication Draft
Representation ID: 65364
Received: 26/06/2014
Respondent: Warwickshire Wildlife Trust
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The Trust believes that there is insufficient evidence to justify the allocation of the Coventry Gateway scheme in the Local Plan. We are concerned that:
a) There is limited up-to-date ecological information to determine the environmental impacts of the Coventry Gateway scheme and other alternatives within the Local Plan evidence base
b) The provisions of policy DS16 have not been assessed within the 2014 Habitat Regulations Assessment
c) The Sustainability Appraisal omits an assessment of the Coventry Gateway scheme against the District's Sustainability Objectives and fails to conclude why the site is promoted in the plan over other reasonable alternatives
The Trust believes that there is insufficient evidence to justify the allocation of the sub-regional employment site near Coventry Airport (hereafter referred to as the Coventry Gateway scheme) in the Local Plan. We are concerned that:
a) There is limited up-to-date ecological information to determine the environmental impacts of the Coventry Gateway scheme and other alternatives within the Local Plan evidence base
b) The provisions of policy DS16 have not been assessed within the Habitat Regulations Assessment dated March 2014.
c) The Sustainability Appraisal report 2014 and its associated appendices omit a formal assessment of the Coventry Gateway scheme against the District's Sustainability Objectives and fails to conclude why the site is promoted in the plan over other reasonable alternatives.
1) Evidence Base
In our consultation response to the draft Local Plan 2012, Warwickshire Wildlife Trust recommended that:
'The evidence base for the natural environment will ... have to be reviewed and updated in order to inform the sustainability appraisal for this site and any other reasonable alternatives that come forward as part of [the] review process.'
However, according to the Habitat Biodiversity Audit data (HBA) for Warwickshire, Coventry and Solihull (2012-2013), much of the habitat data for the land allocated for the Coventry Gateway scheme in Warwick District dates from 1997/98, with only a few small areas updated in 2006. The Gateway scheme was not included in the Warwick District Habitat Assessment 2008 and was not updated as part of the Landscape Sensitivity and Ecological & Geological Study - Landscape Assessment Update April 2014.
A planning application for the Coventry Gateway scheme was submitted in 2012. The application was accompanied by a detailed Environmental Statement (ES) which included up-to-date data on habitats, species and statutory and non-statutory wildlife sites within the proposed allocation, with the exception of Rock Farm potential Local Wildlife Site. Whilst this data may go some way to providing a baseline for the Coventry Gateway scheme, it is not included or summarised within the local plan evidence base and has not been referred to when assessing site allocations in the Sustainability Appraisal report 2014.
In paragraph 2.73 of the Local Plan Submission draft, the local authority broadly outlines the reasons for supporting the Coventry Gateway Scheme. The local authority quotes studies that have been undertaken to support the location of the allocation but these studies are not referred to in the local plan and it is not made clear if such studies are included within the local plan evidence base. Nor is it clear that these studies contain any wider sustainability assessment of the proposal and alternatives given the apparent focus on the economic merits of the proposal at the expense of any reference to environmental constraints and opportunities.
The Local Authority has not proposed alternative sub-regional site allocations as part of the local plan process, nor gathered associated environmental evidence to review the wider sustainability merits and constraints of such options.
We accept that it is unreasonable to require Warwick District to identify a range of alternative sub-regional employment sites alone when the review area for these sites will extend beyond the boundary of a single local authority area. We do believe however, that the local authority has a duty, under the Localism Act 2011, to work collaboratively with other local authorities in the Coventry and Warwickshire Local Enterprise Partnership (LEP) area to collate evidence for other sub-regional options in order to ensure that the preferred option is justified in accordance with sustainability principles. As the responsible local authority for allocating the preferred sub-regional site, we believe it is necessary for the results of this cross-boundary assessment to be present in the evidence base of this local plan so that the Gateway allocation, as with all other proposed housing and employment sites in the plan, can be reviewed using the sustainability Appraisal process.
2) Habitat Regulations Assessment
The local authority has updated the Habitat Regulations Assessment of the local plan in accordance with article 6(3) and (4) of the Habitats Directive; the findings of which are presented in the Habitat Regulations Assessment- Screening Report 2014. The report screens the likelihood that policies in the plan could impact on Natura 2000 sites; however the policies reviewed in the report were those detailed within in the 2012 Preferred Option draft and not the current submission draft of the Local Plan.
Paragraph 3.3.1 of the Habitat Regulations Assessment - Screening report 2014 states that:
'As the local plan is in development, this assessment will report the Local Plan Preferred Options as of May 2012. A further addendum may need to be prepared should the local plan policies or site allocations be materially altered'
The Trust believes that since 2012, the provisions of policies surrounding the Gateway Scheme have materially changed from a generic 'exploration of the case for the proposal' in policy PO8 to a specific 'allocation of land' in policy DS16 of the 2014 submission draft. The implications of this change should therefore be subject to further screening and added as an addendum to the 2014 screening report.
3) Sustainability Appraisal
The Sustainability Appraisal Report 2014 does not assess the Coventry Gateway site allocation against Warwick District's Sustainability objectives nor does it provide any assessment of the proposal against reasonable alternatives.
Article 5.2 of the European Directive 2001/42/EC "on the assessment of the effects of certain plans and programmes on the environment" states that:
"The environmental report shall include information that may reasonably be required taking into account current knowledge and methods of assessment, the contents and level of detail in the plan or programme, [and] its stage in the decision-making process"
The Coventry Gateway scheme is a specific site allocation identified within the plan and is promoted by policy DS16. However, unlike all other specific housing and employment allocations, it is not reviewed or assessed within the Sustainability Appraisal report 2014.
The Directive further states that the report should contain information on:
"the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors. These effects should include secondary, cumulative, synergistic, short, medium and long-term, permanent and temporary, positive and negative effects" (Annex I (f) and
footnote)
There appears to be no evidence about such effects within the local plan evidence base and no assessment of these effects against the District's sustainability objectives using the Sustainability Appraisal methodology employed for all other housing and employment allocations.
"an outline of the reasons for selecting the alternatives dealt with" (Annex I (h))
There are no alternatives identified for sub-regional employment sites in the Sustainability Appraisal and subsequently no supporting information for selecting the Gateway scheme in accordance with sustainability criteria.
"the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme" (Annex I (g))
Without an assessment of the Coventry Gateway scheme against the Sustainability objectives there is no option to consider any measures that may be required within the local plan to reduce and offset any adverse effects of the proposal.
In the absence of information for the above, the Trust firmly believes that the Sustainability Appraisal fails to provide the necessary justification for allocating land for the Coventry Gateway proposal within the local plan.
Object
Publication Draft
Representation ID: 65404
Received: 27/06/2014
Respondent: Stoneleigh & Ashow Parish Council
Agent: Parklands Consortium Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Stoneleigh and Ashow Parish Council considers Policy DS16 is unsound as it contravenes the NPPF: There has been no Public consultation with the local community and other stakeholders concerning the removal of this land from the Green Belt.
There is no policy for a Sub Regional Employment site which is not the most appropriate strategy when considered against reasonable alternatives.
No objectively assessed need for the policy has been established or consideration undertaken for reasonable alternatives subject to sustainability appraisals. This policy should be based upon evidence including the production of a sub-regional strategy, not be justified by retrospective evidence
STONELEIGH AND ASHOW PARISH COUNCIL REPRESENTATION: Policy DS16 ; Local Plan
This policy is unsound: it is not justified.
The justification for Policy DS16 relies on the Strategic Economic Plan (SEP) commissioned by CWLEP in March 2014. The SEP supported the Coventry and Warwickshire Gateway application, the subject of a call in inquiry awaiting a decision by the SoS. The SEP and the WDC draft plan depend on a 'Joint Employment Land Review, March 2014, which has not been made available for public consultation or the engagement of interested parties on this evidence. There is no evidence of exceptional circumstances to justify a Sub-Regional Employment site
Object
Publication Draft
Representation ID: 65728
Received: 27/06/2014
Respondent: Mr David A Ellwood
Legally compliant? No
Sound? No
Duty to co-operate? No
Paragraph 2.69 does not mention that the whole of the site is in the Green Belt and the consequent presumption against development and the need to prove exceptional circumstances. The policies map does not make this clear either because it shows the bulk of the site as not being in the green belt. Paragraphs 2.26 and 2.71 refer to a Joint Employment Land Study carried out for the LEP on behalf of its local authorities. References refer to it being published in March 2014 however on enquiry to the Council reveals it has not been published due to it not being completed. two consequences arise from this - that the consultation is defective and the decision to designate the sub regional site relys on the GL Hearn reports prepared in connection to the planning applications for the site. The applications were subject to Secretary of State call in and Public inquiry and were subject to strong opposition by the three Parish Councils most affected , the community group, CPRE and 1000 others. The G L Hearn reports considered alternative sites but only in the context of the application not the area as a whole. Paragraph 2.75 dismisses local concerns. The strong opposition should have informed the LEP and Council that it would be premature and presumptious to designate the site in advance of the SofS decision particularly without the Joint employment land review and statements in other local plan evidence documents. The LEP's approach is contrary to the NPPF which makes it clear that Local authorities and the LEP should work together to prepare and maintain a robust evidence base to understand business needs. The SEP identified the Daw Mill Colliery as a future priority sub regional employment site. Lead in time for the Gateway has been estimated at three years due to the extent and nature of remediation needed. The Highways improvements at Toll Bar are already causing major disruption and the Gateway scheme will need to carry out other significant works. Once built Gateway traffic would inevitably mean the junction would be overrun once more. Flood risk modelling was inaccurate. In contrast no reason that the lead in for Daw Mill Colliery would be anywhere near as long. Local plan states that the Gateway is close to areas of some of the most significant economic deprivation. This is misleading as the greater deprivation is to the north and, particularly, the north east of the city. Nuneaton and Bedworth, to the north west of Coventry, also suffers similarly (the SEPs SWOT confirms this). The Gateway is beyond the southern boundary therefore if it is to play a part a large number of employees will have to travel from the far side of the city or beyond. Concerns over the process of allocating the site.
See attachment
Object
Publication Draft
Representation ID: 65981
Received: 25/06/2014
Respondent: Coventry and Warwickshire Development Partnership (Mr David Keir )
Agent: Oxalis Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Supports the allocation of a major employment site of sub-regional importance at land in the vicinity of Coventry Airport. Sets out in detail the reasons why the allocation and its removal from the green belt should be supported. Considers however that the wording of DS16 should be modified to allow the incorporation of ancillary facilities such as a hotel and minor retail space
see arttached
Object
Publication Draft
Representation ID: 66056
Received: 27/06/2014
Respondent: Lenco Investments
Agent: RPS Planning & Development
Legally compliant? Yes
Sound? Yes
Duty to co-operate? Yes
RPS has set out objection to the strategy of the plan and the interrelationship between housing and employment, including the Duty to Cooperate, particularly in respect of the sub-regional employment allocation. However, the allocation in DS16 as it stands is soundly based, however, the implications of it and the manner in which it is accommodated in the wider strategy and sub-region is not.
See attachment
Object
Publication Draft
Representation ID: 66340
Received: 20/06/2014
Respondent: Cllr Ann Blacklock
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The plan is unsound and fails 3 of the 4 tests of compliance because this element - removing a very large area from Green Belt -
Is not positively prepare in that it is unreasonable to be meeting the unmet employment need of a neighbouring authority when it requires sacrificing Green Belt land and destroying the character of historic villages.
Is not consistent with national policy on Green Belt and the 5 criteria for maintain designated Green Belt areas [ NPPF section 9 para 80] and is not consistent with the principle of sustainable development.
Is not justified in that there are reasonable alternative available in the sub region.
This measure was added to Draft Publication Plan at the 11th hour; there was NO prior consultation: no consultation with neighbouring residents, nor with ward councillors, nor with the Member's Policy Review Group. It therefore fails to meet the requirements of the SCI.
see attached
Object
Publication Draft
Representation ID: 66409
Received: 27/06/2014
Respondent: Hazel and Robin Fryer
Legally compliant? No
Sound? No
Duty to co-operate? No
Proposal to remove area from the green belt is based on a claimed sub regional need and in compliance with sub regional strategy. This strategy has not been published and no public consultation has been undertaken for it. Use of unpublished strategies to circumvent scrutiny is undemocratic. Justification claimed is that it complies with the RSS evidence base. This is false as the evidence directed employment to the adjoining MUA and regeneration zone of Nuneaton and North Coventry. City unemployment is 9.5% compared with Warwick District of 3.5%. provision of a major warehouse development is also against the RSS evidence base that required logitics to be served by a rail link. The health of Baginton residents has been ignored in proposing this location. Development of this size in a rural village with less than 2,000 residents does not constitute sustainable development. The failure of the SA to consider this issue is inadequate. The plan does not provide any of the exceptional circumstances to remove this area from the green belt. While this development is supported by the LEP they are an unelected, undemocratic and unaccountable group and many have financial vested interests which act against community values. Warwick District has not embraced principles of localism.
see attached
Object
Publication Draft
Representation ID: 66414
Received: 27/06/2014
Respondent: CPRE WARWICKSHIRE
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
As described in our response to Policy DS16, the addition of an exception for Sub-Regional Employment needs is not justified. The justification is based on the SEP, but both the SEP and the WDC draft plan depend on a "Joint Employment Land Review, March 2014" but this report has not been made available. The evidence base is incomplete and there has been no opportunity for consultation or engagement of interested parties on this evidence.
There is no evidence to establish the justification for a sub-regional employment site being located within Warwick District. There has been no sustainability appraisal of alternative sites showing why the proposed site should be developed instead of existing or potential alternative sites.
Environmental impacts have not been sufficiently taken in to account. This is not consistent with the NPPF.
There is no evidence of exceptional circumstances for green belt release other than that put forward in the Gateway Inquiry. the Plan is unsound because Policy DS16 is not justified and reasonable alternatives to the Gateway have not been considered.
The Policy also conflicts with the rationale for Policy EC1.
Changes to Plan:
Delete the exception relating to sub-regional employment
see attached
Object
Publication Draft
Representation ID: 66476
Received: 27/06/2014
Respondent: Friends of the Earth
Number of people: 4
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We do not support the current proposals for the sub-regional employment site at Coventry Airport.
However the results of a planning inquiry are currently awaited. If the development does go ahead, we support the proposal for a masterplan to be prepared. In particular, we support the proposals in paragraph 2.75.
see attached
Object
Publication Draft
Representation ID: 66721
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.
See Attached
Support
Publication Draft
Representation ID: 66761
Received: 27/06/2014
Respondent: Coventry City Council
CCC and WDC have undertaken significant levels of joint working alongside the C&W LEP to support and promote the current development proposal referred to as the Coventry and Warwickshire Gateway. As such, CCC supports the allocation of this area as a sub-regional employment site in Policy DS16. The proposed development offers an opportunity for significant economic investment in the sub-region, creating new jobs and generating economic growth.
see attached