EC3 Protecting Employment Land and Buildings

Object

Representation ID: 65150

Received: 24/06/2014

Respondent: Sport England

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Please my comments for Policy DS14

Support

Representation ID: 65249

Received: 25/06/2014

Respondent: Mapeley Gamma Acquisition Co (4) Limited (acting by its Joint LPA Receivers Fergus Jack & Bryn Williams)

Agent: Turley

Support for Policy EC3

Object

Representation ID: 65499

Received: 27/06/2014

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.

Object

Representation ID: 66142

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.

Object

Representation ID: 66373

Received: 27/06/2014

Respondent: Ignis UK Property Fund

Agent: WYG Planning and Environment

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Ignis property UK object to the allocation of the site at Olympus Avenue/ Apollo Way as committed employment land under Policy EC3(Protecting Employment Land and Buildings) for the following reasons:-

* The basis for its allocation as committed employment land is unclear. The policy relates to existing and committed employment land and buildings. The site in question is undeveloped and comprises a greenfield site, never having been developed in the past. It cannot therefore comprise existing employment land or building.
* Paragraph 3.41 of the draft Local Plan notes that "the Districts portfolio of available employment land includes sites with planning permission, those covered by Development Briefs or allocations from the previous Local Plan". The site in question was included in the area granted outline planning permission in 1989 (W88/0385) for the wider Tachbrook Park employment area. That permission is no longer extant and in any event the land has lain undeveloped for circa 15 years. While a development brief did exist to guide the development of this wider area (adopted 1987) the opening paragraph of this document makes it clear that this was prepared pursuant to the Warwick, Leamington and Kenilworth Urban Structure Plan (1979). Importantly the site was not allocated in the Local Plan for the period 1996-2011, including following its review on September 2010.
* The NPPF states that planning policies should avoid the long term protection of sites allocated for employment uses where there is no reasonable prospect of the site bringing forward uses for that purpose and that alternative uses for land and buildings should be considered on their merits. The lack of investment over the last 15 years suggests such alternatives should be considered.
* The NPPF requires the Local Plan to be justified forming the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence. The Council's most recent employment evidence base (Employment land Review May 2013) fails to consider the site in question for employment use and accordingly the potential to release the site for other alternative uses. Reference to
* The site is not required to meet employment land needs as the Employment land demand identified in policy DS8 includes a 16.5ha margin of flexibility. The calculation of this required margin is flawed and it is over inflated by virtue of the calculation relating to the higher development trends of the 2000-2008 period. The reduction in employment land by 1.7 ha (the area of the land in question) will have no material effect on employment objectives.
To summarise - the site is undeveloped, does not benefit from extant planning permission, is not subject to an up- to- date Development Brief and is not allocated in the previous Local Plan. Policy EC3 is simply not applicable to the land in question and its inclusion, therefore, is not coherent or justified and is therefore unsound.

Object

Representation ID: 66527

Received: 27/06/2014

Respondent: Friends of the Earth

Number of people: 4

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We object to the last sentence in proposed policy EC3 "this policy does not apply to land which provides for sub regional employment needs". It is very important that if land in the Coventry Airport area is allocated for employment use, that it remains in that use in perpetuity, and is not converted to housing use, for example.