Local Plan Strategy
Object
Publication Draft
Representation ID: 65616
Received: 27/06/2014
Respondent: Warwickshire County Council [Archaeological Information and Advice]
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
It is not clear whether any regard has been given to the SCS for Warwickshire, 'People, Places and Prosperity'. This document is neither referenced within the Local Plan Publication Draft consultationndocument nor appears in the list of evidence base documents on the WDC website. The three elements of the vision for Warwickshire, as set out in the Warwickshire SCS, are: tackling inequities existing either by geography or within communities; ensuring good access to services, choice and opportunity; and pursuing
sustainability with respect to people, place and prosperity.
The strategy set out at paragraph 1.42 of the Local Plan Publication Draft consultation document does not make reference to tackling inequality or facilitating access.It is therefore unclear whether these matters have been considered through the plan-making process.
The Planning Inspectorate document 'Examining Local Plans Procedural Practice' (December 2013) identifies at part B that "the Plan must have regard to any Sustainable Community Strategy (SCS) for its area (i.e. County and District)". Furthermore, the slightly older Planning Inspectorate document 'Local Development Frameworks: Examining Development Plan Documents: Soundness Guidance'. Specifies at paragraph 1.1 that the submission of a SCS is necessary for the Examination, which in the case of a District Local Planning Authorities should also include one copy of the County's SCS.
It is not clear whether WDC intends to submit a copy of the Warwickshire SCS, given the absence of this
document in the list of evidence base documents on the WDC website. Furthermore it is not clear whether the Warwickshire SCS has even been taken into account in the preparation of the Local Plan. On this basis, WCC questions whether the Local Plan is legally compliant
See attached Representations.
Object
Publication Draft
Representation ID: 65629
Received: 27/06/2014
Respondent: Whitnash Town Council
Legally compliant? No
Sound? No
Duty to co-operate? No
Plan is unsound for the following reasons:
The Local Plan Strategy 1.43 on page 11 says the strategic priorities, are
supported by a Spatial Strategy which seeks to:
maximise use of brownfield sites;
only bring forward greenfield sites in sustainable locations;
Contradiction of what is actually happening. Majority of housing developments are taking place south of River Leam on Greenfield sites. 4655 dwellings currently scheduled to be built on Greenfield sites.
Plan not positively prepared and does not demonstrate effective joing working with neighbouring authorities. WDC could alleviate disproportionate number of houses in one area of district. Applications in the pipeline already amount to 6.5 yr supply.
Supportive of need for houses for local people, however claimed numbers are exagerated to increase Govt. revenue to WDC. Houses planned not aimed at first time buyers but at executive buyers from beyond area. Need for bungalows and housing mix.
Fails to avoid coalescence - Developmnet sites between Myton Road and Europa Way, land south of Harbury Lane and east of railway in Whitnash and south of Campion School coalesces the large part of S Leamington, Whitnash and Warwick.
WDC has not consulted with local people over number of houses required and location. Local people have had no input into the LP.
Object
Publication Draft
Representation ID: 65632
Received: 25/06/2014
Respondent: Mr Kelvin Lambert
Legally compliant? No
Sound? Not specified
Duty to co-operate? Not specified
Despite the best efforts of the WDC planning staff in trying to find solutions, significant problems remain with the proposals for 2900 houses around Europa Way and Harbury Lane.
Transport and sustainability: incidents such as gas pipe repairs and problems on the M40 cause serious congestion on the south side of Warwick and Leamington. There are long queues on Europa Way and Gallows Hill. It is hard to say how widening such roads will solve the problem and undermines claims that the south side of the towns is better placed to cope with traffic than the north. The extra 2900 houses proposed for the south of the towns will make this worse on a daily basis as the river crossings will not be improved under the local plan. Estimated transport costs quoted come to more than £30m. If the Local Plan is 'sustainable' in terms of transport, why must so much money be spent on roads?
It is difficult to understand the thoughts behind remarks that a development on the south side of Leamington will be closer to facilities when the route to Warwick Hospital is through congested roads. The connections to both stations are through congested roads with little parking - the distances are too far for most people to walk or cycle. The supermarkets have congested approaches.
Object
Publication Draft
Representation ID: 65638
Received: 27/06/2014
Respondent: Warwickshire County Council Physical Assets Business Unit
Agent: Savills
Legally compliant? No
Sound? Not specified
Duty to co-operate? Not specified
It is noted that the Local Plan Publication Draft is based on the key priorities in the Warwick District Council Sustainable Community Strategy (SCS), 'A Shared Vision. However it is unlear whether any regard has been given to the SCS for Warwickshire, 'People, Places and Prosperity'. This document is neither referenced within the Local Plan Publication Draft consultation document nor appears in the list of evidence base documents on the WDC website. It is unclear whether the matters contained in it have been considered through the plan-making process as required in government guidance. WCC therefore questions whether the Local Plan is legally compliant.
See attachment
Object
Publication Draft
Representation ID: 65672
Received: 27/06/2014
Respondent: Roger Saunders
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
In my view,and as illustrated by such groups as Save Warwick,the developments South of Warwick continue to be disproportionate to reasonable need. Without additional significant infrastructure investment it will impact Warwick Town and District detrimentally.
A more reasonable I.e. reduced provision of development would have a far less negative impact on traffic,pollution, character, and attractiveness (to residents and businesses new, old, and potential) of the Town and District. It would be more likely to enable Well Being and Healthy Living. It would be less likely to require additional significant infrastructural investments or Social Provision.
The ambitions of the current Plan are beyond reasonable need and contrary to the wishes of significant numbers of the local population: it feels rather undemocratic! and lacking in wisdom and sustainable vision.
Support
Publication Draft
Representation ID: 65957
Received: 25/06/2014
Respondent: CWLEP Planning Business Group
The CWLEP notes that the Local Plan submission draft has been positively prepared and supports the growth ambitions of the C&W SEP for growth and investment. However more reference should be made to the overarching framework for growth and positive statements toward achieving inward investment and economic growth in line with the NPPF
Warwick District Council Local Plan Consultation:
Response from Coventry and Warwickshire Local Enterprise Partnership
Thank you for inviting the CWLEP to comment on your Local Plan consultation.
The CWLEP notes that the Local Plan submission draft has been positively prepared and supports the growth ambitions of the C&W SEP for growth and investment. However more reference should be made to the overarching framework for growth and positive statements toward achieving inward investment and economic growth in line with the NPPF.
The CWLEP recognises that the pre submission Local Plan makes strong connection between the need for employment growth and housing growth. However, the CWLEP questions whether the plan makes adequate provision for new employment land, in terms of quantum, location and choice. Policy DS8 states the Council will provide for a minimum of 66 hectares and paragraph 2.29 says 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 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 and to enable the decision-taker to be responsive to meeting business needs. The CWLEP would advise that strong consideration should be given to the employment land study (the Atkins study).
The allocation of land in the vicinity of Coventry Airport as a sub-regional employment site (Policy DS9) supports the SEP. However Policy MS2: Major Sites in the Green Belt does not support the SEP. The local plan should take a more positive stance to the sites identified, which includes Honiley Airfield at Fen End, rather than merely comment that "there may be very special circumstances to justify further development." If this were to be the case there would be no need for the policy at all as further development could be allowed under existing Green Belt policy. The policy should identify the sites for development and set down development management criteria, which should include for flexibility in proposed uses.
Policy EC1 fails to comply with the policies of the NPPF in relation to opportunities for SMEs. The NPPF provides for the conversion of existing buildings (not just as part of a farm diversification scheme) plus the erection of well-designed new buildings within rural areas. The NPPF also provides for the replacement of a building. These forms of development do not appear to be provided for in the plan (except in the Green Belt). There should also be no need in EC1 - In rural areas, criterion e) to limit support to just the growth and expansion of 'existing rural businesses and enterprise'. In line with the SEP and NPPF the policy should allow for new business start-ups and enterprises moving into the area. The provision and effect of the policy is inconsistent with the explanation to it.
The CWLEP considers that there are a number of potential missed opportunities:
* Rail links - Warwick Parkway/Leamington stations should be identified and the implications should be considered. There could be opportunities to encourage sustainable interchange facilities and at Leamington there could be issues associated with the gyratory at Old Warwick Rd/Bath St/Spencer St/Lower Avenue.
* Employment sites - Notwithstanding the Green Belt issues at Fen End, Stoneleigh Park and Thickthorn the document is a bit cautious in tone. In addition, there should be a commitment for the monitoring and alignment of employment with the needs of business and investment, which should be based on evidence of revised economic forecasts.
* Kenilworth Station - a bit cautious in tone
* High Employment/housing ratio - This is potentially quite difficult in that it raises long term development issues that could lead to housing choices needing to be made in the future presenting WDC with some very difficult strategic housing land decisions about the whole balance of the development of Warwick/Leamington. This could eventually lead to a need to consider Green Belt releases to the north.
* Policy EC1 could be more positively worded, for example, it could be amended to read "It is not clear whether Policy EC1 applies equally within and beyond the Green Belt"?
* Monitoring and review - there should be a commitment from each Council and the C&W LEP area on monitoring and alignment employment. This monitoring data would identify the needs of business and investment should be based on evidence on revised economic outlook/forecasts and current market conditions. This data will also help to guide the alignment between housing and employment land provision for the sub-region.
CWLEP Planning Business Group, June 2014.
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Please see the below e-mail sent on behalf of the CWLEP:
Please note that the response submitted on behalf of the CWLEP to the WDC Local Plan contained a minor error - please disregard the suggestion that policy EC1 should be more positively worded.
Kind regards
Lizzie
Support
Publication Draft
Representation ID: 66023
Received: 27/06/2014
Respondent: Centaur Homes
Agent: McLoughlin Planning
Para 1.42 and 1.43 Centaur Homes support the need to deliver housing in the District and it is central to the Plan. It supports the strategic priorities in paragraph 1.43, in particular only bring forward greenfield sites in sustainable locations and avoid coalescence between settlements.
See attachment
Object
Publication Draft
Representation ID: 66024
Received: 27/06/2014
Respondent: Centaur Homes
Agent: McLoughlin Planning
Legally compliant? No
Sound? No
Duty to co-operate? No
Para 1.42 and 1.43 Centaur Homes objects to the allocation of Land at Arras Boulevard in Hampton Magna because it is considered to lead to the coalescence between Hampton Magna and Warwick
See attachment
Object
Publication Draft
Representation ID: 66255
Received: 18/06/2014
Respondent: Mr Philip Batt
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Agree with representations of Save Warwick Group. In addition, 3000 houses are planned for Gaydon which will also have a detrimental effect on Warwick and the traffic issues will be multiplied several times. the Local Plan does not address this.
no consideration given to agricultural land south of Warwick much of which is grade 2. The judgement to sacrifice the best agricultural land to protect the green belt is wrong.
Myton Road is seriously overloaded with significant congestion. there should be no further houses built with access to Myton Road.
It was promised that the cycleway at Saumur Way would provide a permanent southern edge to the town. The plan does not address this.
The plan does not consider the impacts of the windfall sites.
See attached
Object
Publication Draft
Representation ID: 66258
Received: 03/06/2014
Respondent: Mr Andrew Instone
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
There is too much new development proposed , with questions about whether the size of the new communities (for instance in Kenilworth) can be managed and controlled with impact on crime and the capacity of local shops, particularly in light of cut backs to public services. By planning to meet the needs of major cities there is a danger that there will be an impact on crime.
See attached