DS16
Object
Publication Draft Local Plan: Focused Consultation
Representation ID: 67236
Received: 12/12/2014
Respondent: Mr David Ellwood
Legally compliant? No
Sound? No
Duty to co-operate? No
Considers that the SELS is neither objective or independent and that its function is to support the LEP's decision to make "Coventry and Warwickshire Gateway" its flagship development site in the LEP area and its statement that "Without it [the LEP] cannot achieve its purpose. The study was revised three times after the SEP was published and after the first of those the author changed. It seems that over six months was spent after publication of the SEP ensuring that the Study, a purpose of which was to assist in its preparation, had taken it into account. The treasury and BIS acknowledge that the Government's plan for Britain's sustainable, long-term economic growth is not to be done at the expense of the green belt. Atkins highlights this however overlooks this obvious constraint in taking into account the final choice. A fundamental reason why the Study's findings and conclusions have no credibility. the LEP has said that, if the proposed Gateway development does not go ahead, it (the LEP) cannot achieve its purpose. An Employment Land Review update by G L Hearn for North Warwickshire cited the Black Country and Southern Staffordshire - Regional Logistics Site Study. This recognises that the arising demand is capable of being satisfied by any location in the Midlands which is well served by road and rail. It need not be specifically satisfied within the Black Country/South Staffordshire area, let alone within a particular local authority. The proposed Gateway development site is not served at all by rail. Despite the claims made on behalf of the Applicant at the Public Inquiry, the majority of the deprivation and unemployment in Coventry and the surrounding area is in North and North East Coventry and in Nuneaton and Bedworth to the North East of Coventry. That is why the Coventry-Nuneaton Regeneration Zone was identified for that area in the now abolished Regional Spatial Policy. It is on the opposite side of Coventry from the Gateway site, with the consequent inconvenience, cost and carbon footprint of travel to work at Gateway.
see attached
Object
Publication Draft Local Plan: Focused Consultation
Representation ID: 67272
Received: 15/12/2014
Respondent: Hazel and Robin Fryer
Legally compliant? No
Sound? No
Duty to co-operate? No
The Atkins study is not an objective inquiry into land available in Coventry and Warwickshire. It repeats previous reports by comparing existing sites with commercial planning consent with an area of green belt without consent. it fails to compare with other green belt sites to the north and west of Coventry which have the same green belt status as Baginton and could be made as major employment sites. The Meriden Gap, Coundon Wedge and open land south of the M6 are all much closer to areas of deprivation. The Atkins report makes reference to high levels of worklessness in Binley and Willenhall wards but this not equate to the City Council's figures. The proposed site is too far from the areas in greatest need, Foleshill, Nuneaton and North Warwickshire. Report does not explain how these areas which have the lowest rates of skilled workers will benefit from the presence of high tech design and research facilities. There is already an unbalance of workers in the area, development of the site will make it worse. The report states that accessibility by public transport is good however this relies on improvements being made a claim which could be made for any site. The level of commuting to the site would not be sustainable development. The fundamental problems in locating the site in the small village of Baginton have not been addressed by the report It is in opposition with the Governments stated aims of reducing the need to travel, to reduce energy consumption, to reduce CO2 emissions and creating sustainable communities. The current local plan proposals do not identify a sub region but identify the site to be necessary to meet sub regional needs. The term is confusing and the only defined plans are those which form the disbanded RSS which sought to stop the outflow of workers from urban centres to surrounding rural areas . The RSS recommended that new development should be away from Warwick District and into regeneration zones. The County Council incorporated this aim into its own Structure Plan. The RSS is used as the evidence base for the logistics park however this concluded that sites for warehouses must be served by road and rail at a transport hub. The Atkins report does not address the lack of a rail connection. The claim that the logistics park is part of the automotive supply chain is unsupported and counter to recent evidence which indicates a shift eastwards to the Birmingham / Black Country urban region.
see attached
Object
Publication Draft Local Plan: Focused Consultation
Representation ID: 67303
Received: 12/12/2014
Respondent: CPRE WARWICKSHIRE
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The consultation process is flawed as the policies that are dependent on the SEP are not justified and the focussed change consultation is too narrow in scope to address this (no mention of the SHMA Addendum). This means the proposals are unsound and are not justified.
the recommended scenario of the Employment Land Study is based on CWLEP prediction of jobs. It therefore depends on a circular argument since the SEP was based on the ELR. Different scenarios yield hugely different employment land requirements and this is not adequately explained. The recommnended scenario is significantly higher than Experian's used in the JSHMA addendum.
the proposed approach is predicated on unsubstantiated claims that City Deal will yield 8,800 new jobs. So the employment land requirements are recommended for no better reason than it is what the CWLEP would like to see.
On the supply side, invalid discounts/reductions are applied to employment land and also fails to take account of the 100ha site at Gaydon.
The selection criteria for evaluating strategic employment sites omits green belt - meaning these sites are precluded from the presumption in favour of sustainable development. Direct rail connection is also omitted from the criteria - important for logistic sites. Site Appraisal Assessment Methodology depends on very selective and short-sighted measures. This highly questionable methodology results in good assessments for sites in the south of the area regardless of how ill-served they are by public transport from the area of greatest socio-economic need in the north.
Based on its methodology, the SELS claims that "Coventry and Warwickshire Gateway (Zones A and B) in particular satisfies all the strategic sites criteria." This amazing claim is despite the fact that:
* It is in the Green Belt;
* Access requires extensive off-site highway improvements;
* There is no direct rail link;
* There is serious contamination;
* There is currently poor provision of facilities and amenities;
* There is currently poor public transport accessibility to the site;
* At best, there would be only moderate access to A roads (from Zone A in particular);
* Emergency access (to Zone A) is very restricted in a cul-de-sac passing directly adjacent to Coventry Airport's runway end;
* It is not in the north of the CWLEP area where socio-economic need is greatest;
* It has negative environmental impact.
Twelve of the SELS's Potential Strategic Employment Sites are identified as being a good match to the CWLEP's strategy, all offering good alternatives to the Gateway. Additionally, key strategic sites on the periphery of the CWLEP area, such as DIRFT, the MIRA Enterprise Zone and Blythe Valley Business Park, are omitted without justification. Put simply, there is no shortage of alternative sites.
The recently published version of the SELS has clearly been written with a view to providing, for the already 7-month-old SEP, post-hoc justification for a stream of questionable assertions and heroic assumptions in the SEP, which reflects long-held aspirations. The SELS is nowhere near good enough or cohesive enough to meet even that very limited objective. Its many technical weaknesses and its inherent bias mean that it cannot be taken seriously as an independent assessment of the need for, and supply of, employment land in the CWLEP area. It does not provide a valid justification for development of the Gateway site.
This is a further representation on this part of the Local Plan following publication of new information by the District Council.
The consultation process for Warwick District Council's Publication Draft Local Plan is seriously flawed. As we highlighted in our response to the previous consultation, policies that depend on the Strategic Economic Plan ('SEP') are not justified because key evidence was missing. The current 'focused consultation' is far too narrow to make good these fundamental flaws.
For example, the current consultation document makes no mention of the Strategic Housing Market Assessment ('SHMA') Addendum dated September 2014. This is a critical document that should inform the local plan and its omission renders the current consultation unsound. It appears that WDC is misleading potential consultees, resulting in an unsound local plan - it is not justified.
This consultation response outlines objections to new material and its relationship to earlier material:
1. Summary of issues with the Strategic Employment Land Study ('SELS');
2. Issues with the SHMA Addendum;
3. Issues with the Sustainability Appraisal ('SA'), including the recent SA addenda.
This focused consultation response adds more weight to our previous submissions that the proposed local plan is unsound and it policies are not justified.
Summary of Issues with the Strategic Employment Land Study
The SELS claims that it provides a robust evidence base for the Strategic Economic Plan ('SEP') produced by the Coventry and Warwickshire Local Enterprise Partnership ('CWLEP'). However, the SELS's recommended scenario is based on the CWLEP's own prediction of new jobs. The SELS is neither independent nor robust evidence - it depends on circular arguments. Its call for two or three new sub-regional sites is based on impressions of the chosen consultees rather than substantiated evidence.
The SELS's forecasts of demand for employment land yield vastly differing results with the highest figure being nearly 6 times the magnitude of the lowest. There is no satisfactory explanation for either this very wide disparity or for other conflicting trends across forecasts. The chosen forecast is likely to prove wildly inaccurate.
The SELS forecast based on Cambridge Econometrics' Baseline requires 201 hectares and is stated to be the minimum amount of employment land to meet the CWLEP's plans. The SELS ignores the fact that this forecast is significantly higher than the alternative forecast (Experian's) used in the SHMA Addendum.
In contrast, the SEP claims that the Employment Land Review recommends 250ha. Yet the SELS now recommends that its 'growth figure' of 326ha should be used as a minimum estimate of need. The SELS 'growth figure' is predicated purely on the CWLEP's unsupported prediction that its City Deal would create 8,800 new jobs in advanced manufacturing and engineering by 2025. The SELS takes this figure at face value, without subjecting it to any form of independent verification, and compounds it with unvalidated assumptions. The SELS thus alights on the resulting number as its recommended demand figure, apparently for no better reason than it is what the CWLEP would like to see in order to promote its interests. No justification is given for compounding high growth on a highly optimistic/risky forecast of demand.
On the supply side, SELS starts with a figure of 353ha of available employment land and applies invalid discounts and unjustified reductions until this figure is reduced below the now grossly inflated demand figure. This artificially shrunken supply figure still fails to take proper account of the planned new 100ha employment site at Gaydon. Despite all of these highly dubious exclusions, the SELS still acknowledges that 197ha of employment land is available.
When evaluating strategic employment sites in the LEP area, the SELS acknowledges that planning policy such as Green Belt is relevant but then the skewed selection criteria chosen by SELS omit this key consideration. For example, the SELS does not even mention that Green Belt is precluded from a presumption in favour of sustainable development. Also omitted is another key criterion for large strategic employment sites, particularly logistics sites: namely, direct rail connection. The SELS grossly undervalues rail-connected sites such as DIRFT3, Birch Coppice and Daw Mill.
Despite recognising that the greatest socio-economic need is in the north of the CWLEP area, the SELS uses a Site Appraisal Assessment Methodology that depends on very selective and short-sighted measures. This highly questionable methodology results in good assessments for sites in the south of the area regardless of how ill-served they are by public transport from the area of greatest socio-economic need in the north.
Based on its methodology, the SELS claims that "Coventry and Warwickshire Gateway (Zones A and B) in particular satisfies all the strategic sites criteria." This amazing claim is despite the fact that:
* It is in the Green Belt;
* Access requires extensive off-site highway improvements;
* There is no direct rail link;
* There is serious contamination;
* There is currently poor provision of facilities and amenities;
* There is currently poor public transport accessibility to the site;
* At best, there would be only moderate access to A roads (from Zone A in particular);
* Emergency access (to Zone A) is very restricted in a cul-de-sac passing directly adjacent to Coventry Airport's runway end;
* It is not in the north of the CWLEP area where socio-economic need is greatest;
* It has negative environmental impact.
Additionally, twelve of the SELS's Potential Strategic Employment Sites are identified as being a good match to the CWLEP's strategy, all offering good alternatives to the Gateway. However, even this list of 12 alternatives is an under-estimate because others sites are unjustifiably criticised. Additionally, key strategic sites on the periphery of the CWLEP area, such as DIRFT, the MIRA Enterprise Zone and Blythe Valley Business Park, are omitted without justification. Put simply, there is no shortage of alternative sites.
The recently published version of the SELS has clearly been written with a view to providing, for the already 7-month-old SEP, post-hoc justification for a stream of questionable assertions and heroic assumptions in the SEP, which reflects long-held aspirations. The SELS is nowhere near good enough or cohesive enough to meet even that very limited objective. Its many technical weaknesses and its inherent bias mean that it cannot be taken seriously as an independent assessment of the need for, and supply of, employment land in the CWLEP area. It does not provide a valid justification for development of the Gateway site.
The new evidence does not provide a robust evidence base for the proposed policies in the emerging WDC Local Plan. Multiple forecasts are provided in the various new reports and these forecasts diverge greatly. The SHMA Addendum has one forecast - by Cambridge Econometrics - that is 45% higher than the other (Experian's). The SELS is based on the higher of these forecasts but then it chooses an even higher forecast - its higher growth forecast that is 62% higher again - as the basis of its recommendations. None of these choices of forecast is justified adequately.
The recommendations in the SELS are based on the LEP's prediction of jobs growth; the SELS is neither independent nor robust evidence. The LEP's SEP claims to be supported by the SELS even though the SEP pre-dates the final version of the SELS by 7 months. Such circular arguments are fatally flawed.
The SA makes it clear that the policy to create a new Sub-Regional Employment Site is dependent on the claimed economic benefits. Such claimed benefits are highly speculative. Site selection ignores key constraints such as Green Belt. The SA is unsound and proposed policies are not justified.
The further information we have provided in this focused consultation response adds weight to our previous submissions that the proposed local plan is unsound and it policies are not justified. In particular, it adds to our previous submissions that proposed policies DS16, DS8, DS9, DS19, EC1 and EC3 are unsound and unjustified; the remedies remain as we have previously submitted.