Publication Draft

Object

Representation ID: 66143

Received: 27/06/2014

Respondent: Bloor Homes Midlands

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The majority of the land allocated for development in Leek Wootton is predominantly to the west of the village in the historic half of the settlement as opposed to land of no historic value elsewhere in the village. Three of the four sites (H34, 35 and 36) form part of the historic area within the setting of the conservation area and Woodcote Grade II listed building and locally listed park and garden. The landscape sensitivity study confirms the sites are constrained by the Conservation Areaand that there are visual and functional links between the sites and the heritage assets. The village sites appraisal matrix casts doubts on whether these are suitable and deliverable. According to paragraph 129 of the NPPF the Council should provide evidence that it has identified the significance of the asset which may be affected by a proposal. This has not been undertaken as part of the evidence base, the available evidence is inconclusive. The Local Plan has therefore failed to demonstrate that the proposed allocations are justified in being the most appropriate strategy for Leek Wootton when considered the other reasonable alternatives (Land north of Hill Wootton Road), are effective in being deliverable in that the proposed number of dwellings can be accomodated without causing harm to the heritage assets and their setting, is sustainable development and consistent with national policy. Evidence base does support the residential allocation of land north of Hill Wootton Road - the landscape study confirms the land is free from environmental constraints and designations of of least environmental value compared with other options around the village. It also concludes development could be possible if the noise impact from the A46 could be reduced. Despite this the Council has concluded that the Hill Wootton Road site acts as an environmental buffer between the A46 and the village and an attractive landscape break before entering the village. This approach has not been applied to other sites adjacent to the A46. The Council also raises concern with regard to the width of the site however this is the same as the allocated sites. The Council should review its evidence base and reconsider allocating the Hill Wootton Road site.

Object

Representation ID: 66206

Received: 27/06/2014

Respondent: Bloor Homes Midlands

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Yes

H10 criterion b) requires the housing mix of rural schemes to reflect local need through a parish or housing needs assessment. However this does not take into account demographic trends, market trends or the local needs of different groups in the community as set out in the NPPF.
It also states that beyond meeting local need or where an assessment does not exist the mix should reflect the needs set out in the latest SHMA. However the evidence in the latest SHMA is based on 2011 information and is district wide. It does not reflect the local demand of the parish or village as required by the NPPF

Object

Representation ID: 66207

Received: 27/06/2014

Respondent: Bloor Homes Midlands

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objects to phasing of development of over 50 dwellings at a rate of 50 dwellings per 5 years. This will not boost housing in a district where a 5 year supply cannot be demonstrated It is contrary to the NPPF, will have unintended consequences on the character of villages and not support social cohesion. This approach would result in the phased delivery of infrastructure which may result in new residents being isolated from the existing settlement and services.

Object

Representation ID: 67218

Received: 27/06/2014

Respondent: Bloor Homes Midlands

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Framework requires Plans to allocate land with least environmental/amenity value, and the evidence base would suggest that the selection of proposed allocations at
Leek Wootton has not adhered this principle. Accordingly, the Plan does not contain the most appropriate strategy for Leek Wootton when considered against the reasonable alternatives.

Object

Representation ID: 67219

Received: 27/06/2014

Respondent: Bloor Homes Midlands

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Interest in land adjoining Leek Wootton between village boundary to east and A46. Land is not currently allocated in DS11.
Historic settlement predominantly to west of village with listed buildings locally designated historic parkland and protected trees; the area being a Conservation Area. This half of the village has greater environmental value than more recently developed area. Surprising therefore that the new housing proposed in historic area.
DS11 allocated four sites three of which form part of historic area. Sites fall within setting of Grade II LB, the setting of the Conservation Area and locally listed park and garden.
The Landscape Sensitivity and Ecological & Geological Study confirms sites are constrained by Woodcote and Conservation Area, and that there are visual/functional links between sites and heritage assets. The sites would not be suitable for commercial development due to proximity to the Conservation Area and listed building. It is recognised that a commercial use of a building may be different from a residential use in terms of the nature of its use, however, the development itself will have a very similar physical impact on the heritage assets/setting in terms of changing the character/appearance of land, and the loss of important views.
The Village Sites Appraisal Matrix casts doubt as to whether these sites are suitable/deliverable, with references to the sites being 'potentially suitable', and 'achievable, subject to overcoming landscape heritage issues'. Evidence base does not support allocation of these sites for new housing. Moreover, having regard to paragraph 129 of the Framework, the Council are required to specifically identify and assess the particular significance of the asset that may be affected by a proposal (including by development affecting the setting of a heritage asset) taking account of the available evidence and any necessary expertise. They should take this assessment into account when considering the impact of a proposal on a heritage asset, to avoid/minimise conflict between the heritage asset's conservation and the proposal.
No such assessment has been published by the Council or therefore taken into account. The available evidence base is inconclusive and there is a lack of an adequate evidence base to justify the allocation. The draft Local Plan has failed to demonstrate that H34, H35 and H36 are justified as most appropriate strategy for Leek Wootton, when considered against alternatives outside the historic environment which is effective in being deliverable without causing harm to the heritage assets and their setting; and, sustainable, consistent with NPPF.
The Council's evidence base does support the residential allocation of land north of Hill Wootton Road to which Bloor Homes have an interest, and which is shown on the attached plan.
The Landscape Sensitivity and Ecological & Geological Study confirms the land is free from environmental constraints/designations, and identified of least environmental value compared to other options around the village. Concludes the site would be suitable for residential development, providing noise impact from adjacent A46 could be reduced. Evidence has been provided to the Council demonstrating that suitable mitigation could be incorporated into any detailed design to achieve satisfactory noise environment, and this evidence has not been challenged. Evidence has been provided to the Council to demonstrate development would be 'deliverable' as defined by the Framework.
Council has concluded within the Village Sites Appraisal Matrix that the site acts as an environmental buffer between the A46 and the village, and an attractive landscape break before entering the village. This is not a formal landscape or environmental designation referred to within the evidence base, and is a designation which is not applied by the Council to other settlements alongside the A46. Concern is also raised as to the width of the site, although it will be noted the site is the same width as other proposed allocations within the village and District.

Object

Representation ID: 67220

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 subregion.
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.
The Council should therefore review its objectively assessed housing need figure prior to submission.
In the context of delivering sustainable development, this review should consider economic, social and environmental effects of increasing the level of housing growth in order to balance with the forecast economic growth and economic ambitions of the Council. Other representations made by Bloor Homes Limited to the draft Local Plan have identified locations where additional housing growth can be accommodated.
In the absence of this exercise being undertaken, Bloor Homes Limited would invite the Inspector to find this Plan 'unsound'.

Object

Representation ID: 67221

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.

Object

Representation ID: 67222

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.

Object

Representation ID: 67223

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.

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.