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Object

Publication Draft

DS16 Sub-Regional Employment Site

Representation ID: 65075

Received: 26/06/2014

Respondent: The Community Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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.

Full text:

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

DS19 Green Belt

Representation ID: 65076

Received: 26/06/2014

Respondent: The Community Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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 are no 'exceptional circumstances' that would justify the revision of the Green Belt in this location. The identified site should be removed from the proposals map and the area around Coventry airport retained in Green Belt.

Full text:

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 are no 'exceptional circumstances' that would justify the revision of the Green Belt in this location. The identified site should be removed from the proposals map and the area around Coventry airport retained in Green Belt.

Object

Publication Draft

DS1 Supporting Prosperity

Representation ID: 65483

Received: 27/06/2014

Respondent: The Community Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

'We will provide for the growth of the local and sub-regional economy by ensuring sufficient and appropriate employment land is available within the District to meet the existing and future needs of businesses.'
Warwick DC cannot and should not provide the land for all sub-regional needs as the adverse impacts to the District would significantly and demonstrably outweigh any perceived benefit!

Full text:

'We will provide for the growth of the local and sub-regional economy by ensuring sufficient and appropriate employment land is available within the District to meet the existing and future needs of businesses.'
Warwick DC cannot and should not provide the land for all sub-regional needs as the adverse impacts to the District would significantly and demonstrably outweigh any perceived benefit!

Object

Publication Draft

DS5 Presumption in Favour of Sustainable Development

Representation ID: 65484

Received: 27/06/2014

Respondent: The Community Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Policy DS5 largely repeats the NPPF but it misrepresents Government policy in so far as there is a glaring omission. The NPPF explicitly excludes Green Belt land from the presumption in favour of sustainable development but this is not recognised in Policy DS5. It is therefore unsound.

Full text:

Policy DS5 largely repeats the NPPF but it misrepresents Government policy in so far as there is a glaring omission. The NPPF explicitly excludes Green Belt land from the presumption in favour of sustainable development but this is not recognised in Policy DS5. It is therefore unsound.

Object

Publication Draft

DS8 Employment Land

Representation ID: 65490

Received: 27/06/2014

Respondent: The Community Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Policy DS8 is unsound in so far as it does not satisfy the requirement to meet objectively assessed development requirements.

Despite previous objections, the proposed plan persists with the approach on employment land that leads to an excessive allocation of employment land. The figures on employment land make it very clear that the Plan proposes redevelopment of existing employment land and this leads to the excessive amount of new employment land to be allocated. This makes both the proposed Plan and the associated Sustainability Appraisal unsound.

Full text:

Policy DS8 is unsound in so far as it does not satisfy the requirement to meet objectively assessed development requirements.

Despite previous objections, the proposed plan persists with the approach on employment land that leads to an excessive allocation of employment land. The figures on employment land make it very clear that the Plan proposes redevelopment of existing employment land and this leads to the excessive amount of new employment land to be allocated. This makes both the proposed Plan and the associated Sustainability Appraisal unsound.

Object

Publication Draft

DS9 Employment Sites to be Allocated

Representation ID: 65491

Received: 27/06/2014

Respondent: The Community Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Policy DS9 is unsound - it does not satisfy the requirement to meet objectively assessed development requirements.
Policy DS9 is predicated on the erroneous claim that an additional 19.7ha of employment land is needed. If the calculation IN DS8 is corrected as above, WDC has an excess of employment land. There is no justification for the proposal to allocate green-field land for employment use and in particular, there are no exceptional circumstances for allocating 8ha of Green Belt land at Thickthorn.

Full text:

Policy DS9 is unsound - it does not satisfy the requirement to meet objectively assessed development requirements.
Policy DS9 is predicated on the erroneous claim that an additional 19.7ha of employment land is needed. If the calculation IN DS8 is corrected as above, WDC has an excess of employment land. There is no justification for the proposal to allocate green-field land for employment use and in particular, there are no exceptional circumstances for allocating 8ha of Green Belt land at Thickthorn.

Object

Publication Draft

EC1 Directing New Employment Development

Representation ID: 65497

Received: 27/06/2014

Respondent: The Community Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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.

Full text:

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

EC3 Protecting Employment Land and Buildings

Representation ID: 65499

Received: 27/06/2014

Respondent: The Community Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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.

Full text:

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.

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