Publication Draft

The employment land required for Warwick District has been assessed as 66 hectares (paras 2.26-7) and has been met in the provisions of this draft Local Plan
Warwick District Council officials have confirmed that the Joint Employment Land Review (JELR) referred to in para 2.71 has Not been completed and is NOT in the public domain. The evidence base is therefore incomplete. There are no means to enable legitimate assessment of the claims made for example in 2.71.
There are as yet NO 'objectively assessed development and infrastructure requirements' (para 1.8) for employment land from outside Warwick District. Therefore 'unmet requirements from neighbouring authorities' (para 1.8) CANNOT form the basis for policies in this draft local plan.
The plan is NOT JUSTIFIED. The proposed sub regional employment site is NOT the most appropriate strategy when considered against reasonable alternatives, for the following reasons:
There are existing SUSTAINABLE ALTERNATIVE sites in the area with infrastructure in place, to satisfy existing and future employment land requirements. The Plan fails to meet the requirements specified in the National Planning Policy Guidance that "the sustainability appraisal needs to compare all reasonable alternatives...and assess these against the baseline environmental, economic and social characteristics.
The proposed site is NOT located close to areas of significant economic deprivation in Coventry and Warwickshire (para 2.73) so as to generate employment for the sub-region. Other alternative sites are better located in this regard.

The planning application for the proposed 'Coventry and Warwickshire Gateway' (para 2.75) is currently the subject of an ongoing Public Inquiry. Evidence submitted to the Inquiry challenged comprehensively the deliverability of that project, the size of the claimed jobs and other benefits to the local communities, the damage to landscape and heritage assets and the supposedly positive environmental impact of the development. Hence the claims made in particular in 2.75 remain contentious and contested and subject to a judgment by the Planning Inspector.
The proposed Sub-Regional Employment Site is in Green Belt. Because there are alternative sites available there are NO VERY SPECIAL CIRCUMSTANCES to justify development on this Green Belt land. The proposal is therefore INCONSISTENT with the National Planning Policy Framework.

The proposal to remove land for a sub-regional employment site in the vicinity of Coventry Airport from the Green Belt has NOT been the subject of appropriate public consultation with the local communities and other stakeholders. The Revised Development Strategy of June 2013, which was consulted upon, identified the site for employment but retained it in Green Belt.
This area of Green Belt south of the City of Coventry has been and remains crucial to the prevention of urban sprawl as identified in the NPPF. Any unjustified proposal to remove this land from Green Belt and to do so without any public consultation is self-evidently unsound.

The employment land required for Warwick District has been assessed as 66 hectares and has been met in the provisions of this draft local plan (paras 2.26-7).
The Joint Employment Land Review (JELR) referred to in para 2.71 has NOT been completed and is NOT in the public domain to enable legitimate assessment of the claims made in 2.71. There are as yet NO 'objectively assessed development and infrastructure requirements' (para 1.8) for employment land from outside Warwick District. Therefore 'unmet requirements from neighbouring authorities'(para 1.81) CANNOT form the basis for policies in this draft local plan.

The Publication Draft proposes to take the site out of the Green Belt while the outcome of a Public Inquiry on a major planning application for the site (the Coventry and Warwickshire Gateway) is still awaited.

The proposed retention within the Green Belt of 111 hectares of this Green Belt (para 2.75 bullet one) relates specifically to the planning application for the 'Coventry and Warwickshire Gateway'.

There are no VERY SPECIAL CIRCUMSTANCES required by the NPPF to justify removal of this land from Green Belt.

Warwick District Council Local Plan 2014 Publication Draft DS 6 and DS 7. Paragraph Numbers 2.20 to 2.30.

The Council's provision of 12,860 new homes between 2011 and 2029 (para 2.20) is based on economic projections for the area including projections of POPULATION numbers through 2029 (from the SHMA of 2013). However,
(1) The Plan projections use the old out-of-date data on population from the ONS which only covers the period until the year 2021. The revised ONS data (May 2014) that cover the full period to 2029 and also show much slower growth are ignored.
(2) The Plan projections are questionable because in translating population numbers into the number of dwellings required, the consultants have assumed a significant decline in the size of the average Warwick household: to a figure eventually reaching 2.181 persons per households by 2029 - lower than the average figure of 2.294 from the 2011 Census.

Warwick District Council Local Plan 2014 Publication Draft DS 6 and DS 7. Paragraph Numbers 2.20 to 2.30.

The Council's provision of 12,860 new homes between 2011 and 2029 (para 2.20) is based on economic projections for the area including projections of POPULATION numbers through 2029 (from the SHMA of 2013). However,
(1) The Plan projections use the old out-of-date data on population from the ONS which only covers the period until the year 2021. The revised ONS data (May 2014) that cover the full period to 2029 and also show much slower growth are ignored.
(2) The Plan projections are questionable because in translating population numbers into the number of dwellings required, the consultants have assumed a significant decline in the size of the average Warwick household: to a figure eventually reaching 2.181 persons per households by 2029 - lower than the average figure of 2.294 from the 2011 Census.