Publication Draft

Object

Representation ID: 66825

Received: 27/06/2014

Respondent: Europa Way Consortium

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The housing target policy in DS6 should be clearly identified as a minimum delivery requirement, net of demolitions, to enable the full objectively assessed need to be met.

The District's overall affordable housing need should be increased to 360 affordable dwellings per annum to deal with past undersupply.

The December 2012 Economic and Demographic Forecasts study shows net in migration of 855 persons a year in Warwick, therefore the zero migration scenario used in the 2013 SHMA is likely to have underestimated the need for affordable housing. In addition the 2012 SHMA identified a need for 698 affordable dwellings per annum in the District. This is a significantly higher level of need identified only one year before the joint SHMA.

The Council's proposed figure of 12,860 homes between 2011 and 2029 is over 100 dwellings less than what the Joint SHMA states is the objectively assessed housing target.

Object

Representation ID: 66828

Received: 27/06/2014

Respondent: Europa Way Consortium

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The allocation of B1 and B2 employment uses would be detrimental to the successful delivery of a sustainable residential-led urban extension at this location; the existing evidence base does not provide sufficient justification for the proposal nor is the employment allocation in accordance with the NPPF, which requires a sequential approach for the selection of sites for offices with priority for town centres.

There are already employment opportunities surrounding the site, and having regard to existing supply, there is not a market for additional employment land in this area. The Council has allowed employment land to go for housing nearby, e.g. Gallagher Business Park for 220 dwellings (W/13/0607).

Land south of Gallows Hill would be a better site for the extension of Warwick Technology Park.

Residential rather than employment use would be beneficial to the delivery of the urban extension with regard to amenity, and creating appropriate links between Warwick Gates and Myton School.

Support

Representation ID: 66829

Received: 27/06/2014

Respondent: Europa Way Consortium

Agent: AMEC

The Consortium supports the Council's decision to direct most new development to sites within, or to the edge, of main towns within the District, namely Leamington, Warwick, Whitnash and Kenilworth.

Support

Representation ID: 66830

Received: 27/06/2014

Respondent: Europa Way Consortium

Agent: AMEC

The Consortium fully supports the allocation of Lane West of Europa Way for housing and broadly supports the allocation of associated infrastructure (subject to concerns raised in separate representations).

The land is within walking distance of existing schools, employment opportunities, and community services.

Development may be delivered within five years.

By specifying a specific number of dwellings the Consortium considers Policy DS11 to be too restrictive and should be reworded.

The allocation for housing on the Myton School campus should be reclassified as brownfield development, and not be included in the 1,190 dwellings for Land West of Europa Way. The figure of 1,190 dwellings should be increased to 1,235 dwellings given the potential reallocation of the 8 ha of employment to residential.

Object

Representation ID: 66831

Received: 27/06/2014

Respondent: Europa Way Consortium

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Whilst constructive discussions are taking place with the Consortium, WDC and Myton School, we are nonetheless concerned over the lack of information regarding how the proposed education solution, which requires a major land area owned by the Consortium, has been chosen over alternatives; how the preferred option will be funded, and how it will be delivered.

We have also proposed boundary changes to the school campus in a separate representation.

Object

Representation ID: 66832

Received: 27/06/2014

Respondent: Europa Way Consortium

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We do not support the Council's proposals for a new community sports complex on land West of Europa Way. It is understood the proposed sports complex may include a stadium for Leamington FC with complimentary uses, but we are not aware of any detailed proposals for, or evidence base to support a new community sports complex on Land West of Europa Way. We feel such a stadium would raise residential amenity concerns, funding issues, and the land identified is needed for the school campus.

It is recognised that if land is to be made available for the new school campus in the same location as the proposed community hub, then alternative space needs to be found for other social infrastructure e.g. neighbourhood retail, health facility, and community meeting hall, which can be provided on the site possibly co-located on the Myton School campus.

Object

Representation ID: 66833

Received: 27/06/2014

Respondent: Europa Way Consortium

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy DS15 should be amended so that reference to Policy DS14 (community hub and health facilities) is deleted - compliant with separately submitted representations objecting to Policy DS14.

Object

Representation ID: 66834

Received: 27/06/2014

Respondent: Europa Way Consortium

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We are concerned that the wording requiring a minimum of 40% affordable housing may not allow sufficient flexibility to take into account viability or site specific factors. Consideration of viability is required to be consistent with para 173 of the NPPF.

With regard to sub point ii) sizes, types, and tenures of homes; flexibility is needed to allow for changing housing needs and market conditions over the time required to build an urban extension. Flexibility is needed to facilitate a wide range of factors being taken into account in determining overall housing mix.

We would recommend changing the words 'determined on' in the first line to 'guided by'.

There is a very real danger of creating pockets of relative social exclusion if the proportions of social rented tenures are inflexibly required.

Object

Representation ID: 66835

Received: 27/06/2014

Respondent: Europa Way Consortium

Agent: AMEC

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

the key issue is whether the Council can justify its request for Code Level 4 from plan adoption and Code Level 5 from 2016 given the potential impact on viability. DCLG's latest figures suggest an additional £1.4 - £2.4k per dwelling to achieve Code Level 4, and £14.1k - £16.8k per dwelling for Code Level 5. Therefore the Council needs to demonstrate that this policy is viable, considering the cumulative effect of other policies in the plan.

Object

Representation ID: 66836

Received: 27/06/2014

Respondent: Europa Way Consortium

Agent: AMEC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In separate written representations to policies DS9, DS11, DS12, and DS14, the Consortium has called for modifications to these policies, specifically changes to land use proposals affecting the site allocation H01 - Land West of Europa Way, and as a consequence we believe that modifications are needed to Policies Map No 2 Leamington, Warwick, and Whitnash as follows:

Employment Allocation (Policy DS9) - delete

Amended Site Allocation Boundary (Policy DS11 - H01) - to give a clear distinction between the allocated brownfield housing site at the front of Myton School and H01.

Amended boundary for proposed education campus focused upon Myton School (Policy DS12) as agreed with the Governing Body of Myton School.

Community Hub (Policy DS14) - delete.