Publication Draft

Object

Representation ID: 66010

Received: 27/06/2014

Respondent: University of Warwick

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Removal of what is referred to as "Central Campus West" from the Green Belt has been a longstanding objective of the University. This is in order to establish a secure long-term boundary around the edge of the campus and to allow development to be approved and to proceed without the unnecessary constraints of Green Belt policy which are no longer relevant to the University's circumstances. The University therefore supports the revised Green Belt boundary under policy DS19.

However the University considers that Local Plan policy DS19 is not sound because it is inconsistent with para 83 of the NPPF which requires exceptional circumstances to be identified. These should be specifically included in the supporting text.

Support

Representation ID: 66011

Received: 27/06/2014

Respondent: University of Warwick

Agent: Turley

Policy MS1 is welcomed in supporting the role that the University plays in the local economy as a long established major site. The recognition of the University's intention to refresh its campus masterplan is also welcomed. The policy is considered to be sound because it is consistent with national policy in supporting sustainable economic development.

Support

Representation ID: 66012

Received: 27/06/2014

Respondent: University of Warwick

Agent: Turley

The University welcomes policy H6 which offers support for student accommodation where it is located on the University of Warwick Campus. This is considered to be sound in supporting the development of sustainable residential accommodation for the student population of the university. Where off-campus
accommodation is promoted by others, the University supports the locational criteria in the policy which will help sustain public transport routes that serve the University from both Coventry and Leamington.

Object

Representation ID: 66015

Received: 27/06/2014

Respondent: University of Warwick

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy CC3: Buildings Standards Requirements is considered unsound as presently
drafted. In respect of residential buildings, the policy is no longer appropriate following the findings of the Housing Standards Review and publication of the related Ministerial Statement which has signalled the intention of the Government to wind down the Code for Sustainable Homes to coincide with national sustainability standards through the building regulations. Furthermore it is inconsistent with the guidance given in paragraph 95, NPPF.

Policy CC3 provides no supporting evidence confirming that it is feasible and viable for all non-residential development over 500 sq.m to meet the BREEAM Very Good standard. In respect of non-residential buildings, the University of Warwick has delivered a number of its buildings to the BREEAM standard and is committed to delivery of its estates strategy to the highest possible
environmental sustainability standards. However, the BREEAM standard is not always the most appropriate method to ensure the optimum sustainability performance of non-residential buildings and the policy could be more effective in allowing a greater degree of flexibility particularly for smaller development
projects.

Support

Representation ID: 66016

Received: 27/06/2014

Respondent: University of Warwick

Agent: Turley

The requirement for developments to "protect, and where possible enhance, the natural environment
including important landscapes, natural features and areas of biodiversity" is supported. This policy is
considered to be sound.

Object

Representation ID: 66017

Received: 27/06/2014

Respondent: University of Warwick

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The requirement within this policy for new developments to protect or enhance biodiversity assets and avoid negative impacts on existing biodiversity is considered to be contrary to the NPPF which at para. 118 requires development to be refused only when '"significant harm" to biodiversity cannot be avoided,
mitigated or compensated. Opportunities to incorporate biodiversity in and around developments should be "encouraged" but avoidance of impacts is not a requirement of the NPPF. This policy is considered to be unsound because it is not consistent with national policy.

Object

Representation ID: 66019

Received: 27/06/2014

Respondent: University of Warwick

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We are concerned by the requirement in the supporting text for a recharging point for plug-in and other ultra-low emission vehicles to be provided for each off street parking space. This is excessive and uneconomic on the basis of current practice, and ignores the possible and likely developments in technology in coming years.

The University currently has 30 charging points across its campus and its transport consultant Arup considers it almost impossible to estimate how many plug-in vehicles will be in use in years to come as estimates have been widely inaccurate to date. They consider that the growth area will be around hybrids rather than full electric vehicles. The means of charging and storing energy in vehicles will also be subject to change, as technology advances.

The supporting text requirement of 1:1 provision is considered unrealistic and unreasonable.

Object

Representation ID: 66021

Received: 27/06/2014

Respondent: University of Warwick

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We note that proposals for a Country Park in Kenilworth have been included in the draft Infrastructure Delivery Plan. Whilst the University is not averse to a Country Park in this location, as it would supplement the University's own Jubilee Wood, planted in 2012, its inclusion within the draft IDP is considered to make
the Local Plan unsound because it is not justified by a relevant policy requirement within the Local Plan itself. The only policy reference to the creation of Country Parks is in respect of Tachbrook to the south of Leamington.