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DS16 Sub-Regional Employment Site
Representation ID: 65404
Received: 27/06/2014
Respondent: Stoneleigh & Ashow Parish Council
Agent: Parklands Consortium Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Stoneleigh and Ashow Parish Council considers Policy DS16 is unsound as it contravenes the NPPF: There has been no Public consultation with the local community and other stakeholders concerning the removal of this land from the Green Belt.
There is no policy for a Sub Regional Employment site which is not the most appropriate strategy when considered against reasonable alternatives.
No objectively assessed need for the policy has been established or consideration undertaken for reasonable alternatives subject to sustainability appraisals. This policy should be based upon evidence including the production of a sub-regional strategy, not be justified by retrospective evidence
STONELEIGH AND ASHOW PARISH COUNCIL REPRESENTATION: Policy DS16 ; Local Plan
This policy is unsound: it is not justified.
The justification for Policy DS16 relies on the Strategic Economic Plan (SEP) commissioned by CWLEP in March 2014. The SEP supported the Coventry and Warwickshire Gateway application, the subject of a call in inquiry awaiting a decision by the SoS. The SEP and the WDC draft plan depend on a 'Joint Employment Land Review, March 2014, which has not been made available for public consultation or the engagement of interested parties on this evidence. There is no evidence of exceptional circumstances to justify a Sub-Regional Employment site
Object
Publication Draft
H06 East of Kenilworth (Thickthorn)
Representation ID: 65409
Received: 27/06/2014
Respondent: Stoneleigh & Ashow Parish Council
Agent: Parklands Consortium Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
As current ONS figures demonstrate, WDC's housing figures are almost 30% higher than current predictions the requirement for urban expansion within the Green Belt is no longer an urgent requirement. The proposed housing site H6 demonstrates no very special circumstances for development in the Green Belt and the removal of this very important section of the A46 Green Corridor.
Stoneleigh and Kenilworth Parish Council submission:
WDLP 2014 Publication Draft:DS6, DS7 DS10 and DS11
Paragraphs 2.20, 2.22, 2.37 and 2.39
Policy Map 5
Details of Why the Local Plan is not sound:
The provision of 12,860 new homes between 2011 and 2029, (para.2.20) is based on projections of population numbers through to 2029, form the SHMA of 2013, but the plan projections used population data from the ONS which only covers the period until the year 2021. Revised ONS data, (May 2014), covers the full period until 2029 and shows much slower growth projections.
NPPF requirements that the latest ONS data is used for making growth projections require that these housing figures should be revised downwards. This requirement would minimise the need to consider locating the balance of housing land in Greenfield sites, (para2.22)
Policy Map 5 shows the allocation of a Green field site H06 to the east of Kenilworth, (Thickthorn) for the allocation of 760 houses, (para2.39). This use of the Green Belt does not demonstrate very special circumstances as required by the NPPF and would breach the A46 Green Corridor.
Object
Publication Draft
TR5 Safeguarding for Transport Infrastructure
Representation ID: 65584
Received: 27/06/2014
Respondent: Stoneleigh & Ashow Parish Council
Agent: Parklands Consortium Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Green belt sites indicated for the area of park and ride search are not sound as they are not located at a strategic close to the envelopes of the towns of Kenilworth or Leamington Spa and would create urban sprawl in the Green Belt as they will require large areas of hard surface, lighting and bus shelters. Alternative areas which are more sound should be considered as part of the area of study for the Park and Ride facility.
TR5 Stoneleigh and Ashow Parish Council
Warwick District Council Local Plan 2014 Publication Draft TR5
Paragraph Number 5.59.3.
Policy maps 5 and 12
The proposal is not sound and is
Not justified and Not consistent with National Policy.
The area of search for the Park and Ride facility to the south of Leamington are all located in green belt areas adjacent to the A452 The sites are not located on a Strategic Road Link or in an ideal position for a transport interchange.
However the Councils projections of population numbers through to 2029 are from the (SHMA of 2013) and the revised ONS data (May 2014) indicates much slower growth and the NPPF requirement to use current data to determine housing targets may allow Green Belt area previously required to meet housing short falls to be considered within the park and ride study area.
Object
Publication Draft
DS19 Green Belt
Representation ID: 65681
Received: 27/06/2014
Respondent: Stoneleigh & Ashow Parish Council
Legally compliant? No
Sound? No
Duty to co-operate? No
The list of sites proposed to be removed from the Green Belt includes "land in the vicinity of Coventry Airport (sub-regional employment site)". This change was not included in previous versions of the emerging WDC plan, The RDS explicitly argued against such a course of action. There has therefore been no prior consultation on this proposed GB change. This makes the proposed policy unsound and unjustified because the consultation process has not allowed effective engagement of interested parties.
See attached
