Publication Draft

Object

Representation ID: 65638

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? No

Sound? Not specified

Duty to co-operate? Not specified

It is noted that the Local Plan Publication Draft is based on the key priorities in the Warwick District Council Sustainable Community Strategy (SCS), 'A Shared Vision. However it is unlear whether any regard has been given to the SCS for Warwickshire, 'People, Places and Prosperity'. This document is neither referenced within the Local Plan Publication Draft consultation document nor appears in the list of evidence base documents on the WDC website. It is unclear whether the matters contained in it have been considered through the plan-making process as required in government guidance. WCC therefore questions whether the Local Plan is legally compliant.

Object

Representation ID: 65650

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Questions whether part c) of DS4 which proposes that site allocated for employment development should be in close proximity to existing or proposed housing represents effective spatial planning. Not all employment development is compatible with residential development. B1 offices are suitable but considered as a town centre use the location of which should be considered via a sequential approach. There are previously-developed sites on the edge of Leamington town centre, which are being proposed for residential development which should be subject to this sequential approach. B2 and B8 are less suitable for residential areas therefore the strategic approach to residential and employment allocations should recognise this.

Object

Representation ID: 65657

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concern the council is not meeting the objectively assessed need for employment land through an up to date evidence base.
Employment land calculations include assumptions relating to housing requirements. The Employment Land Review Update (May 2013) evidence base document or employment forecasting have not been updated following the publication of the higher housing figures in the Joint SHMA. The ELR update does not state how the Economic and DEmographic Forecasts study has been used to inform the demographic-based assumptions underlying the employment
forecasting. It is therefore not clear in the ELR Update whether the land being provided for is still appropriate.

Market assessment questions the majority market demand identified by the ELR update for B1a/b on the basis market signals identicate a strong demand for B2/B8 uses and identifies a preference for sites in or on the edge of the town centres. The evidence base informing the Local Plan does not
appear to be responding to the needs of the market, which raises questions over the employment
assumptions being carried forward into the employment figure set out in Local Plan Publication Draft policy
DS8 and explained in supporting paragraphs 2.24-2.29

ELR update makes assumptions about the redevelopment of existing employment areas which WCC considers are ineffective.

Object

Representation ID: 65668

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Considers the allocation of 8ha of employment land north of Gallows Hill is not justified.
Market assesment identifies there is good demand for B1 office space across regional markets, existing out of town offices continue to see poor demand and landowners are seeking to diversify. THis has been evidenced by WDC recently granting permission for residential development on the comitted employment land at Warwick Gates which benefited from planning permission for B1. The focus of demand is for high quality accomodation within or adjacent to the town centres.
There is a severe shortage of land to serve the needs of the distribution
sector nationally and regionally and in Warwick District there are very few existing sites which are available
for industrial and distribution uses to meet local needs. Industrial and distribution uses should be located
with good accessibility to the national and regional road network.
In relation to B2 whilst traditional manufacturing is declining there is renaissance in the advanced manufacturing sector. Warwick District will see good demand from local advanced manufacturing companies given the District's links with the automotive sector. Occupiers prefer sites which are not adjacent to other uses such as offices and residential. Sites which are adjacent to these uses see much lower levels of demand and are often not deliverable. Land North of Gallows Hill does not meet the current market requirements. This is evidenced by slow take up on Warwick Technology Park and lack of interest at Warwick Gates.
Market assessment also disagrees with the ELR update that the majority of demand with be for B1a/b with some demand for storage and distribution. Market signals show very strong demand for B2 / B8. Whilst demand for office accommodation will also be significant, this will be
focused on or adjacent to town centres.
To meet the demands of the office market delivery should be focused on the town centres and informed by a sequential approach. It is not clear why WDC has chosen to allocate Riverside House, an existing office location on the edge of Leamington town centre, for residential development. The market assessment shows there would be good demand there and the ELR update identifies as a good office location. Redevelopment densities would be higher that what could be acheived on an out of town site.
No reasonable justification is provided for the 8ha North of Gallows Hill. No detailed assessment of potential sites which would meet market requirements is provided. land to the north of Gallows Hill would not support the long term future of the Warwick Technology Park, would not be deliverable or viable for office development and is not a suitable location for B2 development.
Previous Local Plan consultation documents note that the relationship of the land with Warwick Technology Park is dependant on this area being accessed directly from the existing Technology Park road. WCC has submitted objections detailing that this link cannot be acheived without loss of existing parking and the use of third party land to overcome the difference in levels. The concept of the Technology Park being a specialist area was diluted by the planning approval for unrestricted B1 use in 1991.
Questions allocation in relation to deliverability, spatial planning and overall masterplanning in terms of
the ability to deliver a spine road through the Land West of Europa Way urban extension if it is not delivered due to poor market demand.
Would create an unattractive gap in development form whilst waiting for market interest.
Amenity considerations arising from the juxtaposition of B2 with residential uses
Impact on Grade II listed Heathcote Hill Farmhouse

Most recent transport assessment has made a 50 / 50 assumption between B1 and B2 and refers to the allocation as Lower Heathcote Farm - the scenario does not therefore reflect the Publication DRaft.

Object

Representation ID: 65725

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Yes

Considers that the approach taken through DS10 for appropriate redevelopment of previously developed sites and focusing development on greenfield sites south of Warwick, Leamington and Whitnash is justified and in accordance with the principles of sustainable development.
The balance of allocated sites in the Plan between urban brownfield sites and other sites is affected by the proposed distribution of employment land. Allocating B1 offices on the fringe of the urban area reducing land available for housing is contrary to the NPPF town centres first' approach in paragraph 23.
WDC has not undertaken a sequential assessment for town centre offices and full justification for the release of more sequentially preferable sites.

Object

Representation ID: 65727

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Considers inclusion of Land West of Europa Way as a strategic growth area for residential development is justified.
The principle of including a mix of uses to the West of Europa Way is deemed appropriate including provision of a medical centre, primary school, local centre and the principle for the expansion of Myton School. However the Local Plan approach to the development of Community Facilities is not considered to be positively prepared, justified, effective or in accordance with national policy and WCC has concerns about the uncertainty as to the amount of land required for the expansion of Myton School.
The inclusion of 8ha of employment land to the West of Europa Way is not deemed appropriate in market, quantum and location terms.

Object

Representation ID: 65732

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

WCC supports the principle of expanding Myton School and the principle of accomodating some of the expansion on land in WCC ownership to the west of Europa Way.
WCC as a landowner has submitted an outline application for residential development which includes an area for the expansion of the school informed by consultation with the adjacent landowner and the LEA. There is however uncertainty regarding the nature and scale of any expansion to Myton School which the Policies Map does not resolve. The Local Plan should identify land requirements for schools which are demonstrated to be necessary and
reasonable. Until expansion proposals are shown to be deliverable the Local Plan should make alternative fall back provision for secondary school facilities.

It is noted that the Strategic Transport Assessment Phase 4 does not appear to consider the impacts of major education development in this location.

Object

Representation ID: 65859

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

WDC have not fully justified the need for, size of and delivery mechanism for a Country Park to the north side of Tach Brook. WCC questions whether the apparant existing deficiencies in accessibility to natural greenspace sites of
over 2ha in the area south of Warwick, Leamington and Whitnash identified in the Green Infrastructure Study 2010 is a sufficient justification for a 62.5ha Country Park. A proportion of existing development in the areas of deficiency is employment and much of the new development being brought forward will provide onsite green space which will be available to existing and new residents. A transparent evidence base is needed to clarify whether a Country Park of this size is necessary or nice to have. Concern is also expressed over the intention to deliver it via Section 106 contributions. Questions whether this approach is able to meet the legal tests for planning obligations set out in the CIL regulations as it is not clear why the delivery of the Country Park is needed to make development acceptable especially as some of the justification is to rectify existing deficiencies. The combined need taking account of all of the proposed housing allocations south of Warwick and Leamington would be 16.6ha, this may be a more appropriate starting point for considering the need for and payment of a country park. Questions why the Park is required for flood alleviation and whether habitat creation and buffering can be acheived via a smaller area. It is unclear how WDC moved from the £1.5million 20 ha peri-urban park. It should be noted that WCC does not object to the principle of providing a Country Park, subject to appropriate justification being provided for a facility of this size through a robust evidence base.

Object

Representation ID: 65861

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Considers the principle of locating the medical centre on WDC land as appropriate and justified and has included this in the recently submitted planning application in response to pre application discussions with NHS property services. It also considers that the County land may be appropriate for local retail facilities subject to evidence of need, market interest and viability. However WCC considers that the proposal set out in Local Plan Publication Draft policy DS14 for the allocation of land in the location shown on the Policies Map, and explained in the supporting text at paragraphs 2.59-2.64, for four specific community uses as a 'Community Hub' is not positively-prepared, justified, effective or consistent with National Policy. The proposals map does not clearly indicate the proposed area. the publicly-available evidence
base documents do not set out a rationale for why all the proposed community uses included in the policy are: a) necessary; b) required to be located to the west of Europa Way; and c) best located within the area marked with a dotted black line on the Policies Map. No justification for floorspace threshold or location of proposed convenience store.
No justification for the need for, size for and specific location of the separate community meeting place and community sports complex and complementary uses.
WCC is not a willing landowner in relation to suggestions that County land could be used to relocate Leamington Football Club. There is no evidence that consideration has been given to the cost and viability of such a scheme, the IDP does not include costings for a small stadium. The Transport assessment does not consider the impacts of a small stadium.

Object

Representation ID: 65862

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Warwickshire County Council (WCC) supports the principle of comprehensively developing strategic sites, to ensure the provision of appropriate uses and necessary infrastructure across a number of different land ownerships through good design. However WCC does not consider that the infrastructure requirements for 'Land at Myton / West of Europa Way' listed in Local Plan Publication Draft Policy DS15 are necessary and justified by a robust evidence
base and has made separate representations in this respect to Local Plan Publication Draft policies DS12 and DS14.