Sustainability Appraisal - Publication Draft

Object

Representation ID: 66413

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

The proposed Plan is unsound because there is no evidence that Policy DS16 is justified. The Plan should be the most appropriate strategy when considered against reasonable alternatives. There is no evidence that there has been a balanced evaluation of reasonable alternative sites. The Sustainability Appraisal claims major positive economic effects but does not seem to have included analysis of the environmental effects of the Sub-Regional Employment Site (Gateway) proposal. The proposed Plan, with its SA, is unsound.

Object

Representation ID: 66581

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Policy DS8 is unsound - it does not satisfy the requirement to meet objectively assessed development requirements. The plan proposes excessive allocation of employment land. The Plan proposes redevelopment of existing employment land and this is part of the rationale for this. The SA's section on Consultation Responses shows no recognition of CPRE's earlier consultation responses despite claiming positive effects of the ammountof employment land. This makes both the proposed Plan and the associated Sustainability Appraisal unsound.

in summary:
 The margin "to provide flexibility of supply" (16.5ha) is excessive (almost 50% extra on top of the established demand of 36ha) in order to provide 'choice'. In terms of 'additional buffer to ensure choice' for housing, the NPPF proposes a 5% buffer. Even double that buffer (10%) amounts to 3.6ha rather than 16.5ha;
 The addition of a further 13.5ha for "potential replacement for redevelopment of existing employment areas" is also unjustified. This approach conflicts with the 'brownfield first' approach of policies DS4 (Spatial Strategy) and EC3 (Protecting Employment Land). There is no valid justification for releasing existing employment land in urban areas rather than regeneration as employment land, improving effective use of existing urban employment sites.

The established employment land requirement is 39.6ha. The Plan shows that there are 47.55ha of available employment land, confirming that there is an excess supply of employment land.