Publication Draft Local Plan: Focused Consultation
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Publication Draft Local Plan: Focused Consultation
1 - DS9
Representation ID: 67241
Received: 12/12/2014
Respondent: CPRE WARWICKSHIRE
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
CPRE Warwickshire opposes the allocation of a new large employment area east of the A429 Stratford Road, Warwick, and deletion of the site off Birmingham Road next to the A46 / A4177 junction.
The existing location is suitable for employment, being adjacent to other employment land and isolated from any services suitable for a residential area. It would be car-served development with no obvious public transport or cycle access. It lies between the town cemetery and the A46, and is used as car parking and access to a large employment area. If the car parking is not required it should be used for new industrial builsings (B1(v) or B2 Use Classes).
The proposed employment land would be between the Stratford Road and the River Avon. It was formerly in part a nursery and can be used again for horticulture.
The proposal for 11.7 ha of B1 and B2 uses would extend the urban area of Warwick southwards and bring new development close to the River Avon. To the east of the Avon is Warwick Castle Park, with only a few low-lying fields between the proposed site and the edge of the Grade I Park.
The effect would be an undesirable spread of the South West Warwick development eastwards across the Stratford Road and into the green wedge of countryside that reached up to the historic town from the south.
This is a further representation on this part of the Local Plan following publication of new information by the District Council.
The consultation process for Warwick District Council's Publication Draft Local Plan is seriously flawed. As we highlighted in our response to the previous consultation, policies that depend on the Strategic Economic Plan ('SEP') are not justified because key evidence was missing. The current 'focused consultation' is far too narrow to make good these fundamental flaws.
For example, the current consultation document makes no mention of the Strategic Housing Market Assessment ('SHMA') Addendum dated September 2014. This is a critical document that should inform the local plan and its omission renders the current consultation unsound. It appears that WDC is misleading potential consultees, resulting in an unsound local plan - it is not justified.
This consultation response outlines objections to new material and its relationship to earlier material:
1. Summary of issues with the Strategic Employment Land Study ('SELS');
2. Issues with the SHMA Addendum;
3. Issues with the Sustainability Appraisal ('SA'), including the recent SA addenda.
This focused consultation response adds more weight to our previous submissions that the proposed local plan is unsound and it policies are not justified.
Summary of Issues with the Strategic Employment Land Study
The SELS claims that it provides a robust evidence base for the Strategic Economic Plan ('SEP') produced by the Coventry and Warwickshire Local Enterprise Partnership ('CWLEP'). However, the SELS's recommended scenario is based on the CWLEP's own prediction of new jobs. The SELS is neither independent nor robust evidence - it depends on circular arguments. Its call for two or three new sub-regional sites is based on impressions of the chosen consultees rather than substantiated evidence.
The SELS's forecasts of demand for employment land yield vastly differing results with the highest figure being nearly 6 times the magnitude of the lowest. There is no satisfactory explanation for either this very wide disparity or for other conflicting trends across forecasts. The chosen forecast is likely to prove wildly inaccurate.
The SELS forecast based on Cambridge Econometrics' Baseline requires 201 hectares and is stated to be the minimum amount of employment land to meet the CWLEP's plans. The SELS ignores the fact that this forecast is significantly higher than the alternative forecast (Experian's) used in the SHMA Addendum.
In contrast, the SEP claims that the Employment Land Review recommends 250ha. Yet the SELS now recommends that its 'growth figure' of 326ha should be used as a minimum estimate of need. The SELS 'growth figure' is predicated purely on the CWLEP's unsupported prediction that its City Deal would create 8,800 new jobs in advanced manufacturing and engineering by 2025. The SELS takes this figure at face value, without subjecting it to any form of independent verification, and compounds it with unvalidated assumptions. The SELS thus alights on the resulting number as its recommended demand figure, apparently for no better reason than it is what the CWLEP would like to see in order to promote its interests. No justification is given for compounding high growth on a highly optimistic/risky forecast of demand.
On the supply side, SELS starts with a figure of 353ha of available employment land and applies invalid discounts and unjustified reductions until this figure is reduced below the now grossly inflated demand figure. This artificially shrunken supply figure still fails to take proper account of the planned new 100ha employment site at Gaydon. Despite all of these highly dubious exclusions, the SELS still acknowledges that 197ha of employment land is available.
When evaluating strategic employment sites in the LEP area, the SELS acknowledges that planning policy such as Green Belt is relevant but then the skewed selection criteria chosen by SELS omit this key consideration. For example, the SELS does not even mention that Green Belt is precluded from a presumption in favour of sustainable development. Also omitted is another key criterion for large strategic employment sites, particularly logistics sites: namely, direct rail connection. The SELS grossly undervalues rail-connected sites such as DIRFT3, Birch Coppice and Daw Mill.
Despite recognising that the greatest socio-economic need is in the north of the CWLEP area, the SELS uses a Site Appraisal Assessment Methodology that depends on very selective and short-sighted measures. This highly questionable methodology results in good assessments for sites in the south of the area regardless of how ill-served they are by public transport from the area of greatest socio-economic need in the north.
Based on its methodology, the SELS claims that "Coventry and Warwickshire Gateway (Zones A and B) in particular satisfies all the strategic sites criteria." This amazing claim is despite the fact that:
* It is in the Green Belt;
* Access requires extensive off-site highway improvements;
* There is no direct rail link;
* There is serious contamination;
* There is currently poor provision of facilities and amenities;
* There is currently poor public transport accessibility to the site;
* At best, there would be only moderate access to A roads (from Zone A in particular);
* Emergency access (to Zone A) is very restricted in a cul-de-sac passing directly adjacent to Coventry Airport's runway end;
* It is not in the north of the CWLEP area where socio-economic need is greatest;
* It has negative environmental impact.
Additionally, twelve of the SELS's Potential Strategic Employment Sites are identified as being a good match to the CWLEP's strategy, all offering good alternatives to the Gateway. However, even this list of 12 alternatives is an under-estimate because others sites are unjustifiably criticised. Additionally, key strategic sites on the periphery of the CWLEP area, such as DIRFT, the MIRA Enterprise Zone and Blythe Valley Business Park, are omitted without justification. Put simply, there is no shortage of alternative sites.
The recently published version of the SELS has clearly been written with a view to providing, for the already 7-month-old SEP, post-hoc justification for a stream of questionable assertions and heroic assumptions in the SEP, which reflects long-held aspirations. The SELS is nowhere near good enough or cohesive enough to meet even that very limited objective. Its many technical weaknesses and its inherent bias mean that it cannot be taken seriously as an independent assessment of the need for, and supply of, employment land in the CWLEP area. It does not provide a valid justification for development of the Gateway site.
The new evidence does not provide a robust evidence base for the proposed policies in the emerging WDC Local Plan. Multiple forecasts are provided in the various new reports and these forecasts diverge greatly. The SHMA Addendum has one forecast - by Cambridge Econometrics - that is 45% higher than the other (Experian's). The SELS is based on the higher of these forecasts but then it chooses an even higher forecast - its higher growth forecast that is 62% higher again - as the basis of its recommendations. None of these choices of forecast is justified adequately.
The recommendations in the SELS are based on the LEP's prediction of jobs growth; the SELS is neither independent nor robust evidence. The LEP's SEP claims to be supported by the SELS even though the SEP pre-dates the final version of the SELS by 7 months. Such circular arguments are fatally flawed.
The SA makes it clear that the policy to create a new Sub-Regional Employment Site is dependent on the claimed economic benefits. Such claimed benefits are highly speculative. Site selection ignores key constraints such as Green Belt. The SA is unsound and proposed policies are not justified.
The further information we have provided in this focused consultation response adds weight to our previous submissions that the proposed local plan is unsound and it policies are not justified. In particular, it adds to our previous submissions that proposed policies DS16, DS8, DS9, DS19, EC1 and EC3 are unsound and unjustified; the remedies remain as we have previously submitted.
Object
Publication Draft Local Plan: Focused Consultation
Sustainability Appraisal
Representation ID: 67287
Received: 12/12/2014
Respondent: CPRE WARWICKSHIRE
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The Sustainability Appraisal has changed significantly since the previous consultation, notably with the SA Addenda. These include an SA of the proposed Sub-Regional Employment Land Site, dated October 2014. This is a further representation on the Sustainability Appraisal following publication of new information by the District Council.
The SA has changed significantly since the previous consultation, notably with the SA Addenda. These include an SA of the proposed Sub-Regional Employment Land Site, dated October 2014.
This SA Addendum recognises that the proposed sub-regional employment site ('Gateway') development could have a significant adverse impact on the Green Belt and its environment ("Ultimately development could result in loss of Green Belt and Greenfield land, and has the potential to significantly affect the landscape character, biodiversity and wetland features..."). The SA assesses the environmental impact as negative to highly negative (especially prudent use of land and natural resources); we consider that this under-estimates the damage that is likely to be caused by such a development.
The SA assesses the impact on the economy as highly positive; consequently, it assesses the impact on poverty, social exclusion, health and well-being as positive. For the reasons we have outlined in the sections above, the SA's assessment is based on flawed analyses and circular arguments.
The SA's assessment on housing and local communities is also erroneous. The 'Gateway' is claimed to support upwards of 10,000 new jobs but the site is located outside urban areas. As we have already shown, the site is not close to the areas of greatest socio-economic need (in the north of the CWLEP area). If many thousand new jobs were created as claimed, it would add great pressure on Warwick District to provide even more homes than the very high figure already proposed. The 'Gateway' site is in the Green Belt and surrounded by Green Belt, exacerbating the challenge of providing suitable housing in a sustainable way. We assess this impact as negative on housing and highly negative both on the local community and on reducing the need to travel.
Even though the SA recognises that the huge scale of the proposed 'Gateway' development could lead to potential large impacts, it assesses the effect on climate change as potentially positive as well as negative. We submit that the non-urban location, increased need to travel, lack of existing sustainable transport and huge scale of built form in the countryside would all lead to adverse impact on climate change.
Overall, the SA greatly over-estimates positive impact of the 'Gateway' and under-estimates the impact on the environment. The 'Gateway' site is an unsustainable location for development of large-scale employment facilities. Even if a sub-regional employment site were justified, there is no evidence that the proposed 'Gateway' site is the most sustainable location - there is no evidence of a methodical sustainability assessment process that compared alternative sites and selected the most sustainable location.
Conclusion
The SA makes it clear that the policy to create a new Sub-Regional Employment Site is dependent on the claimed economic benefits. Such claimed benefits are highly speculative. Site selection ignores key constraints such as Green Belt. The SA is unsound and proposed policies are not justified.
This is a further representation on this part of the Local Plan following publication of new information by the District Council.
The consultation process for Warwick District Council's Publication Draft Local Plan is seriously flawed. As we highlighted in our response to the previous consultation, policies that depend on the Strategic Economic Plan ('SEP') are not justified because key evidence was missing. The current 'focused consultation' is far too narrow to make good these fundamental flaws.
For example, the current consultation document makes no mention of the Strategic Housing Market Assessment ('SHMA') Addendum dated September 2014. This is a critical document that should inform the local plan and its omission renders the current consultation unsound. It appears that WDC is misleading potential consultees, resulting in an unsound local plan - it is not justified.
This consultation response outlines objections to new material and its relationship to earlier material:
1. Summary of issues with the Strategic Employment Land Study ('SELS');
2. Issues with the SHMA Addendum;
3. Issues with the Sustainability Appraisal ('SA'), including the recent SA addenda.
This focused consultation response adds more weight to our previous submissions that the proposed local plan is unsound and it policies are not justified.
Summary of Issues with the Strategic Employment Land Study
The SELS claims that it provides a robust evidence base for the Strategic Economic Plan ('SEP') produced by the Coventry and Warwickshire Local Enterprise Partnership ('CWLEP'). However, the SELS's recommended scenario is based on the CWLEP's own prediction of new jobs. The SELS is neither independent nor robust evidence - it depends on circular arguments. Its call for two or three new sub-regional sites is based on impressions of the chosen consultees rather than substantiated evidence.
The SELS's forecasts of demand for employment land yield vastly differing results with the highest figure being nearly 6 times the magnitude of the lowest. There is no satisfactory explanation for either this very wide disparity or for other conflicting trends across forecasts. The chosen forecast is likely to prove wildly inaccurate.
The SELS forecast based on Cambridge Econometrics' Baseline requires 201 hectares and is stated to be the minimum amount of employment land to meet the CWLEP's plans. The SELS ignores the fact that this forecast is significantly higher than the alternative forecast (Experian's) used in the SHMA Addendum.
In contrast, the SEP claims that the Employment Land Review recommends 250ha. Yet the SELS now recommends that its 'growth figure' of 326ha should be used as a minimum estimate of need. The SELS 'growth figure' is predicated purely on the CWLEP's unsupported prediction that its City Deal would create 8,800 new jobs in advanced manufacturing and engineering by 2025. The SELS takes this figure at face value, without subjecting it to any form of independent verification, and compounds it with unvalidated assumptions. The SELS thus alights on the resulting number as its recommended demand figure, apparently for no better reason than it is what the CWLEP would like to see in order to promote its interests. No justification is given for compounding high growth on a highly optimistic/risky forecast of demand.
On the supply side, SELS starts with a figure of 353ha of available employment land and applies invalid discounts and unjustified reductions until this figure is reduced below the now grossly inflated demand figure. This artificially shrunken supply figure still fails to take proper account of the planned new 100ha employment site at Gaydon. Despite all of these highly dubious exclusions, the SELS still acknowledges that 197ha of employment land is available.
When evaluating strategic employment sites in the LEP area, the SELS acknowledges that planning policy such as Green Belt is relevant but then the skewed selection criteria chosen by SELS omit this key consideration. For example, the SELS does not even mention that Green Belt is precluded from a presumption in favour of sustainable development. Also omitted is another key criterion for large strategic employment sites, particularly logistics sites: namely, direct rail connection. The SELS grossly undervalues rail-connected sites such as DIRFT3, Birch Coppice and Daw Mill.
Despite recognising that the greatest socio-economic need is in the north of the CWLEP area, the SELS uses a Site Appraisal Assessment Methodology that depends on very selective and short-sighted measures. This highly questionable methodology results in good assessments for sites in the south of the area regardless of how ill-served they are by public transport from the area of greatest socio-economic need in the north.
Based on its methodology, the SELS claims that "Coventry and Warwickshire Gateway (Zones A and B) in particular satisfies all the strategic sites criteria." This amazing claim is despite the fact that:
* It is in the Green Belt;
* Access requires extensive off-site highway improvements;
* There is no direct rail link;
* There is serious contamination;
* There is currently poor provision of facilities and amenities;
* There is currently poor public transport accessibility to the site;
* At best, there would be only moderate access to A roads (from Zone A in particular);
* Emergency access (to Zone A) is very restricted in a cul-de-sac passing directly adjacent to Coventry Airport's runway end;
* It is not in the north of the CWLEP area where socio-economic need is greatest;
* It has negative environmental impact.
Additionally, twelve of the SELS's Potential Strategic Employment Sites are identified as being a good match to the CWLEP's strategy, all offering good alternatives to the Gateway. However, even this list of 12 alternatives is an under-estimate because others sites are unjustifiably criticised. Additionally, key strategic sites on the periphery of the CWLEP area, such as DIRFT, the MIRA Enterprise Zone and Blythe Valley Business Park, are omitted without justification. Put simply, there is no shortage of alternative sites.
The recently published version of the SELS has clearly been written with a view to providing, for the already 7-month-old SEP, post-hoc justification for a stream of questionable assertions and heroic assumptions in the SEP, which reflects long-held aspirations. The SELS is nowhere near good enough or cohesive enough to meet even that very limited objective. Its many technical weaknesses and its inherent bias mean that it cannot be taken seriously as an independent assessment of the need for, and supply of, employment land in the CWLEP area. It does not provide a valid justification for development of the Gateway site.
The new evidence does not provide a robust evidence base for the proposed policies in the emerging WDC Local Plan. Multiple forecasts are provided in the various new reports and these forecasts diverge greatly. The SHMA Addendum has one forecast - by Cambridge Econometrics - that is 45% higher than the other (Experian's). The SELS is based on the higher of these forecasts but then it chooses an even higher forecast - its higher growth forecast that is 62% higher again - as the basis of its recommendations. None of these choices of forecast is justified adequately.
The recommendations in the SELS are based on the LEP's prediction of jobs growth; the SELS is neither independent nor robust evidence. The LEP's SEP claims to be supported by the SELS even though the SEP pre-dates the final version of the SELS by 7 months. Such circular arguments are fatally flawed.
The SA makes it clear that the policy to create a new Sub-Regional Employment Site is dependent on the claimed economic benefits. Such claimed benefits are highly speculative. Site selection ignores key constraints such as Green Belt. The SA is unsound and proposed policies are not justified.
The further information we have provided in this focused consultation response adds weight to our previous submissions that the proposed local plan is unsound and it policies are not justified. In particular, it adds to our previous submissions that proposed policies DS16, DS8, DS9, DS19, EC1 and EC3 are unsound and unjustified; the remedies remain as we have previously submitted.
Object
Publication Draft Local Plan: Focused Consultation
DS16
Representation ID: 67303
Received: 12/12/2014
Respondent: CPRE WARWICKSHIRE
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The consultation process is flawed as the policies that are dependent on the SEP are not justified and the focussed change consultation is too narrow in scope to address this (no mention of the SHMA Addendum). This means the proposals are unsound and are not justified.
the recommended scenario of the Employment Land Study is based on CWLEP prediction of jobs. It therefore depends on a circular argument since the SEP was based on the ELR. Different scenarios yield hugely different employment land requirements and this is not adequately explained. The recommnended scenario is significantly higher than Experian's used in the JSHMA addendum.
the proposed approach is predicated on unsubstantiated claims that City Deal will yield 8,800 new jobs. So the employment land requirements are recommended for no better reason than it is what the CWLEP would like to see.
On the supply side, invalid discounts/reductions are applied to employment land and also fails to take account of the 100ha site at Gaydon.
The selection criteria for evaluating strategic employment sites omits green belt - meaning these sites are precluded from the presumption in favour of sustainable development. Direct rail connection is also omitted from the criteria - important for logistic sites. Site Appraisal Assessment Methodology depends on very selective and short-sighted measures. This highly questionable methodology results in good assessments for sites in the south of the area regardless of how ill-served they are by public transport from the area of greatest socio-economic need in the north.
Based on its methodology, the SELS claims that "Coventry and Warwickshire Gateway (Zones A and B) in particular satisfies all the strategic sites criteria." This amazing claim is despite the fact that:
* It is in the Green Belt;
* Access requires extensive off-site highway improvements;
* There is no direct rail link;
* There is serious contamination;
* There is currently poor provision of facilities and amenities;
* There is currently poor public transport accessibility to the site;
* At best, there would be only moderate access to A roads (from Zone A in particular);
* Emergency access (to Zone A) is very restricted in a cul-de-sac passing directly adjacent to Coventry Airport's runway end;
* It is not in the north of the CWLEP area where socio-economic need is greatest;
* It has negative environmental impact.
Twelve of the SELS's Potential Strategic Employment Sites are identified as being a good match to the CWLEP's strategy, all offering good alternatives to the Gateway. Additionally, key strategic sites on the periphery of the CWLEP area, such as DIRFT, the MIRA Enterprise Zone and Blythe Valley Business Park, are omitted without justification. Put simply, there is no shortage of alternative sites.
The recently published version of the SELS has clearly been written with a view to providing, for the already 7-month-old SEP, post-hoc justification for a stream of questionable assertions and heroic assumptions in the SEP, which reflects long-held aspirations. The SELS is nowhere near good enough or cohesive enough to meet even that very limited objective. Its many technical weaknesses and its inherent bias mean that it cannot be taken seriously as an independent assessment of the need for, and supply of, employment land in the CWLEP area. It does not provide a valid justification for development of the Gateway site.
This is a further representation on this part of the Local Plan following publication of new information by the District Council.
The consultation process for Warwick District Council's Publication Draft Local Plan is seriously flawed. As we highlighted in our response to the previous consultation, policies that depend on the Strategic Economic Plan ('SEP') are not justified because key evidence was missing. The current 'focused consultation' is far too narrow to make good these fundamental flaws.
For example, the current consultation document makes no mention of the Strategic Housing Market Assessment ('SHMA') Addendum dated September 2014. This is a critical document that should inform the local plan and its omission renders the current consultation unsound. It appears that WDC is misleading potential consultees, resulting in an unsound local plan - it is not justified.
This consultation response outlines objections to new material and its relationship to earlier material:
1. Summary of issues with the Strategic Employment Land Study ('SELS');
2. Issues with the SHMA Addendum;
3. Issues with the Sustainability Appraisal ('SA'), including the recent SA addenda.
This focused consultation response adds more weight to our previous submissions that the proposed local plan is unsound and it policies are not justified.
Summary of Issues with the Strategic Employment Land Study
The SELS claims that it provides a robust evidence base for the Strategic Economic Plan ('SEP') produced by the Coventry and Warwickshire Local Enterprise Partnership ('CWLEP'). However, the SELS's recommended scenario is based on the CWLEP's own prediction of new jobs. The SELS is neither independent nor robust evidence - it depends on circular arguments. Its call for two or three new sub-regional sites is based on impressions of the chosen consultees rather than substantiated evidence.
The SELS's forecasts of demand for employment land yield vastly differing results with the highest figure being nearly 6 times the magnitude of the lowest. There is no satisfactory explanation for either this very wide disparity or for other conflicting trends across forecasts. The chosen forecast is likely to prove wildly inaccurate.
The SELS forecast based on Cambridge Econometrics' Baseline requires 201 hectares and is stated to be the minimum amount of employment land to meet the CWLEP's plans. The SELS ignores the fact that this forecast is significantly higher than the alternative forecast (Experian's) used in the SHMA Addendum.
In contrast, the SEP claims that the Employment Land Review recommends 250ha. Yet the SELS now recommends that its 'growth figure' of 326ha should be used as a minimum estimate of need. The SELS 'growth figure' is predicated purely on the CWLEP's unsupported prediction that its City Deal would create 8,800 new jobs in advanced manufacturing and engineering by 2025. The SELS takes this figure at face value, without subjecting it to any form of independent verification, and compounds it with unvalidated assumptions. The SELS thus alights on the resulting number as its recommended demand figure, apparently for no better reason than it is what the CWLEP would like to see in order to promote its interests. No justification is given for compounding high growth on a highly optimistic/risky forecast of demand.
On the supply side, SELS starts with a figure of 353ha of available employment land and applies invalid discounts and unjustified reductions until this figure is reduced below the now grossly inflated demand figure. This artificially shrunken supply figure still fails to take proper account of the planned new 100ha employment site at Gaydon. Despite all of these highly dubious exclusions, the SELS still acknowledges that 197ha of employment land is available.
When evaluating strategic employment sites in the LEP area, the SELS acknowledges that planning policy such as Green Belt is relevant but then the skewed selection criteria chosen by SELS omit this key consideration. For example, the SELS does not even mention that Green Belt is precluded from a presumption in favour of sustainable development. Also omitted is another key criterion for large strategic employment sites, particularly logistics sites: namely, direct rail connection. The SELS grossly undervalues rail-connected sites such as DIRFT3, Birch Coppice and Daw Mill.
Despite recognising that the greatest socio-economic need is in the north of the CWLEP area, the SELS uses a Site Appraisal Assessment Methodology that depends on very selective and short-sighted measures. This highly questionable methodology results in good assessments for sites in the south of the area regardless of how ill-served they are by public transport from the area of greatest socio-economic need in the north.
Based on its methodology, the SELS claims that "Coventry and Warwickshire Gateway (Zones A and B) in particular satisfies all the strategic sites criteria." This amazing claim is despite the fact that:
* It is in the Green Belt;
* Access requires extensive off-site highway improvements;
* There is no direct rail link;
* There is serious contamination;
* There is currently poor provision of facilities and amenities;
* There is currently poor public transport accessibility to the site;
* At best, there would be only moderate access to A roads (from Zone A in particular);
* Emergency access (to Zone A) is very restricted in a cul-de-sac passing directly adjacent to Coventry Airport's runway end;
* It is not in the north of the CWLEP area where socio-economic need is greatest;
* It has negative environmental impact.
Additionally, twelve of the SELS's Potential Strategic Employment Sites are identified as being a good match to the CWLEP's strategy, all offering good alternatives to the Gateway. However, even this list of 12 alternatives is an under-estimate because others sites are unjustifiably criticised. Additionally, key strategic sites on the periphery of the CWLEP area, such as DIRFT, the MIRA Enterprise Zone and Blythe Valley Business Park, are omitted without justification. Put simply, there is no shortage of alternative sites.
The recently published version of the SELS has clearly been written with a view to providing, for the already 7-month-old SEP, post-hoc justification for a stream of questionable assertions and heroic assumptions in the SEP, which reflects long-held aspirations. The SELS is nowhere near good enough or cohesive enough to meet even that very limited objective. Its many technical weaknesses and its inherent bias mean that it cannot be taken seriously as an independent assessment of the need for, and supply of, employment land in the CWLEP area. It does not provide a valid justification for development of the Gateway site.
The new evidence does not provide a robust evidence base for the proposed policies in the emerging WDC Local Plan. Multiple forecasts are provided in the various new reports and these forecasts diverge greatly. The SHMA Addendum has one forecast - by Cambridge Econometrics - that is 45% higher than the other (Experian's). The SELS is based on the higher of these forecasts but then it chooses an even higher forecast - its higher growth forecast that is 62% higher again - as the basis of its recommendations. None of these choices of forecast is justified adequately.
The recommendations in the SELS are based on the LEP's prediction of jobs growth; the SELS is neither independent nor robust evidence. The LEP's SEP claims to be supported by the SELS even though the SEP pre-dates the final version of the SELS by 7 months. Such circular arguments are fatally flawed.
The SA makes it clear that the policy to create a new Sub-Regional Employment Site is dependent on the claimed economic benefits. Such claimed benefits are highly speculative. Site selection ignores key constraints such as Green Belt. The SA is unsound and proposed policies are not justified.
The further information we have provided in this focused consultation response adds weight to our previous submissions that the proposed local plan is unsound and it policies are not justified. In particular, it adds to our previous submissions that proposed policies DS16, DS8, DS9, DS19, EC1 and EC3 are unsound and unjustified; the remedies remain as we have previously submitted.
Object
Publication Draft Local Plan: Focused Consultation
DS6
Representation ID: 67305
Received: 12/12/2014
Respondent: CPRE WARWICKSHIRE
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Despite the fact that the current 'focused consultation' does not mention the SHMA Addendum, this document is a significant addition to the evidence base since the previous WDC consultation. Its findings are relevant to many aspects of the draft Local Plan.
The JSHMA Addendum fails to address the caveats ONS make about their projections. The projections simply indicate what might happen if past trends were to continue, and they take no account of future policy changes. The value of the SHMA Addendum is therefore limited. assumptions about headship rates are questionable. It might have been better to await the 2012-based household projections rather than second guess them. The consultants decided to ignore 'unattributable population change' (the difference between ONS estimates and the 2011 census population figure). This decision could have had the effect of overestimating future population. The SHMA Addendum does not articulate its assumptions about vacancies, second homes, sharing, concealed households and institutional population, all factors that will affect future levels of housing need. The report looks at two economic forecasts that vary significantly. But no preference is suggested. Further conflicting market signals means there are no clear conclusions. the assessments show housing need for the HMA varying from 3,270 to 3,981 per annum. However it then alights on a figure of 'about 4,000 per annum' and goes on to treat this as a minimum. The new evidence does not provide a robust evidence base for the proposed policies in the emerging WDC Local Plan.
CPRE's original response on Policy DS6 regarding housing growth of June 2014 remains applicable.
This is a further representation on this part of the Local Plan following publication of new information by the District Council.
The consultation process for Warwick District Council's Publication Draft Local Plan is seriously flawed. As we highlighted in our response to the previous consultation, policies that depend on the Strategic Economic Plan ('SEP') are not justified because key evidence was missing. The current 'focused consultation' is far too narrow to make good these fundamental flaws.
For example, the current consultation document makes no mention of the Strategic Housing Market Assessment ('SHMA') Addendum dated September 2014. This is a critical document that should inform the local plan and its omission renders the current consultation unsound. It appears that WDC is misleading potential consultees, resulting in an unsound local plan - it is not justified.
This consultation response outlines objections to new material and its relationship to earlier material:
1. Summary of issues with the Strategic Employment Land Study ('SELS');
2. Issues with the SHMA Addendum;
3. Issues with the Sustainability Appraisal ('SA'), including the recent SA addenda.
This focused consultation response adds more weight to our previous submissions that the proposed local plan is unsound and it policies are not justified.
Summary of Issues with the Strategic Employment Land Study
The SELS claims that it provides a robust evidence base for the Strategic Economic Plan ('SEP') produced by the Coventry and Warwickshire Local Enterprise Partnership ('CWLEP'). However, the SELS's recommended scenario is based on the CWLEP's own prediction of new jobs. The SELS is neither independent nor robust evidence - it depends on circular arguments. Its call for two or three new sub-regional sites is based on impressions of the chosen consultees rather than substantiated evidence.
The SELS's forecasts of demand for employment land yield vastly differing results with the highest figure being nearly 6 times the magnitude of the lowest. There is no satisfactory explanation for either this very wide disparity or for other conflicting trends across forecasts. The chosen forecast is likely to prove wildly inaccurate.
The SELS forecast based on Cambridge Econometrics' Baseline requires 201 hectares and is stated to be the minimum amount of employment land to meet the CWLEP's plans. The SELS ignores the fact that this forecast is significantly higher than the alternative forecast (Experian's) used in the SHMA Addendum.
In contrast, the SEP claims that the Employment Land Review recommends 250ha. Yet the SELS now recommends that its 'growth figure' of 326ha should be used as a minimum estimate of need. The SELS 'growth figure' is predicated purely on the CWLEP's unsupported prediction that its City Deal would create 8,800 new jobs in advanced manufacturing and engineering by 2025. The SELS takes this figure at face value, without subjecting it to any form of independent verification, and compounds it with unvalidated assumptions. The SELS thus alights on the resulting number as its recommended demand figure, apparently for no better reason than it is what the CWLEP would like to see in order to promote its interests. No justification is given for compounding high growth on a highly optimistic/risky forecast of demand.
On the supply side, SELS starts with a figure of 353ha of available employment land and applies invalid discounts and unjustified reductions until this figure is reduced below the now grossly inflated demand figure. This artificially shrunken supply figure still fails to take proper account of the planned new 100ha employment site at Gaydon. Despite all of these highly dubious exclusions, the SELS still acknowledges that 197ha of employment land is available.
When evaluating strategic employment sites in the LEP area, the SELS acknowledges that planning policy such as Green Belt is relevant but then the skewed selection criteria chosen by SELS omit this key consideration. For example, the SELS does not even mention that Green Belt is precluded from a presumption in favour of sustainable development. Also omitted is another key criterion for large strategic employment sites, particularly logistics sites: namely, direct rail connection. The SELS grossly undervalues rail-connected sites such as DIRFT3, Birch Coppice and Daw Mill.
Despite recognising that the greatest socio-economic need is in the north of the CWLEP area, the SELS uses a Site Appraisal Assessment Methodology that depends on very selective and short-sighted measures. This highly questionable methodology results in good assessments for sites in the south of the area regardless of how ill-served they are by public transport from the area of greatest socio-economic need in the north.
Based on its methodology, the SELS claims that "Coventry and Warwickshire Gateway (Zones A and B) in particular satisfies all the strategic sites criteria." This amazing claim is despite the fact that:
* It is in the Green Belt;
* Access requires extensive off-site highway improvements;
* There is no direct rail link;
* There is serious contamination;
* There is currently poor provision of facilities and amenities;
* There is currently poor public transport accessibility to the site;
* At best, there would be only moderate access to A roads (from Zone A in particular);
* Emergency access (to Zone A) is very restricted in a cul-de-sac passing directly adjacent to Coventry Airport's runway end;
* It is not in the north of the CWLEP area where socio-economic need is greatest;
* It has negative environmental impact.
Additionally, twelve of the SELS's Potential Strategic Employment Sites are identified as being a good match to the CWLEP's strategy, all offering good alternatives to the Gateway. However, even this list of 12 alternatives is an under-estimate because others sites are unjustifiably criticised. Additionally, key strategic sites on the periphery of the CWLEP area, such as DIRFT, the MIRA Enterprise Zone and Blythe Valley Business Park, are omitted without justification. Put simply, there is no shortage of alternative sites.
The recently published version of the SELS has clearly been written with a view to providing, for the already 7-month-old SEP, post-hoc justification for a stream of questionable assertions and heroic assumptions in the SEP, which reflects long-held aspirations. The SELS is nowhere near good enough or cohesive enough to meet even that very limited objective. Its many technical weaknesses and its inherent bias mean that it cannot be taken seriously as an independent assessment of the need for, and supply of, employment land in the CWLEP area. It does not provide a valid justification for development of the Gateway site.
The new evidence does not provide a robust evidence base for the proposed policies in the emerging WDC Local Plan. Multiple forecasts are provided in the various new reports and these forecasts diverge greatly. The SHMA Addendum has one forecast - by Cambridge Econometrics - that is 45% higher than the other (Experian's). The SELS is based on the higher of these forecasts but then it chooses an even higher forecast - its higher growth forecast that is 62% higher again - as the basis of its recommendations. None of these choices of forecast is justified adequately.
The recommendations in the SELS are based on the LEP's prediction of jobs growth; the SELS is neither independent nor robust evidence. The LEP's SEP claims to be supported by the SELS even though the SEP pre-dates the final version of the SELS by 7 months. Such circular arguments are fatally flawed.
The SA makes it clear that the policy to create a new Sub-Regional Employment Site is dependent on the claimed economic benefits. Such claimed benefits are highly speculative. Site selection ignores key constraints such as Green Belt. The SA is unsound and proposed policies are not justified.
The further information we have provided in this focused consultation response adds weight to our previous submissions that the proposed local plan is unsound and it policies are not justified. In particular, it adds to our previous submissions that proposed policies DS16, DS8, DS9, DS19, EC1 and EC3 are unsound and unjustified; the remedies remain as we have previously submitted.
