Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate?
Need from Coventry, Birmingham and the Black Country should be met firstly from brown field sites in those areas. In any event, this sentence is not part of a vision it is an administrative statement. The use of brown field sites would help to preserve the amenity of Warwickshire, which has already met considerable need from neighbouring urban areas.
Argument 8 The process is flawed. Strategic Objectives 4 and 5 strive for health, well-being and environmental protection yet al the proposed growth options presume greenbelt development. Other options should be put forward to ensure Strategic Objectives 4 and 5 can be better met
I do agree with the overall objectives on paper, but don't see how the plan to build on green belt land in any way meets them. Decimating open green spaces is directly the opposite of working towards zero carbon and protecting biodiversity, the opposite of supporting physical and mental health (walking in open spaces is one of the few cost-free and accessible ways ALL people can get this sort of exercise for wellbeing), and the opposite of supporting distinct town centres.
I do not agree with the objective to deliver more homes in the area - focus should be on better use of already developed land rather than building more greenbelt developments. It is clear that building on green field sites is a cheaper options for developers and easier from a local planning point of view but there are significant areas of brownfield land which should be developed to provide more affordable houses within the areas where people can work. This will ultimately benefit the local area by providing more affordable houses without the need to deliver extra infrastructure (rail roads and busses) and by not destroying the countryside with more developments that can only realistically be accessed by car drivers. Development of our towns should be the priority rather than joining up our villages with development, this is the only option that delivers a sustainable future.
A Vision should be bold and aspirational. Given the content and aims set out in the supporting information published, the Vision should not mince words, but be clear in stating that the South Warwickshire Local Plan (SWLP): "Will achieve net zero across the Local Plan area." That is a Vision. Anything less is a compromise. Simply referring to how development should "take every opportunity" represents a hesitant approach. It does not require the achievement of net zero but rather, it attempts to deal with climate change whilst increasing the scope for failing to actually do so. This is unfortunate, as it is clear that the SWLP is being prepared with the best intentions and that it does want to plan for positive change. Also, in reality, truly innovative and Visionary projects are already looking to go beyond net zero – whether through carbon sequestration or other methods. By the end of the plan period, simply achieving zero carbon could be seen as a missed opportunity. Across the country, there are a number of landowners and developers actively looking to take the lead in achieving and going beyond net zero. Landowners who are rooted in and who invest in their communities – with a focus on building beautifully, thinking in generational terms and providing long-lasting legacy development. One example is the Forward Group and Alderley Holdings Trust which has set-out a long-term vision to create a thriving and sustainable community at Henley-in-Arden (see separate vision document). This is the way to achieve sustainable development and the SWLP should set out a Vision that seeks to not only provide for this, but to ensure that all development achieves something better, through truly sustainable development. Given this, there is a real opportunity for the SWLP to grasp the nettle and to set out a genuine Vision. The SWLP goes on to identify the potential for aspirational approaches aimed at achieving better development outcomes. The Vision needs to reflect this by stepping up and setting out a much bolder approach.
William Davis consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and William Davis consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. Furthermore, it is stated that unmet need ‘could’ be met, which should be revised to state that unmet needs ‘will’ be met where appropriate and agreed. Whilst Birmingham and the Black Country authorities are not neighbouring authorities of South Warwickshire, they do form part of the same Housing Market Area and therefore should not be excluded.
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Plan in some cases contradicts the goals. Therefore some of the goals are not adequately described and can be interpreted too broadly
I believe that there is inadequate emphasis on the need to preserve the heritage and nature of South Warwickshire. Its villages and countryside are renowned for their character and as a break from the spread of the industrialised West Midlands conurbation. Of course there will be change and some encroachment on the Green Belt, but it should be done as sensitively as possible. Entire new settlements with modern infrastructure would be preferable to damaging irreversibly the history and character of many of the existing settlements and communities
The development of the SWLP to date has clearly involved a huge amount of work. However there is a fundamental flaw in the process which has been amplified by the publication of the draft revised National Planning Policy Framework (December 2022). The current direction of Government policy is that Green Belt land should be protected and does not have to be released to meet housing need. SWLP Strategic Objectives 4 and 5 seek to promote health and environmental resilience, much of which we know can be gained from protecting and enhancing Green Belt land. This is evidenced by numerous comments from local people who use the Old Milverton footpaths for recreation and exercise (see Supporting Document A uploaded at S12). This is why Old Milverton & Blackdown Parish Council are so dismayed to see Green Belt development assumed in all five of the ‘spatial growth options’ here. Doing this is more than just being “blind” to whether proposed locations are in the green belt (Section S6, line 37). By offering no alternatives it suggests that the planning team has already assumed that it is necessary to remove land from the Green Belt. This is contradictory to national policy for three reasons: 1. The Government has asserted that local planning authorities are not expected to review the Green Belt to deliver housing. See letter from the Secretary of State for LUHC to MPs on 5.12.22. This is now reflected in the draft NPPF (paragraph 142). 2. It does not take into account the views of local communities. The Secretary of State said that local authorities would “work with their communities” to determine “how many homes can actually be built, taking into account what should be protected in each area - be that our precious Green Belt or national parks, the character or an area, or heritage assets.” See written statement from SS LUHC, 6.12.22. 3. It ignores the existing protections for Green Belt land as outlined in (new) paragraph 143 of the NPPF which states: “Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development... [including whether it] (a) makes as much use as possible of suitable brownfield sites and underutilised land; (b) optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and (c) has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground. As we will set out in the remainder of our response, this ‘full examination’ has not taken place and the result is that the consultation document presumes that there will be Green Belt development, even though: i) no Green Belt review has taken place and ii) options for non- Green Belt development have been explored in SWLP workshops yet no weight or visibility has been given to these in the consultation document. With regard to the SWLP plan process, this situation gives rise to some key questions: i) Why is there no option to comment on Section 6 (“A review of green belt boundaries”)? ii) What would the timetable be for a review of the Green Belt? The West Midlands Land Commission (2017, p63) has cautioned against reviews being done piecemeal, so it should be part of a joint exercise. The results would then need to be known before spatial growth options can be firmed up, yet current timescales indicate that the preferred option will be put out for consultation in just four months’ time (July 2023). iii) Even if such a review were to take place in time, the Green Belt around North Leamington fulfils all of the stated purposes. There are no exceptional circumstances to justify its removal as the Secretary of State has made clear that housing need figures do not take precedence. Please see an analysis of the value and contribution of the Green Belt in North Leamington (Supporting Document B uploaded at S12). One further point that we wish to make is that some of the SWLP work that has been undertaken has not been presented transparently, to take three examples: i) The Spatial Growth Strategy Workshops which you carried out in June and July 2022 and reported on in September 2022 each involved two exercises to decide the distribution of growth, one with Green Belt development permitted, and one with it not permitted. This means that there will have been numerous explorations of non-Green Belt development, none of which feature in the consultation document. There is a complete lack of visibility or weight given to non-Green Belt development. ii) The 54% figure cited in favour of Green Belt development is, at best, misleading. This is not a representative figure because the respondents to the first consultation were not a representative sample. The document also fails to mention that 45% of respondents were developers, landowners or businesses (35% developers and 10% landowners according to Consultation Statement January 2022, p275). This suggests that only a small proportion of other respondents were in favour of pursuing growth opportunities. This skew towards groups with a vested interest means that this statistic should not be used as the primary statistic setting the scene for Section 6. More importantly it should not be used in any way as a justification for pursuing this strategy. iii) There are numerous other commissioned desktop studies and reports which make up the technical documentation. These amount to some 2,250 pages and are incredibly dense but at the same time utilise generic tick box descriptors, lack local knowledge and make extrapolations from uncomprehensive and potentially inaccurate data. They could even be construed as manufacturing a case for justifying exceptional circumstances to develop the Green Belt. Such studies must not be allowed to be used as a justification for development in the Green Belt. In view of all the above, we feel that the premise of the consultation is flawed and that the current process should be halted while the background and options are revisited in light of the national policy direction on the Green Belt.
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The general direction of the strategic objectives are difficult to argue against because they are specified at a high level. There are inconsistencies in how the objectives are written, for example "a well-designed and beautiful South Warwickshire" then specifies how this might be achived. But "A resilient and Net Zero Carbon South Warwickshire" says nothing about carbon emissions will be reduced. Suggest that "Ensuring that new development does not cause a net increase in carbon emissions" contiues by adding "by embedding sustainable energy generation into all new developments".
Whilst all the above proposals are laudable, I have concerns for road access across and through town. Pollution levels are already too high due to idling traffic. When we first moved here in 2010 getting through the town had traffic but nothing on the scale we have today. One of the joys of Beehive Hill is the open vista, I cannot see how this could be improved upon and I doubt the wintering geese would want to see their. Whilst their has been great concern about HS2 ecological impact I would have to question how much habitat could be lost. I understand the need for new housing but I am unsure the town with its current infrastructure could embrace more, smaller developments maybe. The latest findings in the connection between car pollution and lung diseases gives me cause for concern. If guarantees can't be made to improve traffic through town then I cannot say yes to the proposals. You can't change the geography of the town.
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Vision We strongly disagree with the phrase “climate emergency” contained in the Vision statement. This is an emotive phrase and should not be used. “Climate change” is not and would be far more appropriate. Please remove this contentious phrase or amend to the Climate Change challenge. There is a real danger of exaggeration or adoption of a crisis management mentality which would not only scare people but produce poor decision making. Indeed, in some people’s minds the credibility of the whole document will be undermined as climate change predictions are based on many assumptions, making outcomes unpredictable. Having said this the actions suggested in the document to limit carbon emissions and improve the environment, as expressed in the document so far, appear reasonable.
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There is currently a failure to deliver infrastructure to make LMA work. In order to gain support, a clear path with must-deliverable objectives needs to be outlined.
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"South Warwickshire has a varying landscape and includes parts of 5 national landscape character areas, of which the Cotswold Area of Outstanding Natural Beauty is one, with 8% of the total area of South Warwickshire falling into this specific national landscape designation. Nearly a third of South Warwickshire is part of the West Midlands Green Belt, which is designed to prevent the unplanned expansion of urban areas." The entire area suggested between Weston & Hunningham is greenbelt land that I use daily
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The plan will not meet net zero carbon emissions due to increased traffic levels in the town itself and surrounding roads, that are not wide enough to cope especially during rush hour periods and Road works
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because I do not agree with building on green belt or reducing the green belt so it can be built on nor doing so through stealth via brown field sites. The vision for local plan states a group of generalistic statements which lead to agreeing by default later given what is stated further in this plan. An example of this is changing the character of small villages such as proposing 500 houses to be built in Wilmcote who have a railway station to offset housing shortage in Birmingham. This means running a coach and horses through green belt and small villages to meet targets in larger towns and cities.
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The environmental objectives should be stronger. All new housing should be built to Net Zero standards ("UK Net Zero Carbon Buildings Standard"), within reach of major public transport hubs, and with compulsory long distance cycle route access. New housing should not come at the cost of urban sprawl onto green fields and parkland. Low density new housing should not be built.