Q-V3.1: Do you agree that the Vision and Strategic Objectives are appropriate?
I believe the vision and strategic objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy (unjustified) bias towards development of the greenbelt. The reasoning for this is that the greenbelt in the local area has a vital importance in preventing urban sprawl (especially creep sprawl towards Coventry) and keeping land permanently open. The protection of greenbelt should be given higher priority.
Stratford on Avon is the cultural capital of South Warwickshire. Sustainability is vital as you say. For development to be sustainable please could I suggfest that you first consider a). Make sure Stratford becomes a World heritage site. Create a proper identity for the town as the global centre of Shakespeare's world. b). Remove traffic from central Stratfotrd by constructing tunnel south to north. Pedestrianise the bridge. c). When you have done that, then you will be in a postiion to consider additional housing/hotel needs d). The infrastrucutre is already defying sustainability criteria. Traffic is choking the town. even in winter. e). Try thinking big: put infrastructure first: i.e. the tunnel, and then prepare your growth plans f). If you need the example of a town which has done this: try Duesseldorf in Nordrhein Westafalen g). Net zero causes additional complication which should be left out at this stage.
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I believe that the Vision and Strategic Objectives should specifically state that avoiding development on greenbelt land will be prioritised at all stages of the plan development. This is not currently the situation with a heavy, and unjustified, bias towards development in the greenbelt. The reason I have for this is that the greenbelt in local area has a vital importance in preventing urban sprawl, especially as all areas are creeping sprawl towards each other, and keeping land permanently open. The protection of greenbelt should be given higher priority.
The process is flawed. Strategic Objectives 4 and 5 strive for health, wellbeing and environmental protection but all of the proposed growth options involve Green Belt development. Other options should have been put forward to ensure Strategic Options 4 and 5 can be better met.
Objectives 4 and 5 have the laudable aims of striving for health, wellbeing and environmental protection. However, all proposed growth options are based around green belt development. And this directly goes against these objectives. As such, the proposals are seriously flawed and actually significantly endanger health and wellbeing!
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The 'vision' seems to be realised at the expense of existing greenbelt land and offers a Hobson's choice where all versions of the proposed plan include development of the same greenbelt areas. If you offer people a choice where this is actually no choice you are not really consulting with them at all. As such Strategic objectives 4 and 5 are in direct conflict to the wishes of local people to preserve existing greenbelt land as a precious and scarce resource. Genuinely alternative options that did not include development of the greenbelt areas should have been on offer.
It's hard to argue with the vision and objectives but the consultation proposals undermine Strategic Objectives 4 and 5. These objectives are to support health and well-being and protect the environment. The South Warwickshire Green Belt is an amazing asset for supporting these objectives. Yet all five spatial growth options propose putting major development in the Green Belt. No options are put forward which avoid Green Belt development, despite these being explored in spatial growth workshops. This is contrary to the December announcement by the Secretary of State for Levelling Up, Housing and Communities which recognised the important contribution that Green Belt land makes to the character of an area and said that where constraints like this exist, local authorities will not be expected to meet the stated figure for housing need. In view of this, I feel that options which seek to minimise Green Belt development should be put forward. This would then reinforce the aims of Strategic Objectives 4 and 5.
These are too detailed, over-specific and planning-biased jargon. “A great place to live, work and visit” sums up what we really want. The five 'principles' are actually a list of ten such things – pairs of something and something – so it lacks further clarity. So just say: Resilient to climate change; Beautiful; Healthy; Well-connected; Biodiverse – this would be a much simpler list. What about ‘Prosperous’ – do we not seek that too? If we do, then surely that should be a sixth 'principle'.
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They are hypothetical and idealistic. They do not take into account the lived reality of residents living in these areas. Statistics, data and modelling can only take you so far. Poorly worded, complicated consultation documents can only take you so far. Going into communities and truly understanding their strengths, assets and weaknesses would lead to a better, more realistic and acceptable plan. If you do consultation the way you've always done it, you'll get the results you've always got. Which means angry residents opposed to development being imposed on them. This doesn't mean no development and capitulating to NIMBYism. But it does mean truly listening to communities and understanding what their lived reality is. For example, looking at the bus route modelling is incredibly old fashioned. I know councils want people to use buses but the lived reality is that once an hour is not good enough. I wanted to go from my village to Stratford on the bus. I could leave around 10am and it would take about 40 minutes rather than 25 in a car. Assuming that's an acceptable delay I could only return leaving at 2pm or 6pm. So I could spend 3 hours or 7 hours there. So not, in fact in reality once an hour and with a massive difference in how long I could spend there. So of course I got in my car instead. And my village is one that appears on your modelling to have an acceptable bus service. The lived reality is completely different.
Whilst the strategic objectives appear sound, all options presented presume development that is contrary to these objectives (e.g. developing on the greenbelt). It seems that the process is flawed if the options presented immediately contradict the objectives of the processes.
Vision and Strategic Objectives should state explicitly that there should be no development in the Greenbelt.
Objectives 4 and 5 are not met by any of the growth options which ALL propose development on the green belt. Striving for health, well being and environmental protection is not being achieved if Green Belt development is permitted. Other options should have been put forward.
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There seems to be nowhere in the plans which references the need for land to be retained for agriculture. In times of crop shortages should we not be considering the need for retaining agricultural land to be a priority more than ever.
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CPRE Warwickshire believes that the Plan Plan Period should not attempt to plan as far ahead as 2050. The detailed report on Housing and Employment Need submitted with our responses to the consultation questions sets out why planning so far ahead should be replaced by a shorter period. CPRE considers a plan period between 15-20 years would be appropriate in line with other local plans and the NPPF requirements. This would reduce the need to allocate green field sites (Including potentially Green Belt sites) now for needs which will not arise within a reasonable timescale. It will also allow monitoring of the delivery of windfall sites from which a major element of new housing comes in Warwick and Stratford Districts, and thus to ensure that countryside is not lost to development. CPRE opposes planning through the SWLP to meet claimed unmet housing need from other planning authority areas. Attached to the report from our consultant are reports commissioned by CPRE West Midlands Region (CPRE WM) on the housing requirement calculations prepared for the Birmingham Plan Review (Nov 2022) and the earlier Black Country Plan Reg 18 publication (2021) and submitted to those aquthorities. As set out in those appraisals, the claimed levels of unmet need in Birmingham and the Black Country are much higher than current data suggested, and they may not arise atr all, Any figures for unmet need in the City of Coventry results from miscalculations of its population which the 2021 Census has confirmed. Legislation before Parliament (the LUR Bill) is expected to remove the 'duty to cooperate'. If this ceases to apply, there will be much less requirement on local planning authorities, such as those in the SWLP, to accept housing from other authorities, particularly where it requires the removal of Green Belt. The Vision and Objectives do not as drafted refer to key concerns of wide public interest: 1. landscape and countryside, 2. the protection of Green Belt and 3. protection of ecological sites. They include the aim to address biodiversity and environmental resilience, but not show an objective of ensuring development does not impact on ecological sites. This lack of reference to constraints should be corrected. National planning policy does recognise them: see NPPF Para 11 (b)(ii), read with its footnote 7. This lists a range of constraints which can justify not meeting the 'objectively assessed need' figure for new housing. It needs to include these. CPRE supports the tenor of the five over-arching principles but would warn that the scle of development proposed in some of the growth options could undermine them.
I believe that the Vision and Strategic Objectives should specifically state that: 'avoiding development on greenbelt land will be prioritised at all stages of the plan development'. This is not currently the situation with a heavy (unjustified) bias towards development in the greenbelt. Our reasoning for this is that the greenbelt in the local area has a vital importance in keeping land permanently open so protecting the environmental and cultural landscape, and preventing urban sprawl (especially creeping sprawl towards Coventry). Protection of the Green Belt will also assist in urban regeneration by encouraging the recycling of derelict and other urban land. In our view the protection of greenbelt should be given higher priority.
The vision & strategic objectives do not specify preventing building on greenbelt land and that this will be prioritised at all stages of the development of the plan. This is not included in the current proposal with a unjustified and heavy bias towards development in the greenbelt. 'Protecting what already exists' is a headline statement in the plan, but it is merely that. It is not backed up by preventing building on greenbelt land. Greenbelt in the local area is of vital importance in protecting urban sprawl, and destroying South Warwickshire's rural areas. Protection of greenbelt MUST be prioritised.
Strategic Objectives 4 and 5 aim for health, wellbeing as ev=nviromental protection yet all the proposed options presume Green Belt development . To ensure Strategic Objectives 4 and 5 can be better met, other options should have been put forward
HLM consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and HLM consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. 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.
The vision and strategic objectives are idealistic. There is no detail on how these are to be achieved. For instance, “ensuring new development does not cause a net increase in carbon emissions” is highly unrealistic even if there is significant change in new housing policy. How would this be achieved through the whole supply chain? Steel and concrete are carbon intense materials, trucks will be needed to deliver building materials, trees and green land will be destroyed to make way for housing. Even attempts to make the houses sustainable such as the production of heat pumps, creates carbon in the supply chain as well as the fall-out from mining for the components. Creating new developments causes significant carbon emissions whether we like it or not. Of course there are ways to minimise this but to suggest development will be carbon neutral is green washing even with proposed use of off-setting schemes which are often not effective. Comments such as “providing infrastructure in the right place at the right time” and “design of developments to…cater for the needs of all users and which respect the setting of many settlements” sounds good but is not followed through in the rest of the plans. To respect current settlements there would be no talk of relaxing current green belt rules or overriding current neighbourhood plans, and there would be emphasis on ensuring the infrastructure is present or developed to support the planned growth in communities. At present there is no obvious plan/funding to provide infrastructure and this seems left to private developers who have a poor track record in providing such facilities and may not have the correct information regarding what is actually needed. “A healthy, safe…Warwickshire – enabling everyone to enjoy safe and healthy lifestyles and a good quality of life” will not be possible if there are not enough school places/GP surgeries, increased congestion and pollution on our roads and no substantial green spaces left. The plan to achieve a net increase in biodiversity across South Warwichshire is at odds with the extensive plans for development and current strategy to relax green belt rules. We are extremely concerned that the Plan doesn’t include the 20% biodiversity net gain that the Warwickshire Wildlife Trust advocated for, that the Green Infrastructure study is now 10 years old, that your growth and new settlement locations don’t consider local biodiversity and river habitats and you don’t go far enough in tackling the climate emergency. So whilst superficially the vision and objectives look good we find them to be unrealistic and disingenuous, without proper backing in the rest of the plans.
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This plan is I’ll conceived and will ruin our landscape. Warwickshire has become a building site. Especially in Bidfors on Avon where it has doubled in size in the last 10 years.
Richborough Estates consider that the proposed Vision is appropriate in general terms. However, the proposed Vision makes reference to meeting unmet need from neighbouring authorities, and Richborough Estates consider it would be more appropriate to reference meeting unmet need from the wider Housing Market Areas. 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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