Local Plan - Preferred Options; Proposal to develop on Greenbelt land north of Leamington

I wish to register my objection to the proposal, within the Preferred Options document, to develop Greenbelt land north of Leamington. I believe it is possible to object on many grounds, but I will focus on just two.

Population projection and housing need
I attended the Community Forum discussion about this proposal held at Trinity School on June 14. During the discussion, Bill Hunt accepted that all previous population projections made since the Second World War had been wrong. They had all been under-estimates. I believe the projections you have used as the basis for this current exercise are also wrong. Only this time they are almost definitely an over-estimate. You have used as the baseline a period in the first decade of the current century, which was marked by an unusually high period of sustained economic growth, and by levels of migration, boosted well above the average by both the growth in the economy and the accession of a number of less economically developed countries to the European Union.
None of us can state with certainty what population growth will be in our district through to 2029. But I would suggest we make predictions from a more representative, and therefore more realistic, baseline. We should model forward projections on average annual growth over, say, the last 20 or 25 years. That would flatten out the upward distortion caused by taking years only from within the previous decade. Then I believe we would have a more realistic indicator of predicted housing need. I do not believe it will be as high as the level from which the proposed local plan starts. It is crucial to get the underlying assumptions right first.
Compliance with the National Planning Policy Framework?
I have carefully read the NPPF, and assessed the approach and strategy of the Preferred Options document against it. I believe the proposal to develop Greenbelt land north of Leamington is inconsistent with the framework and principles set out in the NPPF.
Several of the 12 'Core Planning Principles' are relevant to this argument:
Principle 1. Planning should "empower local people to shape their surroundings."
Principle 5. Planning should, "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them."
Principle 7. Planning should, "contribute to conserving and enhancing the natural environment."
According to the NPPF, you should only promote development in the Greenbelt if 'very special circumstances' can be demonstrated. Dave Barber, your Development Policy Manager, also stated at the Trinity School meeting that, "plans have to be evidence-based." I do not believe you have demonstrated the evidence that supports any 'special circumstances' that could justify the inclusion of Greenbelt land north of Leamington for development.
The only principle I can find in the Preferred Options document for including this land for development is that the Council has taken the view that it wishes to "distribute development across the district." That is a planning 'policy' you have asserted but one which I believe does not stand up against the Planning Principles outlined in the NPPF.
The NPPF makes it clear that the purpose of Greenbelt - and why it wishes to see it protected - is to prevent 'urban sprawl'. But the Preferred Options document states quite clearly that the Council has taken a policy decision to promote development "on the edge" of existing urban areas. I think that is a clear inconsistency between the Council's approach, and that required by the NPPF.
A 'very special circumstance' might be established as a result of carrying out a Greenbelt assessment. I have studied your assessment. I cannot find the 'evidence base' that Dave Barber said has to be there. The Greenbelt study simply asserts that the land north of Leamington has been 'identified' as "potentially suitable" for development, and that the land owner is willing to make it available. That simply doesn't stack up as evidence to support 'very exceptional circumstances.'
Your Preferred Options document examines the notion of 'very special circumstances.' It states, "Exceptional circumstances can include the need to accommodate housing and employment growth to meet the needs of a community where there are insufficient and available sites outside the greenbelt." (my italics). I do not believe you have demonstrated any such circumstances. Potential development land has been identified within 'white land' south of Leamington - but it has not been included as a development option in your proposal.
There seem to be two arguments for this. Firstly, you wish to distribute development around the district. But, as I have argued above, that cannot be sustained as a planning principle. Secondly, you claim that larger development could not be achieved in that location because of the difficulties it would present to construction. This is an implausible argument. Development is proposed in phases, not all at once. Larger scale development in the 'white land' area could be achieved on a phased basis. So your own evidence suggests - contrary to what you are proposing - that there are sufficient and available sites outside the Greenbelt (assuming, for argument, that you continue to proceed on the projected overall needs estimate.)
Conclusion
I believe the population and housing need projections on which the Preferred Options document rest are contestable. I would urge a thorough reassessment before proceeding to the next stage of this process.
Whatever level of need ultimately is used as the basis for housing development plans, I do not believe that the Preferred Options paper comes anywhere near establishing the 'very special circumstances' that must be demonstrated before you can proceed with development of Greenbelt land such as that north of Leamington. Without that case being made, you should now exclude these sites from the proposal.
I suspect that, during this consultation, you will hear very clear views from residents about your proposal to develop on Greenbelt land north of Leamington. I urge you therefore to adhere to NPPF planning principle #1, namely that you "empower local people to shape their surroundings."