Object

Revised Development Strategy

Representation ID: 54740

Received: 25/07/2013

Respondent: Justin Richards

Representation Summary:

The Warwick District Local Plan is predicated upon a perceived need for an additional 12,300 houses in the area. This number is not proven, and forecasting to 2029 in the light of changes in social and economic conditions over the past 15 year period - or indeed any 15 year period in post-war history - is at best optimistic and almost certainly foolhardy.

A more realistic forecast from the Office of National Statistics which examines the nearer term predicts a far lower housing need, one which could be supplied from existing brownfield sites and the normal planning process.

Why does the Plan not use the government / ONS predictions which given that its relative timescale and resources for forecasting must make it more accurate?

Full text:

I am writing to voice my concerns about the proposed Local Plan for Warwick which I feel will adversely affect the town and surrounding area providing little benefit and making the environment less pleasant, less safe, and less healthy. I have copied in my District Councillors, who I hope will note my comments and represent them as appropriate. I would be grateful if they could confirm this, or let me know if they are unwilling or unable to represent my views with their reasons.
I have also copied in my MP Chris White, to whom I am grateful for already voicing similar concerns about the Local plan.
As well as my concerns, I have highlighted questions to which I would like a reply.
First, I should state that I understand the disadvantages of not having an agreed Local Plan. But I believe it is fundamental that having the wrong plan is far worse than not having a plan at all. It seems to me that the proposed plan is indeed wrong for Warwick - socially, economically, and environmentally.

Housing
The Warwick District Local Plan is predicated upon a perceived need for an additional 12,300 houses in the area. This number is not proven, and forecasting to 2029 in the light of changes in social and economic conditions over the past 15 year period - or indeed any 15 year period in post-war history - is at best optimistic and almost certainly foolhardy. A more realistic forecast from the Office of National Statistics which examines the nearer term predicts a far lower housing need, one which could be supplied from existing brownfield sites and the normal planning process.
QUESTION: Why does the Plan not use the government / ONS predictions which given that its relative timescale and resources for forecasting must make it more accurate?
Given this false premise as a starting point, the Plan proposes building almost exclusively on Greenfield sites to the south of Warwick, so as to avoid encroaching on land that (by historical accident) has been designated Greenbelt. This Greenfield land is just as valuable to the character and environment of Warwick district, town, and country and should be afforded equal protection. Any reasonable Plan would consider Greenbelt and Greenfield within the county as equivalent, and make the best case for the best use of the most appropriate land accordingly.
The approach to and aspects of Warwick and Leamington from the south contribute enormously to the general perception of the towns and their rural setting is important to continued tourism, as well as the quality of life in the area.
The result will be a clustering of houses in an area with no immediate access to the employment they should serve. Warwick's employment rate is such that it is apparent that 'spare' jobs on this scale are not available. The Plan's own predictions for the availability of employment sites being redesignated for housing makes it clear that new employment in the area is not foreseen.
Therefore, the proposed developments south of Warwick must be to serve as commuter areas. Traffic is unlikely to be moving to the south, given the nature of the Stratford-Upon-Avon Plan which more than caters for new housing North of Stratford/South of Warwick.
QUESTION: Why is the Stratford plan not referenced in the Warwick Plan. If the Warwick Plan has been developed in isolation, as it seems, then the housing requirements it claims will surely be accommodated by the Stratford proposals which further invalidates the figures quoted.

Infrastructure
The Plan addresses only in the vaguest terms how the local infrastructure will cope with the additional 18% of population planned. The most basic mathematics suggests that in order to sustain the development, we should have 18% spare capacity in our infrastructure - that is without yet taking into account the additional housing in the Stratford Plan that will also draw on Warwick's resources and infrastructure in particular for Health facilities. While development would appear to be conditional upon it funding additional infrastructure it does not seem from the Plan that this funding will be sufficient.
QUESTION: Which departments of Warwick Hospital have over 18% spare capacity currently? Which departments are already operating at full capacity (or more)? Is additional capacity needed for the NHS, education, water supply and treatment, or other infrastructure? If so, where will funding for this actually have to come from?

Traffic
The main infrastructure points addressed by the Plan all relate to traffic. This is hardly surprising as the proposed developments will be car-dependent and provide accommodation largely for out-of-area workers. Local transport will therefore increase by at least 18% and probably more. Most of this will be in the form of cars, most of them travelling through Warwick.
The Plan proposes various road changes, none of which are designed to take traffic out of the town of Warwick, but rather attempt to allow the town to cope with greater traffic capacity. Without addressing the main choke-points of the two Avon bridges, and in particular Castle Bridge, these measures will not work. Increased traffic from the new developments will certainly increase air pollution, which is already at an unacceptably high level, as well as increasing the traffic in areas close to major schools. In particular, traffic will be increased significantly along a widened Banbury Road outside Warwick School at a point where there is no pedestrian crossing and where residents have already been informed that the road is too dangerous for a crossing patrol to operate.
QUESTION: Has a Health Impact assessment been carried out with regard to air pollution, and/or the likely effect on road safety especially for schoolchildren? If so, please can you forward me a copy or tell me where to access it. If not, why not?

Local Economy
Warwick town is dependent upon tourism and many of the businesses in the town - including all retail trade - depends upon visitors being able to get into Warwick, park, and get out again. If this becomes a chore, those businesses, and the town as a whole, will suffer as casual visitors simply go elsewhere for shopping and entertainment. Adding to the levels of through traffic will obviously hasten this process.
QUESTION: What proportion of the traffic in Warwick is already through-travelling? I did see a figure from a council survey (not sure which council, I'm afraid, District or County) that suggested that already over 70% of vehicles in the town are travelling through. Is this correct? What will the percentage be when the proposed developments are complete? If there is no data predicting this figure, why not?

Environment
The additional traffic through Warwick will have a detrimental effect on the environment as a whole, and on the physical town itself. As well as a negative impact on conservation areas, listed buildings and other sites of historical interest will suffer from the poor air quality, traffic noise, vibration, and the proposed changes to historic junctions at attractive points of historical interest such as the top of Mill Street.
QUESTION: What assessment has been made of the impact of increased traffic on key buildings, and in particular Castle Bridge. Please can you tell me where I can access the Engineer's / Surveyor's report that must have been completed to ensure that Castle Bridge can actually cope with the increased usage? There seems to be no mention of it, or any other similar assessments, in the Plan.

National Planning Policy Framework
The National Planning Policy Framework requires that proposed developments be sustainable with regards to the environment, the economy, and socially. The Warwick Plan does not meet any of these requirements. It will be detrimental to the environment; it does not serve the current or ONS-predicted economy; it is socially unacceptable.


I have attempted to be as objective as possible in my comments above, but would like to finish on a personal note. My work is not geographically dependent and I - together with my family - live in Warwick because we choose to live in Warwick. It is a convenient, accessible, beautiful, friendly place to live in a delightful rural setting. I am sure that we are not alone in this and that a significant proportion of the local population has made a similar choice. While we are here we obviously contribute to the community in many ways. Warwick is a place where people with a choice want to live.
But if the Plan does through in its current form, then it seems to me that many of the reasons that we had for choosing to live in Warwick will disappear. How many people in similar positions to us will also disappear, it is obviously hard to predict. But there is a real danger that the proposed developments will make Warwick a place where people with a choice do not want to live.