Support

Revised Development Strategy

Representation ID: 55074

Received: 28/07/2013

Respondent: Dr Tim Robbins

Representation Summary:

All previous objections to development in this area must be carried forward and expect them to be noted in consultation summary

Full text:

write in response to the consultation period currently in operation with respect to the "Local Plan Revised Development Strategy."

I firstly write to support the removal of planned development on greenbelt land to the North of Milverton. Development here would be totally unacceptable and in direct contravention of the NPPF. The fact that Warwick District Council has now developed both the "Core Strategy" and "Local Plan Revised Development Strategy" without development on this greenbelt land effectively proves no exceptional circumstances exist.

To U-turn to a plan which does involve development on the North Leamington Greenbelt would be unacceptable because there would be far too great a risk of coalescence with Kenilworth and Coventry. There is a very well used public footpath running through the greenbelt land there providing an excellent leisure and exercise resource for the local people of all ages and free of cost. Trying to incorporate this into development there would not be successful and would result in a loss of that resource. Furthermore the transport assessment the council has produced/published shows that development in this area would result in greater congestion and therefore pollution than development in the South. There has quite clearly been immense local opposition in the previous consultation to development on this greenbelt land and all the points raised opposing development there that were raised in the previous consultation must be carried forward to this consultation, I will not be able to list them all here but expect them to be noted in the summary of consultation responses to this consultation, to not do this would be a lack of joined-up thinking by the council. In short development on the North Leamington Greenbelt would be in direct contravention to the NPPF in terms of not meeting the exceptional circumstances requirement, would be unsustainable for the future of the district and would require an entire new consultation process which the district does not have time to do because of the serious delays that have already been incurred in getting this plan out and the subsequent knock of damaging effects of not having a plan.

I realise that a Joint Strategic Housing Need Assessment has occurred or is on-going, it is essential that the council put together a strong argument as to why Warwick District cannot accommodate any of Coventry's housing needs. However if they fail to do this it is imperative that any additional development is not located on the land to the North of Leamington - indeed there are further development opportunities on non-greenbelt land and on brownfield land that must be brought to bear first. For example the removal of development from "The Asps" is bizarre. The argument is that development would be seen from the castle and therefore would change the historic setting of the castle. Castles were traditionally built on hills in order to look over the towns they were charged with, if there was to be a heritage loss by building on land that can be seen from the castle/can see the castle then development around almost every castle in the entire country would be, according to these principles, incorrect! Indeed there have been many developments in view of the castle/viewing the castle in recent times. This argument is null and void, the heritage value is within the castle itself and it's immediate surroundings (which the Asps does not qualify as). Should you want to preserve a view of the castle from the Asps then this could easily be incorporated by use of a linear park. The Asps is just one example of many non-greenbelt sites that should be built on before greenbelt land.

Furthermore should more housing be needed, a proper, formal assessment of a new village to the South of the district has not been completed, there is ample space to build one of these and this assessment must be completed before development is considered on greenbelt land. This assessment should be started from the position of "Is it possible to build a new village in the South of the district?"

Finally the council has identified a huge number of potential gypsy sites, the requirements needed to make each site suitable to be selected are very similar to the requirements needed to make sites suitable for housing developments. Therefore all proposed gypsy sites that do not accommodate gypsys could accommodate housing development before greenbelt land. This particularly includes land to the West of Warwick Racecourse that is conspicuous in it's absence from planned development - whilst some of this site floods the majority of it does not, and can therefore be built on. The allocation of the site as a potential gypsy site includes the "racecourse spur," unless the council has been disingenuous in it's inclusion of the site as a potential gypsy site then this spur should thus not create a barrier to development, finally there is already road access to this site and it has been offered up for development by it's owners.

There are therefore many options for development of housing on land that is not greenbelt land to the North of Leamington and these must be built on before development on the greenbelt. Were the plan to develop on the North Leamington Greenbelt be re-ignited then so would the immense local opposition and the plan would be fought right through to the inspectorate and judicial review beyond that, based on the sound knowledge that the plan would be the wrong plan for the future of the district.

There are positive aspects to the current plan, which is why it should remain in place; by placing development in the South then accommodation can be near existing employment facilities and the M40. Concerns raised by people across the county about pollution and congestion clearly demonstrate that development should be in the South. The transport assessment shows that development in the South reduces pollution compared to building in the North. This goes not only for the current plan, but also should any more development be needed - this too should be located in the South. If development was not located in the South then people would have to travel to supermarkets, employment land and to the motorway and there is no convincing guarantees whatsoever that this could be mitigated.

A further advantage to the development in the South is that public services can be targeted to that particular area, with new schools etc, that are purpose built to meet the needs of that population, spreading development over the district with bits here and there would mean a make-do-and-mend approach would need to be taken, with worse outcomes for the current population, future population and the education of the next generation.

At meetings regarding the Local Plan Revised Development Strategy there have been arguments that the plan is 'not fair.' These and other simply emotional arguments should be ignored, the plan is fair - there remain plans for development in North Leamington, including on the greenbelt eg at Thichthorn and Lillington and significant development in villages including Milverton . Emotional arguments should be ignored and politics should not intervene in planning the future development of our district. Planning should be based on planning principles. Indeed the reason that these emotional arguments have arisen, I believe is not due to the plan itself, but the way it has been presented to residents by the council. For example development in direct-contravention to the NPPF should never have been proposed in the North Leamington Greenbelt in the first place, doing this has caused the South to see "a change" this should never have happened, furthermore there has been no attempts to demonstrate the attractive nature of development to the South. For instance better and bigger provision of schools, pollution mediation methods, or the advantages of the Community Infrastructure Levy. Perhaps the greatest failing is the failure to properly use the proposed country park to the South of the Town to mitigate development and improve that area for local residents, rather than build it on the outside of the town so far fewer people can benefit from it. I will now discuss this in greater detail:.








Proposed Country Park to South of Town

The proposed country park demonstrated in the image on the left is totally in the wrong place. It has I believe been put there not for planning reasons, but for political reasons. It has been put there to appease the tiny minority of people who live in Bishop's Tachbrook. Interestingly the county councillor for Bishop's Tachbrook is the district councillor who seems to be in charge of the local plan.
I agree that a park in this area is absolutely essential to development in this area, but rather than being placed on the outside of the new development it should be placed bordering the existing housing. This would mitigate the quality of life impact of the new development for people living in existing housing. It would also act as a green lung and therefore help to mitigate the pollution impact of new development. In effect locating it next to existing development it could mitigate the concerns of the many existing local residents have and what will no doubt be their responses to this consultation. This should be the council's response to their concerns.
In it's current form this park is in direct contravention to the NPPF - it is not sustainable as the plan states that is would create a permanent boundary to the South of the town. This is unsustainable. Development cannot happen to the North of the town due to risk of coalesnce with the major urban areas of both Kenilworth and Coventry. However the next major urban area to the South is Banbury many miles away. Therefore in the future the town must develop Southwards and this park prevents that and is unsustainable because it fails the NPPF's economic test of sustainability - "ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation;" it contravenes it's social test for sustainability "meet the needs of present and future generations;" and it fails the environmental test by not maximally "minimis(ing) waste and pollution" as a park adjacent to existing development would act as a green lung and reduce pollution.
The park also contravenes the NPPF because building this park adjacent to existing development and not where currently planned would contribute to "improving the conditions in which people live, work, travel and take leisure" as this land would be more accessible to more people and would thus be more of a "creative exercise in finding ways to enhance and improve the places in which people live their lives." By having walking and cycleways across this park this would encourage sustainable activity again meeting the NPPF's demand to "actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling."
Using this park in this way would also take account of point 66 in the NPPF "Applicants will be expected to work closely with those directly affected by their proposals to evolve designs that take account of the views of the community. Proposals that can demonstrate this in developing the design nof the new development should be looked on more favourably."
It would also meet paragraph 69 "safe and accessible developments, containing clear and legible pedestrian routes, and high quality public space, which encourage the active and continual use of public areas" as this land would be more accessible and better used.
It would further meet paragraph 73 "Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities." because a park between existing and future development would be more accessible to local people.
Therefore in conclusion to this section there are very many reasons why this park should not be located in it's current unsustainable location as a Trojan horse to force future unsustainable development on the Northern Greenbelt, risking the future of this district out of a seemingly politically motivated desire to provide a quite excessive level of protection to Bishop's Tachbrook, which is still quite a way from the proposed development anyway. Many people feel very strongly on this issue and it would certainly make representation to the inspectorate regarding this element of the plan and indeed it would be a shame for the plan to fail on something which could be a great opportunity but is currently being mis-used. A much better location for the country park is shown on the right: