Object

Representation ID: 55375

Received: 12/08/2013

Respondent: Mr Stuart Oldham

Strategy seeks to concentrate the majority of an excessive amount of growth into one particular small part of the District i.e. urban fringe areas around the south west of Leamington. Shoehorning this amount of growth into such a location would result in unsustainable over development with all its associated problems including traffic congestion, pollution and overloaded local infrastructure and services, and which cannot be adequately mitigated.

It would further increase the existing unbalanced pattern of development across the District between the 'urbanised south' (20%) and 'rural north' (80%) and as such, cannot be justified, certainly not on the grounds of seeking to protect existing Green Belt boundaries.

The 2012 Preferred Options level and locations of growth, whilst not perfect, comprises a reasonably robust, sustainable and balanced basis for future development for the District. Within this document, the Council identified the advantages to locating some development in the Green Belt to the north of Leamington and all four options considered for housing locations, (para. 7.38, Table 3) have significant allocations in this part of the District.

Regrettably and misguidedly, the RDS now marks a significant step backwards compared to the 2012 proposals. Any planning benefits arising from the non development of the relatively small parts of the Green Belt north of Leamington are outweighed by the major planning disbenefits of over development to the south of the town, resulting in a net reduction in planning and environmental benefits across the whole District.

The RDS does not constitute a basis for a 'sound' Local Plan as defined by the NPPF para 182.

Since the PO consultation the Council has radically revised its proposals for the broad location of new development. It has switched major housing allocations away from Green Belt land to the north of Leamington and concentrated most housing developments on locations to the south of Warwick, Leamington and Whitnash, outside of the Green Belt.
The Council claims that this is due to the consultation responses opposing Green Belt development, but also as a result of so-called 'new information' on the ability of the land to the south of Warwick / Leamington / Whitnash, and brownfield land, to accommodate new development.

It seems clear that the Council has bowed to the well articulated and forceful objections of the North Leamington NIMBY lobby, with the 'sanctity' of the Green Belt providing a convenient 'escape clause' for both parties, but this does not make for sound planning, in fact just the opposite!

It is important to note that Chapter 9 of the NPPF makes it clear that the Green Belt, which covers the northern 80% of the District, does not represent an insuperable barrier to development. According to the Council 'exceptional circumstances' can include the need to accommodate housing and employment growth to meet the needs of a community where there are insufficient suitable and available sites outside of the Green Belt. The Preferred Options take on board the National guidance in its Green Belt policy (Section 16), which supports the allocation of housing and employment development on Green Belt land with associated boundary adjustments. The Council identified advantages to locating development to the north of Leamington and also highlight some of the negative consequences of a large amount of development to the south of Warwick/ Leamington/Whitnash. These are a key part of the Council's own case for justifying their 2012 Preferred Options and for rejecting what are now their 2013 RDS proposals!

Moreover, it is clear that locally the RDS proposals would: greatly exacerbate existing traffic congestion not just in Leamington but also in Warwick, a town of national historic and cultural importance, both south and north of the river; degrade environmental amenity, including air quality; increase atmospheric pollution; place unsustainable pressure on local services and infrastructure.

That all of this amounts to over development is clear from the fact that the Council feels the need to attempt to put in place various 'mitigation measures', notably relating to transport and traffic management via the County Council.


The RDS proposal also conflicts with the environmental principles of the Council's Local Plan Strategy (RDS Appendix 1, para.3.5) relating to key elements of Sustainable Development: 'Distributing development across the District. Avoiding coalescence. Ensuring new development is based on the principles of Sustainable Garden Towns, Suburbs and Villages. Protecting biodiversity, high quality landscapes, heritage assets and other areas of significance.' Thus it can be seen to be internally inconsistent in policy terms.

Many District residents have strong objections to the RDS proposals; the RDS can also be seen to fail to comply with the NPPF (para. 155).

In summary then I object to the RDS proposed broad locations of growth on the following grounds: The justification, based largely on protecting the Green Belt, for the significant changes from the 2012 Preferred Options, is inadequate. The Council itself made a good case for rejecting this strategy in making its case for the Preferred Options! They would result in an unbalanced and unsustainable pattern of development between the north and south of the District, and a net reduction in planning and environmental benefits compared to the 2012 Preferred Options. They would result in overdevelopment of urban fringe areas around the south west of Leamington, with consequential major adverse environmental and transportation impacts for both Leamington and Warwick that cannot be adequately mitigated. The proposals are clearly contrary to some of the Council's own key planning and environmental policies and principles, and also to para. 155 of the NPPF.