I write to support the overall shape of the New Local Plan Revised Development Strategy (RDS), certainly compared to the original Plan, although with some reservations, in particular about its overall scale. I very much support the absence of development on the North Leamington Green Belt around Milverton and Blackdown.
I am pleased that the Council has recognised that the Exceptional Circumstances to develop the Green Belt to the North of Leamington do not exist and that as a consequence the risks of the Local Plan being found unsound at public enquiry are reduced. It is vital to preserve the limited green space between Leamington and Kenilworth, otherwise there is a real risk that Leamington and Warwick will merge with the West Midlands conurbation.
The Green Belt in this area meets the 5 key roles of Green Belt and is an excellent and well used cultural and exercise related resource. It would be worth referencing the Joint Green Belt Review 2009 which confirmed the high value of this stretch of Green Belt and is key evidence, more clearly in the Plan document. Development in Kenilworth, Baginton and Lillington may already take land from this essential Green Belt and further development on it would not be sustainable. It must not be permitted.
But I am also opposed to any encroachment into other Green Belt designated land in the District if it can possibly be avoided and believe a further review of some assumptions and principles could make this unnecessary. Certainly if it goes ahead the Council should seek to designate additional Green Belt land of the same size or greater than the Green Belt being developed - for example in the Asps area for the reasons highlighted in 4.3.8
My reservations and suggestions for further review are:
1. Windfalls
There is a large increase between the original and the revised Plans in the number of units being added through windfalls within existing planning boundaries, reducing the units required on new land by 1500 or almost 20% (the change was very clear in the public presentation). This huge revision suggests that the assumptions made for windfall or infill developments coming forward during the Plan period of slightly under 200 units per year (page 13 table 2) - there were 600 in the last year alone - may be significantly understated. 50 additional units a year would remove a further 750 from the newbuild total, roughly equivalent to the proposed greenbelt expansion. The assumption should be carefully reviewed.
2. Brownfield sites
The assumption here also looks modest.
Does the Plan include any assumption here or elsewhere about development of the old Potterton site and possibly greyhound track land alongside the Avon in Warwick ? Only phase 1 has been completed and filled (with difficulty - see below).
Has the recreation ground alongside the river, which is linked to the Edmonscote sports track been considered as suitable underutilised open space ?
Given shop vacancy rates and forecast trends, has sufficient allowance been made for conversions to residential in shopping areas, especially if major projects such as Chandos Street were now assumed to be available for high density accommodation ?
3. Building Densities
It is not clear if the new planning framework will specifically encourage higher density developments eg 4-8 storey townhouses/apartments within existing planning boundaries and in particular close to public transport services. It certainly appears not for newbuild proposals (5.1.3) but presumably this could also be adjusted in the new homes criteria at least in part. This would both be in line with the character of central Leamington and Warwick and take further pressure off the need to build on agricultural land. This option should be given further consideration.
4. Impact on Agriculture
It is not clear from the RDS what the impact would be on agricultural production and whether this has been considered in any judgements about possible alternatives, such as a higher density strategy outlined in point 3.
5. Building Quality and Mix
The criteria set out in 5.14 are sensible as far as they go. If there is any scope in the Plan for specifying higher standards of architecture (innovation, variety, local character etc) and of minimum living/garden space requirements I would strongly support those additions. Such criteria would help developers - and planners - avoid the costs and embarrassment of high vacancy rates on newbuild. The best recent example of this locally is probably the unattractive, rabbit-hutch sized first phase development on the old Potterton site. How the Plan might specify or aim to influence such desirable criteria should be considered.
6. Southern Green Park
It is possible that mitigation methods may need to be employed in the Southern areas to reduce pollution and congestion but the work needed to do this would be less than for development in the North. For instance putting the country park in the South next to the existing houses, with new housing beyond it, would make the green-park more accessible and if possible larger. It could be crossed by cycle-ways and would act as a green-lung to reduce air pollution.
7. Transport
The cycling plans look convincing. However the enhanced public transport outlined in the RDS seems unambitious and sketchy. Frequency of links should be at least as good as the current G1 and G2 services (every 8-9 minutes) with evening and weekend improvements throughout the District, if congestion is to be convincingly minimised. More detail is required in the Plan demonstrating how services will attract sufficent use to achieve this (coverage, frequency etc).
Two further points might be usefully touched on as part of a wider discussion of transport needs for a growing District:
- planned improvements at the slightly out-of area Gaydon interchange with the M40 will already be in place to assist flows to the south of Leamington (5.1.15)
- how will bus services (new and existing) connect to Railway stations and what is expected in the way of improved rail connections across the District (eg frequency to Coventry, a Kenilworth station) in order to reduce overall road use, pollution and congestion.
Subject to these reservations I broadly support the revised strategy and would make the following points:
8. A Joint Strategic Housing Needs Analysis is currently being performed with Coventry City Council. If this review identifies that it is necessary to increase the number of houses above those currently proposed, as I hope it wil not, I believe that there is sufficient non Green Belt land to accommodate this additional development.
9. The RDS has a fair distribution of new housing across the District. 16% of the new houses will be in the Green Belt North of Leamington, at Thickthorn and Lillington. (However see the fourth paragraph of this letter and point 1 above). 15% of the proposed development will be in Warwickshire Villages.
10. Given that the RDS will no doubt require some building on new land, even after possible adjustments arising from points 1-3 and 8, the proposal that most of the new development is located close to where employment opportunities already exist (e.g. industrial parks to the South of Leamington & Warwick) is logical. It provides an opportunity for people to live close to their place of work, reducing or eliminating commuting for many people, reducing pollution & improving quality of life. Furthermore there is ample space to build to the south of Leamington as the next nearest town is Banbury.
11. Focusing development in the South, in one broad area, ensures adequate public services can be provided and developed to meet the needs of the new population. These services can be designed to meet the exact needs of that new population and planned within easy walking and cycling distance, minimising traffic congestion. If development were to be more spread across the district public services would have to be developed in an inferior and unacceptable "make-do-and-mend" fashion which would provide poorer levels of service to both existing and new residents in those areas.
12. The RDS provides for improvement to the road network South of Leamington to relieve the existing congestion and to cater for the new development. The transport assessment clearly shows that development in the North would generate more traffic congestion in the district as it would have forced people to travel south to employment land, shopping (e.g. supermarkets) and the M40. Loss of vital Green Belt recreation land would also have resulted in more people travelling by car for recreation.
Less overall development outside the present limits - and particularly within the Green Belt - should be the main objective.