I wish to object to the New Local Plan on the grounds that it is (still) unsound.

Specifically the issues that concern me are, and that I have raised previously in one form or another:

1. The overall Housing Need Forecast of 12,900 homes is exaggerated.

It is a forecast based on projections and assumptions, not on evidence. Fewer than 6,000 new homes would meet both natural growth and any likely reduction in household size.

The Plan period of 18 years, 2011-29, is longer than the 15 years required by the NPPF. The Office of National Statistics' itself advises against extrapolating them beyond 2021.

There is no need to provide in full now for what only may happen in the late 2020s, or never, the consequence of which is the allocation now of huge greenfield sites that may never be needed.

2. The loss of Greenfield land is unsustainable.

The greenfield land that is planned to be destroyed is important both environmentally and agriculturally.

3. The Transport Strategy is ineffective and unsustainable

The proposed large-scale use of greenfield sites, outside the urban area and at suburban densities, would make the new housing estates car-dependent. Peak hour congestion would increase from its already unacceptable level, to the detriment of all road users, the urban environment, and town centre economies.

The transport strategy is incomplete and inconclusive. It would be irresponsible to approve the Plan at this stage without understanding its full implications for traffic and transport.

4. Impacts on Air Quality and on Health have not been satisfactorily assessed.

Existing poor air quality areas in the town centres will continue to suffer dangerous levels of pollution, and the suggestion that this will in time be eliminated by changes in technology is, as the air quality report itself states, dubious.


I also support the Warwick Society's representations over the unsoundness of the plan.