Scenario three

1. Warwick District has already asked for the views of the Warwick. Warwick did not approve the level of new building proposd in the old plan nor where it was proposed to build. Views have not changed.
2.If green field sites are included as well as brown field sites then there must be an assurance that brown field sites will be used first. There is an obvious reluctance to allow building on greenfield sites when other land is available.
3. Everyone acknowledges the need for affordable homes and welcomes the new blood it brings into the community. There is also a financial incentive to build such homes. Yet planners build 'unaffordable' homes in greater numbers to maximise profit. Is there a case, while there is a financial bonus on cheaper housing, to build a higher proportion of affordable homes than the current percentage?
4. Warwick district has suggested where homes might be built. Warwick seems to be subject to the highest level of development. It must not become the dumping ground for new houses. Might I suggest Kenilworth takes a bigger share.
5. Warwick has a unique character, so too do all the other surrounding towns and villages. With the scale of development in the third option each of these separate communities would begin to merge into an area of genteel urban sprawl. Green lungs round each community need to be preserved.
6. We were clearly told at the meeting that the government has an sgenda for growth. We were also told it would be unlikely that data could be produced that would support either option one or two. Where does that leave bottom up planning? It would seem that the only choice you have is to agree with the agenda for maximum growth. I was going to include the word 'sustainable' as well, but that does not seem to be appropriate judging by the level of growth Warwick District seems bent on pursuing.

We accept the need for growth but not at the expense of destroying or altering beyond recognition the town we all love. Listen to us and work with us.

Scenario Three offers the only realistic basis on which to address the coalition Government's shift in the emphasis of economic growth away from the public sector to the private sector in order to assist in redressing the problem of public finances and to provide the employment necessary to address current levels of unemployment.

Scenario Three is the only approach that is identified as meeting forecasts for the amount of development needed to provide for population and household growth (p17, 'Helping Shape the District').
Scenario Three is therefore the only scenario that offers an approach sufficiently rigorous to ensure that the Local Plan is eventually adopted.
Scenario Three provides by far the most benefits in response to the issues identified. Whilst the document also suggests that Scenario Three has the most potential to impact on demands for infrastructure, it also recognises that new development assist in providing improvements that can benefit existing communities as well as provide for new neighbourhoods.

As the three scenarios are not yet attributed evidence-based target figures for matters such as housing delivery we consider it appropriate to comment that any future targets should be based on a full, robust evidence base. Ambitious targets for growth should be derived from this evidence base, taking into account historic undersupply of affordable housing and consideration of the viability of development throughout the district. We recommend that the highest possible housing target be set, enabling higher volumes of affordable housing to be brought forward, with the aim of delivering sufficient high quality housing to meet need. As the 2007 SHMA indicates need for 1,019 affordable dwellings per annum, the suggested figure given at Option 3 for 800dpa is considered too low to meet even affordable housing need. The evidence should be brought up to date before any single option is taken forward, taking into account the backlog of housing need and projected growth across the Plan period.

Suggests the following points are included in future drafts of the Core Strategy:
1. Affordable housing should be given sufficient weight and status within the core strategy.
2. Links should be made between the core strategy and housing strategy.
3. There should be strong links between the core strategy and other local authority strategies, such as the community strategy community care plan, economic development strategy and transport plans, ensuring that affordable housing is given due prominence within a corporate approach.
4. Credible district wide and sub-district wide affordable housing targets should be set over the plan period.
5. Ensuring that site size thresholds for negotiating affordable housing from private developers are properly derived in the light of the local housing and land markets including viability issues. We would anticipate that the Council will consider and articulate the circumstances across the District which justify proposed site size thresholds as per relevant government guidance.
6. A local definition of affordable housing should be set encompassing intermediate, affordable rent and social rented housing, taking full account of local relationships between house prices and incomes.
7. A realistic approach towards brownfield sites to ensure that a sequential approach is not so rigidly applied so as to impede the delivery of affordable housing.
8. There should be proper targeting of individual sites for affordable housing, including identifying sites for 100% affordable housing sites throughout the district.
9. There should be a reasonable amount of flexibility regarding design and development control standards, densities etc. to assist in achieving affordable housing.
10. The provision of affordable housing is recognised per se as both a positive material planning consideration and a planning benefit.
11. A rural exceptions policy should genuinely enable schemes to be developed in the correct locations both within and on the edge of rural settlements and make allowance for cross-subsidy where viability
is challenging.
12. The provision of affordable housing should be viewed within the context of achieving balanced communities and within the wider social exclusion and housing plus agendas.
13. Recognition should be given to the advantages of working with HARPs and a suitably flexible approach should be adopted towards S106 agreements.
14. Indication of the Council's intention to adopt CIL alongside planning obligations contributions and the exemption of affordable housing developments from this, in line with Government advice.
15. Policies should be included that maximise the reuse of empty properties for affordable housing.
16. Housing demand factors should be taken into account. There is likely to be a continuing demand for family housing and this should be considered.
17. Regular monitoring of the progress in meeting affordable housing needs should take place. PPS3 discusses the requirements of Annual Monitoring Reports and sets out what the LPA should carry out on an annual basis. By referring to such indicators, the success or otherwise of the policies can be measurable against clearly defined targets, allowing measurements to be taken on an annual basis.

Scenario Three is the only approach that is identified as meeting forecasts for the amount of development needed to provide for population and household growth (p17, 'Helping Shape the District').
Scenario Three is therefore the only scenario that offers an approach sufficiently rigorous to ensure that the Local Plan is eventually adopted.
Scenario Three provides by far the most benefits in response to the issues identified. Whilst the document also suggests that Scenario Three has the most potential to impact on demands for infrastructure, it also recognises that new development assist in providing improvements that can benefit existing communities as well as provide for new neighbourhoods.

The Council should aim to satisfy its high growth option.

Prefer scenario 3.

There are currently limitations on housing and employment growth; and the district suffers from congestion on strategic routes into Leamington and Warwick. These are important considerations that must be thoroughly addressed through the level of growth to be identified in local plan.

In relation to the level of growth and the three options the Council presents, Gallagher Estates and A.C. Lloyd Ltd support option 3 (high level growth of about 800 homes and 5 hectares of employment land per year). To revitalise the economy and in particular deliver much needed affordable homes, significant infrastructure and community projects, then higher levels of growth will be
necessary.

It is important that the serious economic difficulties currently being experienced are taken into account. The Council will need to make bold decisions to encourage investment and provide the necessary support for businesses to survive and continue to grow. The Governments has set out its committment in it's Plan for Growth (March 2011) to ensuring the planning system does everything it can to promote growth. It is noted that the Coventry and Warwickshire LEP identified stronger economic performance for Warwick District than other parts of the region however there are still key issues which could affect economic recovery such as the relationship with housing growth and congestion on strategic routes into Leamington and Warwick.

Regrettably, scenario 3 totally ignores previous objections to the huge number of houses needed to accommodate such an unrealistic population increase. Indeed, when applied to the period of the Core Strategy, the figure would equate to over 16,000 new homes and well in excess of the proposals in the Core Strategy.

A tenet of the local plan, is a sustainable development strategy, with new development built so as not to threaten the existing high quality built and natural environments. 12,000 new houses will impact negatively on the natural environment because of the need to build on green field sites and the loss of the green space areas, which distinguish the towns of Kenilworth, Royal Leamington Spa, Warwick, Whitnash and other areas of the District, would be the consequence. Such large scale development would result in the bulk of new housing being located in close proximity to existing housing and create continuous urban sprawl.

The Town Council would therefore wish to support Scenario 1, with an expectation that the District Council would direct growth to brown field land, until such time as the District Council:
* Clearly identifies realistic population growth
* Provides an appraisal of housing and employment level requirements
* Identifies the infrastructure necessary to support growth
* Allocates development to sites which have the necessary infrastructure to support development and which have local support.

In every circumstance Scenario 3 should be rejected because it is based upon unrealistic population growth and Scenario 2 should not be contemplated, less the District Council demonstrate that the above requirements are met.

Within Scenario 1, the Council should explore all means to bring forward new homes which are affordable to Warwick residents rather than migrants from the West Midlands. The whole direction of the Local Plan should be to meet local needs.

It is clear that based upon analysis of the evidence base regarding household formation, housing need and the economic demand for new housing, that the level of development needed is at least at the upper end of the Options set out in the Local Plan consultation, if not higher when affordable housing need is factored in.

In this respect, delivery of housing at Option 1 and 2 levels would be significantly
below the level of household formation set out within the 2008 ONS statistics and even the Option 3 figure would be below the long term local needs for the Borough.

Importantly however, it is clear from the SHLAA that the district has the capacity to deliver higher levels of housing growth.

For this reason, WCC consider that it is the higher figure that should be planned for by WDC when assessing the appropriate level of housing to be provided within the district for the next 15 years and beyond.

WCC therefore support the adoption of the higher growth option (i.e. Scenario 3) set out in the Local Plan consultation.

The WCC owned site at Europa Way has significant potential to contribute towards meeting both the identified demand for housing and the acute housing need in the District.

The absence of any forecast of population growth and the reasons for it is a severe weakness of the draft, and makes invalid the assertion (page 17, para4) that scenario three would 'meet forecasts ... and projections ... based on population and household growth'. Rather, it seems to base its argument for maximum development on 'supporting the economy', overlooking the circularity of the argument.

While development should be led by other policy objectives, not be an end in itself, we consider that the level of housing development should be lower than that proposed in scenario 2. It should meet local needs for more housing and, most importantly, needs for affordable housing and housing for the elderly. It should not enable population migration from other local authorities' areas which makes the condition of Warwick District worse for its existing inhabitants

Suggests that growth may not be the appropriate objective for Warwick town centre, conservation, or change, are more significant. Are very concerned that Background Paper 11 (page 104, first three paras) focuses only on retailing and leisure as town centre activities. It omits mention of residential use and office employment, which are the two largest economic activities in Warwick town centre. It prejudges work that has not yet been started on the Town Centre Plan (AAP) in considering services to play the 'anchor function'. It is essential for both sustainability and community cohesion that the centre of the county town has a broader economic base than this, and that daytime retail activity is strengthened, not the 'evening economy'. This objective must be considered further alongside the town centre plan work, and must not constrain the outcome of that.

The objectives should have been debated and agreed before any scenarios were developed and analysed failure to do this is a major weakness of the draft.

Draft objectives 1 and 2 promote balance between economic growth and housing growth, as though each justifies the other when it is actually a circular argument. The argument for housing is unsupported in terms of level, tenure, type of location therefore without evidence the objective has no meaning.

Strongly support objective 4 on the sustainable siting of development and objective 7 on their location and design improving (not just maintaining) the built and natural environments, especially historic areas and buildings. Draws attention to the importance of green space in separating and maintaining the identity of Warwick from Leamington, Whitnash and Bishops Tachbrook. Has concern over the meaning of objective 10 which as worded suggests primacy is given to the needs of the economy rather than conservation. The objectives to improve social, transport and and service infrastructure are noted however it is suggested that achieving this and correcting present deficiencies is likely to be more difficult in the higher growth scenario, as the impact of high growth on the District's infrastructure would be greater than any additional funding resulting from it could resolve.

Of the three scenarios presented in the consultation document, it is considered that only the scale of development envisaged in Scenario 3 would begin to address the evidenced need for housing growth and development in the district. It is considered that Scenarios 1 and 2 are discordant features within the Consultation document, at odds with the Government‟s Plan for Growth and its „call to action on growth‟, and the thrust of up to date and emerging planning policy (PPS3, PPS4, NPPF).

It is pointed out that in the Plan for Growth and recent ministerial statements the Government is committed to reforming the planning system to ensure it does everything it can to support growth and rebuild the economy. Local authorities should be proactive in driving and supporting growth and identify the housing, business and other development needs of the area. Local authorities should also plan positively for new development and prepare local plans with sufficient flexibility to respond to rapid shifts in demand or other economic changes. The plan as presented in the consultation document would not acheive this.

Of the three scenarios presented in the consultation document, it is considered that only the scale of development envisaged in Scenario 3 would begin to address the evidenced need for housing growth and development in the district. It is considered that Scenarios 1 and 2 are discordant features within the Consultation document, at odds with the Government‟s Plan for Growth and its „call to action on growth‟, and the thrust of up to date and emerging planning policy (PPS3, PPS4, NPPF).

It is pointed out that in the Plan for Growth and recent ministerial statements the Government is committed to reforming the planning system to ensure it does everything it can to support growth and rebuild the economy. Local authorities should be proactive in driving and supporting growth and identify the housing, business and other development needs of the area. Local authorities should also plan positively for new development and prepare local plans with sufficient flexibility to respond to rapid shifts in demand or other economic changes. The plan as presented in the consultation document would not acheive this.

Of the three scenarios presented in the consultation document, it is considered that only the scale of development envisaged in Scenario 3 would begin to address the evidenced need for housing growth and development in the district. It is considered that Scenarios 1 and 2 are discordant features within the Consultation document, at odds with the Government‟s Plan for Growth and its „call to action on growth‟, and the thrust of up to date and emerging planning policy (PPS3, PPS4, NPPF).

It is pointed out that in the Plan for Growth and recent ministerial statements the Government is committed to reforming the planning system to ensure it does everything it can to support growth and rebuild the economy. Local authorities should be proactive in driving and supporting growth and identify the housing, business and other development needs of the area. Local authorities should also plan positively for new development and prepare local plans with sufficient flexibility to respond to rapid shifts in demand or other economic changes. The plan as presented in the consultation document would not acheive this.

Warwick District is ideally placed within the country, with excellent communication links to the rest of the Midlands and to the south east, and therefore should plan for the highest level of development which would be realistic, and would meet demand for new employment opportunities and crucially the demand for new housing development.

The City Council generally supports a medium level of growth as proposed by Option Two, as this is in line with the RSS Phase Two submission which includes a reasonable allowance for migration from Birmingham to Warwickshire.

Option one providing a localised need could result in an increase in housing need and pressure for growth in Birmingham beyond its capacity on brownfield sites.

Option three could lead to out-migration from the City

The evidence within the technical paper supports Scenario 3.

Object to scenarios 1 and 2 as they are not based on sound evidence.

The timescale of the Plan should be from 2013 to 2028, or possibly even 2013.

The Plan should take into account the influence of travel to work links with adjoining Districts, in particular, Coventry.

The only sound Scenario for Growth is Scenario 3. Scenario 1 is based on recent trends and could deliver no development. Scenario 2 is purely notional, being a mid-point between Scenarios 2 and 3. Therefore Scenario 3 is supported.

Taylor Wimpey are promoting land north of Milverton for a sustainable urban extension of 1,500 dwellings and key development principles have been drawn up to demonstrate that the site is deliverable.

The Scenarios for Growth should cover the period to 2028.

Scenario 3 meets population forecasts and provides for the amount of development required to support the local economy.

A higher level growth option is appropriate having regard to current population predictions and the need for the District to remain economically competitive.