PO1: Preferred Level of Growth

I do not believe that this level of housing is sustainable.

Too high alevel of growth-lack of clear justification

Responses to The Council's own Local Plan consultation exercise "Helping Shape the District" showed that the majority of respondents to the general questionnaire, and sample household survey, considered that Scenario 1 would be best for the District. However, the preferred option put forward is somewhere between Scenarios 2 and 3 and therefore does not reflect the views expressed by the majority of respondents and is not representative of what the people of Warwick District want.

There is not sufficient justification for this level of growth.

This level of growth seems at odds in the long term with the ageing demographic of the population.
There is no guarantee that economic growth will follow population growth.

no

If local people have already indicated that the prefered level of growth is that descibed in scenario 1 it would seem un democratic to go against there wishes. i.e. why ask people what they think and the propose something which is not wanted for the reasons described.

The Joint Parish Council continues to object to the Preferred Option level of growth. Previous consultation OVERWHELMINGLY supported lower levels of growth and the JPC does not find adequate evidence to support the chosen level. The JPC believes that growth should only be linked to predicted demand from the current population, closely matching housing and employment needs and should not be "encouraging" inward migration into the district.
In particular growth directed towards villages must take account of recent and currently proposed developments.
Agricultural land should wherever possible be protected and growth must not drive mineral demands from high quality land - other mineral options must be explored.

The 2011 census shows Warick population rising by 8% since the 2001 census. The rate of growth is approx 0.8% per annum which means that by 2029 the population will be increased by about 19,800. At an average dwelling occupation of 2.38 people per house (source Warwick Observatory) about 8300 homes will be needed by 2030. This is an annual requirement of about 450 homes per year. It is my opinion that your figures over represent the need for housing.

I wholeheartedly object. The level of growth is far too high. As mentioned in other comments this is completely against the results from previous surveys / consultations. Are we all wasting our breath?????

There is little justification for this level of growth in the documents produced by WDC and it appears that this may have been chosen to enable the plan to be accepted by Central Planning rather than to reflect the District or Local wishes.
The level of growth of housing should be directly linked to the growth of employment. If houses through the District are built without extra jobs being available locally for the occupants then this will cause additional requirements for transport and inevitably produce more pollution.
As the level of growth of the British economy is currently being downgraded it seems reasonable that the level of growth of housing should not be a fixed number but related to the economy. If this is not possible then a revision of the numbers in the plan should be undertaken at regular intervals
The level of growth should take account of houses built from 2011 (and perhaps earlier) and that the growth - especially in the villages - should be phased over the years of the Local Plan

The population in Warwick increased by 12% over the past 10 years. 10,800 new homes represents a growth of 18%; far in excess of that seen in the last decade.

We do not agree that the proposed level of growth is realistic or justified by the statistics given.
In the initial consultation 'Helping shape the District'
Scenario 1 proposed 250 homes and 58% of respondents supported this, a further 28% supported 500 homes.
The plan has been based on unrealistic projections, made after a period of growth, which has led to a global recession and not made on local requirements.

I do not think the case of the growth I justified.

I doubt if this is enough.

The council's own consultation on levels of growth found the majority of respondents in favour of a lower level of growth but they have chosen a level of growth higher than the medium level of 500 houses per year - this shows that the council are ignoring the wishes of their residents/voters/tax payers and they should not be doing this. It also shows that the consultation was a waste of everyone's (residents' and council employees/councillors') time and money.

The SHLAA draws on data which is itself derived from uncertain and scientifically unquantifiable data. The rate of completion within the current plan has fallen well behind target and has caused infrastructure issues which have caused frustration and compromised safety. The failure to meet clear obligations by the developer at Chase Meadow is a good example. There can be no guarantee that this wouldn't happen again.

Local consultation has already indicated that people want lower growth and yet this is being ignored.
The growth rate we have already had is excessive and includes large numbers coming from Europe or other parts of the country who want to live or work in the area. Further development will only stimulate this and will not remedy local housing shortages.
Growth at this level is not sustainable and will destroy the character of Warwick.
This is not a good reason to despoil our countryside.

I don't believe that the need (level of growth) has been proven within the documents that have been used as evidence

I don't think there really is evidence of that much demand for privately owned rather than social housing

The New Local Plan - Preferred Option : Level of Growth - PO1

I am writing to register my objection to the development of site identified as East Milverton within the proposed Warwick District Council (WDC) Development May 2012.

Whilst acknowledging the need for additional housing during the period 2014-2029 and the overall approach; the Preferred option in its current form, (i) goes beyond identified housing need at the expense of the
Green Belt, (ii) ignores national planning policy guidelines for development of Green Belt, and (iii) does not recognise other development opportunities that are better suited to development and more consistent with WDC's own stated sustainable growth objectives and evidence base.

Objection 1: Housing requirement.
The New Local Plan (NLP) Preferred options May 2012 Page 19 (7.22) identifies a requirement for 6986 dwellings not including windfall sites over the period of the plan. In its current form the Local Plan indicates
it would deliver 8360 dwellings, equal to an over provision of 1370 (19.6%) dwellings.

Paragraph 47 of the NPPF requires local authorities to effectively assess the full needs for housing in the Housing Market Area (HMA). The District Council appears to have prepared a Strategic Housing Market Assessment (SHMA) that considers the needs of the District only. This is a fundamental flaw in the Council's approach, which could raise issues about the soundness of the plan. This needs to be rectified prior to producing the Submission version.
On this basis, we therefore neither support nor object to the proposed level of growth proposed in PO1 since the evidence is lacking.

We have been advised to write to you re New Objections to the Core Strategy Plan.

We wish to object to the expansion plan to build 2700 new homes in the south of Warwick (P04 Distribution for Sites for Housing: Location 2 and 3).

There is likely to be considerable job creation towards Coventry (PO3 Broad Location of Growth). Therefore several extra thousand people per day will want to drive through Warwick morning and evening. That would lock up the highly congested Myton Road, Banbury Road and Europa Way at peak times and also the road layout of historic Warwick. (PO14: Transport).

The suggested improvement to the junction to the end of Myton Road and Banbury Road is redundant. The bottle neck of the narrow historic Avon bridge, constrained road layout and traffic calming in the Town centre, means such provision would not ease the current backlog along Myton Road at peak times. (PO14: Transport).

The most disturbing consequence of the proposed development of sites 2 and 3 is the danger to Public Health as a result of exposure to dangerously high Nitrogen Dioxide (N02) levels. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. In 2012, air quality remains in breach of these regulations, and will become toxically high with the increased traffic volume resulting from the Local Plan preferred options. Please see weblink: http://aqma.defra.gov.uk/action-plans/WDC%20AQAP%202008.pdf. (PO12 Climate Change; PO14 Transport).

Current infrastructure including town centre rail stations, schools, GP surgeries, sewage, water, drainage are at capacity with the current population, and will not sustain the proposed increased numbers within the Myton proposed sites 2 and 3. (PO2 Community Infrastructure levy).

Warwick District population has increased by 12% since 2000, which is approximately 2x the rate of increase for Warwickshire; 2x the national average increase, and over 3x the increase for West Midlands. (PO1 Level of Growth).

Warwick has therefore already been subject to significant recent Urban Fringe development and population expansion, a large proportion of which is in South Warwick where the majority of further development is now proposed. (PO1 Level of Growth).

We wish to object specifically about the development zone 2 to the west of Europa Way. This area had been identified as an area of restraint at the time of planning the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa, to prevent the two towns becoming one urban sprawl.
Furthermore, the land West of Europa Way is rich agricultural land which has been under the careful stewardship of the Oken Trust and Henry VIII Trust. There are also wide green hedges providing habitats for many species including woodpeckers, buzzards, bats, foxes, the occasional deer, as well as newts, hedgehogs etc. (PO11 Historic environment, PO15 Green Infrastructure).

Development on the area of restraint threatens the local houses with flooding. At present, during heavy rain, the run off is slowed by the pasture and crops. It backs up by the Malins and is relieved into the Myton School playing fields. Property in Myton Crescent was flooded when development was carried out on the Trinity School site. Developing the Myton side of the site would threaten all of the houses south of Myton Road . (PO18 Flooding and Water).

We object to the fact that the area of restraint is one of the first to be developed under the proposals, and should with immediate effect be designated as the last site to be developed so as to protect this area until a viable alternative is found.

The further urban fringe development of Warwick is unsustainable with respect to saturated infrastructure, constrained historic town layout, and the existing Public Health danger that exists today as a consequence of high traffic volume.

Therefore further development should be concentrated in areas where road improvement is possible, air quality is not already in breach of regulation, access to A46, M40 and rail links are direct so commuting traffic is not funneled through Warwick's congested urban centre.

We also urge Warwick District council to consider the overwhelming number of objections received from Warwick residents at the last consultation 2 years ago.

In the present economic climate I believe the growth forecasts are overestimated.Even with the increase in population and job opportunities a lower growth estimate would be more realistic.

NPPF paragraph 47 requires local plans to meet their full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with other NPPF policy (para. 47). Paragraph 159 clarifies that this should be done through a Strategic Housing Market Assessment, working with neighbouring authorities where housing market areas cross administrative boundaries.
Housing Need has been assessed through the Council's Housing Market Assessment and the Council recognises that, due to timing, it has not been possible to prepare a sub-regional Housing Market Assessment. The preferred option approach of bringing forward a Local Plan to deliver this level of growth and not delaying the local plan to prepare a housing market assessment across administrative boundaries is supported by this Council. We understand that this approach is also likely to be supported by Inspectors.
From past experience I would also add that there can be significant difficulties in defining housing market areas, which are far from exclusive in this area of the Country, and producing assessments to satisfy each local authority's requirements.
We note that the assumed scale of out migration from the conurbation has been reduced, however, the Preferred Option places no reliance on Solihull to meet any of Warwick's assessed need and this is supported by Solihull Council. The Solihull Draft Local Plan has reached an advanced stage in its progress to submission and any such reliance would by contrary to sub-regional strategies, the Solihull Draft Local Plan Spatial Strategy and could only be met through green belt release in rural areas of the Borough.

The methodology behind the 10,800 total figure (8,300 on allocated sites) is at-best highly subjective and at worst flawed. It is presented in a very definitive and matter-of-fact way, but is not wholly reliable for the following reasons:

* It is one interpretation of evidence that could be interpreted in many ways and give many possible results.
* It uses base data from the 2001 Census which is then extrapolated using very generic 'trends' that loses accuracy and reliability. The available 2011 data does not support this level of population growth or housing demand.
* There are errors in the calculations.

This level of growth is between the medium and high scenarios set out in the 'Helping Shape the District' consultation. This is despite 58% of respondents preferring a 'low' level of growth of 250 units per annum as seen in Scenario 1.

The average of 555 homes per year on allocated sites (8,300 in the plan period) includes approximately 1,300 that exist on already-consented schemes. Therefore assuming this level of growth is required only 7,000 homes actually need to be built on the as-yet unidentified sites (that forms the basis of the preferred options). Therefore 1,300 homes would be proposed on more marginal / sensitive sites unnecessarily.

I think this amount is too high. Is this supported by the latest figures from the Census to justify that level of growth. Making an area grow at a faster pace doesn't necessarily make it better (look at Rugby Borough for example)

The projections mentioned in the justification take no account of present trends and therefore exagerate the need for more homes, something nearer to option 1 is probably more realistic.

Data being used to make the decision for this number of new homes is out of date - confirmed by council representatives. The data is not in line with the current recession and likely reduction in demand for new homes.

Please see attachment in respect of Policy PO1 Preferred Level of Growth and paragraphs 5.6 to 5.23

POI: Preferred Level of Growth
The Council's Preferred Option is for the level of growth between 2011 and 2029 to be 10,800 dwellings at an annual average of 600 dwellings per annum. An objection is made to the level of growth in Policy POI and the justification for this as set out in paragraphs 5.6 to 5.23 for the reasons explained below.

The Council has identified a plan period only up to 2029, which seems to be 15 years from the anticipated year of adoption (April 2014 in paragraph 3.7). This reflects the guidance in the National Planning Policy Framework (The Framework), but it is noted that the time frame of the demographic and employment evidence base that the Council is relying refers to the period 2011 - 2031. It is likely therefore that the choice of an end date of 2029 will artificially restrain the levels of growth. It is considered therefore that the time period of the local plan should be extended to 2031to take account of the the Local Plan is based on 'adequate, up-to date and relevant evidence about the economic, social and environmental characteristics and prospect of the area (paragraph 158 of the Framework). It is possible that the adoption of the Local Plan would be delayed until after April 2014, and in any event the Local Plan does not demonstrate that it has taken account of longer terms requirements as required by the Framework.

By using the 2029 time period the Local Plan, using the Council Preferred Option could potentially under provide 1,200 dwellings and about 850 jobs.

Choice of Level of Growth
2.4 The Council's decision to choose the Option 1 level of growth 600 dwellings pa 2011- 2029 (lower than Option 2 - 700 dwellings pa) seems partly to be on the basis that the national economy is not performing as well as expected - paragraph 5.22. This is despite the Option 2 figure being more in line with the available evidence base (West Midlands Integrated Policy Model - Cambridge Econometrics July 2010) which reflects the fact that the local economy of Warwick District has and will be likely to continue to perform better than the West Midlands and national average- see the comments at paragraphs 8.2, 8.3 and 8.4 of the draft Local Plan. The Council's cautious aspirations in terms of housing and employment related growth in Section 5 of the draft Local Plan seem to be at variance with the positive comments about the local economy set out in Section 8 of the Preferred Option document. It is noted that paragraph 8.21 states that 'further work is needed to clarify; this figure (need for additional jobs) in relation to more up to date economic and demographic projections and to examine the impact of potential development at the Coventry and Warwickshire gateway site ... '. If this is the case for employment growth then it follows that the further demographic and economic modelling may result in a different housing requirement being identified. In this context the evidence base for the draft Local Plan fails to demonstrate how it has been positively prepared in the context of paragraph 182 of The Framework whereby the 'the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements ... ' and paragraph 158 of the Framework which states 'Each local planning authority should ensure that the Local Plan is based on adequate, up to date and relevant evidence about the economic, social and environmental characteristics and prospect of the area. Local Planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals '.

It is also suggested in paragraph 5.20 that the testing of the two options in the Sustainability Appraisal Framework (SAF) results in Option 1 being preferred. An examination of the SAF reveals that this is not the case. Firstly it is noted that the SAF May 2012 is an 'initial report' that is at the beginning of the process, that sits between the 'scoping report and the 'Sustainability Appraisal Report'. Secondly, it is noted that the SAF has been prepared by Warwick DC and not by an independent assessor.

The table below paragraph 3.7 of the SAF refers to two growth scenarios - trend based (600 homes p.a.) and employment growth based (700 homes p.a.). It is noted that both of these options score the same i.e. 2.5 in the Council's assessment. Appendix 3 of the SAF does not identify whether consideration of these 2 options is based upon an aggregated assessment of individual sites - and if so whether the sites used are the same or different. The SAF does not explain how the consideration of the four options (in the latter part of Appendix 3 and in Section 3.9 of the main Report) have been utilised for the purposes of defining the Preferred Option.

It is also important to note that the Sustainability Appraisal Scoping Report (March 2011) included at Appendix 4 a review of growth options. It is noted that Table 9 identified an annual average increase of 840 households in Warwick District for the period 2008 - 2033 based on CLG 2008-based Household Projections. The Council's own consultants, CQW /Cambridge Econometrics produced a study in 2010 which estimated the annual average increase in households at 800. In this context, the Council's report states at paragraph 5.1

"There is evidence that if existing trends in household growth and economic forecasts are continue, there will be a need to provide an annual average of around 800 new dwellings a year up until 2026. This level of new development broadly equates to the potential supply of land identified within the SHLAA. The Council are of the opinion that this should be the higher growth option .... "

There is no substantive basis to establish the rationale for rejecting a higher growth option of 800 dwellings per annum as proposed during the earlier consultation process. It appears that this option was not tested as part of the SAF process.

In short, it is considered that SAF is not a robust or sound basis for the purposes of identifying a Preferred Option for the Local Plan. It is not transparent. It is not possible to assess the implications of choosing different sites within an option. Consequently, it is considered that the draft Local Plan is not consistent with national policy in enabling the delivery of sustainable development in accordance with the policies in the Framework. Moreover, it is considered that the SAF does not meet the requirements of the EU Strategic Environmental Assessment Directive (European Directive 2001l42/EC) which requires that all plans and programmes are assessed in terms of their impact on the environment.

There is also no evidence base that the Council provides to support the contention in paragraph 5.23 that there is a 'lack of certainty, therefore, that a sufficient number of homes on strategic sites could delivered within the plan period to meet Option 2 '.

This implies, logically, that some strategic sites are more capable of delivery than others, and perhaps have a finite capacity within a specified time frame. However, no assessment is provided to support this contention. For example, the 16 criteria used in the SAF do not include reference to delivery within the plan period in whole or part.

On the basis that Option 1 and 2 score the same in the SAF, and that the Council has chosen the lower growth option (and seemingly ignored following the initial consultation stage, a further higher growth option 'Scenario 3' founded on a robust SQW/Cambridge Econometrics evidence base), we consider that the draft Local Plan fails to meet the objectively assessed requirements for population, housing and employment growth, utilising the Council's own evidence base.

For example, choosing Option 2 in preference to Option 1 would result in the draft Local Plan making provision for an additional 1800 dwellings, and 1800 jobs 2011 - 2029 (increasing to 3,200 dwellings and 3,000 jobs if the plan period is extended to 2031).

The Preferred Option does not therefore support building a strong competitive economy in the context of paragraph 21 of the Framework and does not meet the full objectively assessed needs for market and affordable housing as required by paragraph 47 of the Framework.