Justification for Preferred Option

Public consultation is meaningless if the public's opinions are not taken into account in preferred options. The survey carried out by WDC was a partial one and therefore not to be relied upon for "mathematical" calculations. Preferred options in the NLP are akin to the options in the Regional strategy. The weight of public opinion during that round of "public consultation" was overwhelmingly opposed to proposals then; one could suppose it will be the same this time. Nothing has changed exceopt yet another round in this war of attrition against communities. Leave our area alone. It's developed enough!

Unless a large number of houses are designated for social housing and low cost schemes, the builders will simply build more expensive houses and the issue of cost will not b e addressed. We need also to take account of the fact that the housing market has collapsed and houses are not selling well. LOW COST HOUSING is what is needed.

The Council`s preferred option is for nearly the highest growth possible despite the majority wishing for the lowest growth possible. This option would also increase the pressure on the traffic infrastructure by 10- 13%, as aknowledged in Point 3.1.20 of the Draft Infrastructure Plan. The rationale is that if there are more houses there will be more jobs; there are plenty of houses up North but unemployment there is very high. Trying to attract capital to a region is ephemeral; it may work for a short time but there are no guarantees that it will stay, so changes on this scale are very risky.

There is a widely held perception that consultations have little effect on courses of action already decided by the "powers that be" and that they simply serve to flush out the opposition, to enable counter arguments to be developed. The "Preferred Options" document does little to change that perception. Whilst it is accepted that preferences expressed by the public are only one of several factors to be considered, many people will be dismayed to see a Preferred Option in excess of Scenario 2 when the majority of people who took part in an earlier recent consultation had favoured a much lower level of growth, as per Scenario 1.

There is little point in seeking the views of the public if those views will inevitably be trumped by dubious "regional employment forecasts".

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. See uploaded spreadsheet.

So the preferred option is the one that had least support from existing residents! I don't think many people when asked would say they wouldn't like to spend less when buying a house - so no surprise there - but I don't think building a load of houses is the answer. Unless you make the area so horrible that all the existing house prices will fall and the people who suffer are the people who at the moment enjoy living in a nice area. Is that the aim of the preferred option???

The majority of respondents (58%) chose the level of growth in Scenario 1, 4,500 new homes over the next 18 years. Over 4/5s of respondents chose either Scenario 1 (250 per year) or Scenario 2 (500 per year) yet the proposed level of growth (600 per year) exceeds even Scenario 2.

The commentary in this section fails to justify the decision to specify 600 homes pa. It simply cites evidence which shows that the majority of local people believe this figure to be too high.

The recently released population figures for Warwick District, taken from the 2011 census, are lower than the estimates for 2009/2010. This suggests that fewer houses will be required than the Preferred Options assume.

The infrastructure for Leamington/Warwick is already poor. The only roads between the two (Emscote Road and Myton Road) are already clogged with traffic. Building new houses on the edge of the district on the scale proposed will make matters far worse.

Why are you ignoring what 58% of people previously consulted have said about the level of growth on housing? Most people wanted the lower level of growth. What is the point in consultation if you ignore the outcome?

I object to the PO1 choice of homes/year from options stated by the Council as 250/500/800 because I do not accept that the Council must plan to build any new homes. I am not satisfied that there is valid evidence of demand for new homes other than from Developers with established land Options. I do not accept a consultation process which asks for comments on a choice of house numbers without the choice including zero.

he 2011 census suggests lower population figures than estimated for 2009/10 indicating a need for fewer houses

This suggests that fewer houses will be required than the Preferred Options assume.

This sort of number makes sense over that time period - inducements to first time buyers would help stimulate demand and help boost the economy as Australia have done so successfully. A bottom up approach (unlike the Spatial Strategy) makes more sense as then you only release new housing as it is needed

The evidence shown does not support the level of growth proposed. If the majority of local people want a lower level of growth and the evidence shows growth in the District to be lower than previously thought (i.e. Census) how can the proposed level be justified?

I believe that the figures for the need for 10,800 homes are false. There is plenty of land available for the actual quantity needed for the futre already held by developers.

scenario one is the only one which would allow the current towns to continue to act as a decent place to live with a vibrant heart.

Given the recent census results, the projected housing demand needs to be reassessed. A reduction in the proposed allocation will also support the results of previous consultation. Given an increased density of affordable housing development on brownfield and othere preferred sites, the achievement of these housing targets should be achievable.

I object to all of this mass building policy on the grounds that the problem was caused by mass immigration about which the electorate was never consulted. The so called benefits to the economy are at best dubious and the effect on the environment will be catastrophic.

I am against development of green belt land in principle. London's 'belt has more or less worked and been maintained. By contrast, Greater Manchester and Birmingham have seen a wholesale loss of town and city identity with the absorption of Stockport, Oldham or Wolverhampton etc. Warwick and Leamington have been allowed to coalesce as symbiotic twins and so to neither's benefit. Further development will lead to greater coalescence of the two towns and with neighbouring villages. The additional housing will put greater strain on the two town road systems which are already heavily congested.

In my view the projected housing numbers are based on a mathematical model, the premises of which are now completely out of date, given the present recession. I doubt myself whether Warwick, or any other part of the UK is going to see economic growth over the next 10 years which in any way would approach that of the last 10.
My suggestion is, therefore that WDC should withdraw this consultation and produce another plan based strictly on natural population growth, but limited to what new housing can be accommodated without encroaching on the Green Belt. WDC has often said that it wishes to preserve the character of the District. A necessary condition for that is that the Green Belt is maintained. I expect that my view will be shared by many others

Local Plan - Preferred Options; Proposal to develop on Greenbelt land north of Leamington

I wish to register my objection to the proposal, within the Preferred Options document, to develop Greenbelt land north of Leamington. I believe it is possible to object on many grounds, but I will focus on just two.

Population projection and housing need
I attended the Community Forum discussion about this proposal held at Trinity School on June 14. During the discussion, Bill Hunt accepted that all previous population projections made since the Second World War had been wrong. They had all been under-estimates. I believe the projections you have used as the basis for this current exercise are also wrong. Only this time they are almost definitely an over-estimate. You have used as the baseline a period in the first decade of the current century, which was marked by an unusually high period of sustained economic growth, and by levels of migration, boosted well above the average by both the growth in the economy and the accession of a number of less economically developed countries to the European Union.
None of us can state with certainty what population growth will be in our district through to 2029. But I would suggest we make predictions from a more representative, and therefore more realistic, baseline. We should model forward projections on average annual growth over, say, the last 20 or 25 years. That would flatten out the upward distortion caused by taking years only from within the previous decade. Then I believe we would have a more realistic indicator of predicted housing need. I do not believe it will be as high as the level from which the proposed local plan starts. It is crucial to get the underlying assumptions right first.
Compliance with the National Planning Policy Framework?
I have carefully read the NPPF, and assessed the approach and strategy of the Preferred Options document against it. I believe the proposal to develop Greenbelt land north of Leamington is inconsistent with the framework and principles set out in the NPPF.
Several of the 12 'Core Planning Principles' are relevant to this argument:
Principle 1. Planning should "empower local people to shape their surroundings."
Principle 5. Planning should, "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them."
Principle 7. Planning should, "contribute to conserving and enhancing the natural environment."
According to the NPPF, you should only promote development in the Greenbelt if 'very special circumstances' can be demonstrated. Dave Barber, your Development Policy Manager, also stated at the Trinity School meeting that, "plans have to be evidence-based." I do not believe you have demonstrated the evidence that supports any 'special circumstances' that could justify the inclusion of Greenbelt land north of Leamington for development.
The only principle I can find in the Preferred Options document for including this land for development is that the Council has taken the view that it wishes to "distribute development across the district." That is a planning 'policy' you have asserted but one which I believe does not stand up against the Planning Principles outlined in the NPPF.
The NPPF makes it clear that the purpose of Greenbelt - and why it wishes to see it protected - is to prevent 'urban sprawl'. But the Preferred Options document states quite clearly that the Council has taken a policy decision to promote development "on the edge" of existing urban areas. I think that is a clear inconsistency between the Council's approach, and that required by the NPPF.
A 'very special circumstance' might be established as a result of carrying out a Greenbelt assessment. I have studied your assessment. I cannot find the 'evidence base' that Dave Barber said has to be there. The Greenbelt study simply asserts that the land north of Leamington has been 'identified' as "potentially suitable" for development, and that the land owner is willing to make it available. That simply doesn't stack up as evidence to support 'very exceptional circumstances.'
Your Preferred Options document examines the notion of 'very special circumstances.' It states, "Exceptional circumstances can include the need to accommodate housing and employment growth to meet the needs of a community where there are insufficient and available sites outside the greenbelt." (my italics). I do not believe you have demonstrated any such circumstances. Potential development land has been identified within 'white land' south of Leamington - but it has not been included as a development option in your proposal.
There seem to be two arguments for this. Firstly, you wish to distribute development around the district. But, as I have argued above, that cannot be sustained as a planning principle. Secondly, you claim that larger development could not be achieved in that location because of the difficulties it would present to construction. This is an implausible argument. Development is proposed in phases, not all at once. Larger scale development in the 'white land' area could be achieved on a phased basis. So your own evidence suggests - contrary to what you are proposing - that there are sufficient and available sites outside the Greenbelt (assuming, for argument, that you continue to proceed on the projected overall needs estimate.)
Conclusion
I believe the population and housing need projections on which the Preferred Options document rest are contestable. I would urge a thorough reassessment before proceeding to the next stage of this process.
Whatever level of need ultimately is used as the basis for housing development plans, I do not believe that the Preferred Options paper comes anywhere near establishing the 'very special circumstances' that must be demonstrated before you can proceed with development of Greenbelt land such as that north of Leamington. Without that case being made, you should now exclude these sites from the proposal.
I suspect that, during this consultation, you will hear very clear views from residents about your proposal to develop on Greenbelt land north of Leamington. I urge you therefore to adhere to NPPF planning principle #1, namely that you "empower local people to shape their surroundings."