PO3: Broad Location of Growth

I am writing to object to the proposed sacrifice of greenbelt land in North Leamington.

I understand the need for more housing in the area and believe there is great demand for subsidized and affordable housing locally. However please do not sacrifice greenbelt land - it has been proved many times the benefit green space provides to the health and well-being of a community - destroying the availability of such land is in my view a crime against humanity.

There are no "exceptional circumstances" demonstrated by the council for building on greenbelt land. The council have identified available land east of the A452 and south of Heathcote which has not been included in the "Preferred Options" where there is better access to the M40 Motorway and where the infrastructure would more readily support development of this size and nature. Therefore to sacrifice greenbelt land in these circumstances I can only assume is a political decision and not one guided by the NPPF.

The properties built on the old Pottertons site have been up for sale for a very considerable time to not much avail, no one seems to want to buy them. There are many empty properties in need of renovation, would not the money for building the infrastructure to serve the new developments be better spent on updating and renovating existing buildings thus improving local environments?

Please reconsider the use of greenbelt land in the light of the above comments.

I read WDC's proposed plans for green belt development with dismay and incredulity and would like to add my objection to what will hopefully be a successful campaign to stop this damaging and costly ruination of our local area.

WDC have no democratic mandate to proceed with these plans. In response to a previous consultation nearly 60% of respondents opposed development in the Green Belt yet you ignore this and offer us only options on which massive level of destruction we would prefer.

Green belt is there for a reason, and previous WDC studies had identified areas of development that did not require this harmful removal of precious land.

Kenilworth cannot cope with 770 additional homes and 1000 + cars. It is gridlock during rush hour and most of the day up the Warwick Road. There is nothing in your plans to accomodate this extra traffic load on the local streets. Nor is there evidence of how the disruption, noise and pollution will be minimised or managed while the development is underway.

The quicker this ill conceived and unwanted plans are shelved the better. I wish WDC the worst of luck and will resist in every way I can.

Re. Local Plan Preferred Options
I wish to raise the following objections:
Use of Green Belt land generally
In order to use Green Belt land, you must demonstrate that there are exceptional circumstances that require its use. I understand that the demand for thousands of new houses has come from central government and would not, in the normal course of things, be something you would expect to be faced with. However, that in itself does not constitute exceptional circumstances. I would only consider it exceptional if every possible non-green belt area that has been highlighted for possible development had been included in the proposal, and yet there was still insufficient land without using the green belt. As I understand it, this is not the case and there is a considerable area to the south of the town east of the A452, which has not been used, despite being highlighted earlier. I understand that you wish to avoid large development in a particular area, but spreading it out doesn't diminish the size of the development overall.
Convenience does not equal exceptional
Spreading the development does not equal exceptional
Spreading the building contracts does not equal exceptional
I would therefore contend that you have failed to meet the required criteria for Green Belt use.

Milverton Gardens area specifically

* Traffic on Old Milverton Road
This is my main concern. Many children walk, run, scoot and cycle along old Milverton Road on their way to Brookhurst and Trinity Schools. They are forced to the very edge of the pavement by overgrown nettle-infested hedges, which are rarely cut back. With 810 extra houses just north of here, a conservative estimate puts an extra 200 cars on that stretch of road in rush hour. Every day I see children casually step off the pavement to get past others, without looking. This is not hysteria, this is fact: with that many extra cars, someone will be seriously hurt or killed. The result will be that more people from that side of the railway line will drive, putting yet more stress on the congested streets. If you do go ahead with this development, please: cut the hedges back regularly and look at installing railings along the stretch of road between St James Meadow Road and the cut-through.


* The effect on Old Milverton itself
This is a small close-knit community. With hundreds of extra cars going through it every day, new bridges and roads being built to accommodate the changes and a massive new estate on its doorstep, that will change forever. Yes, you have kept a gap, and yes, I am informed by the planning officer who was stationed at Tesco, the new road will go to the North of the village, rather than through it (as shown on the map) but the fact remains that it will become part of a commuter route and a much less attractive place to live. People will move and the traditions of the village, such as its annual show, will be lost.

Overall
You have flexibility built into your plan. You have 1370 "spare" houses and additional areas outside the green belt at your disposal. Please do the right thing, so that future generations can have the pleasure of a walk across the fields, as well as a safe walk to school.

My partner, Lee Hammond, and I have only just heard about the District Council's plans to develop on Green Belt Land North of Leamington as shown in their 2012 Preferred Options booklet.

We would like to register our objection to the new Proposed Development Plans. It would be unforgivable and irresponsible of planners to damage this area of North Leamington, when with a little effort and thought they could find other more appropriate sites such as Brown or White field sites. They owe it to the residents of Leamington Spa, Warwick,Kenilworth and all those who appreciate and enjoy the area.

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I am writing in support of the general principles outlined in the new Local Plan.

As owner of the Warwick Arms Hotel in Warwick High Street it is encouraging to see that a priority is "to protect existing visitor accommodation within or adjoining the Districts three town centres unless it can be demonstrated that the use is no longer viable or suitable "

I look forward to being contacted as part of the Visitor and Tourism Strategy Action Plan currently under preparation as mentioned under "other options". I am convinced that this will conclude that there is no "lack of adequate accommodation" in the District.

Furthermore I trust it will highlight the fact that many accommodation providers in the District,often in heritage buildings (essential to the town centre street scenes which attract tourists)need the same level of protection from edge of town Budget Hotels as the retailers referred to in PO3...."we will protect our existing retail uses in town centres and strongly resist any out of town centre proposals that may come forward.

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Submission made on behalf of the Hatton Parish Plan Steering Group.
Overall Strategy
The overriding principle of the National Planning Policy Framework (NPPF) is Sustainable Development. When the previous Core Strategy was being prepared, three sites at Hatton Green, which landowners had put forward for development, were dismissed because the general location was considered to be unsustainable. If the area was considered unsustainable then, how does it suddenly become sustainable and where is the evidence to support this change? Indeed, where is the evidence to suggest that housing spread across the district is the most sustainable form of development?
Table 7.2 show approximately 10% of new housing will be in villages, roughly half of which will be concentrated in five villages along the A4177/B4439 corridor - most of which lack the facilities to support sustainable development. Moreover, this will create a corridor of development that will seriously threaten the integrity of the Green Belt. The A4177 and B4439 are also dangerous roads with bad accident records. Potentially another 400 houses will obviously increase the danger, yet the Plan contains no infrastructure improvements to reduce the risks.
We therefore have serious misgivings about the strategic approach to rural areas.
Local Plan Policy PO4: Distribution of Sites for Housing
We object to the inclusion of Hatton as a Category 2 village. In a recent survey for the Parish Plan, 60% of respondents said they are opposed to more housing. We expect the natural reaction will be to dismiss this as NIMBYism, but there are several sound reasons why residents consider this designation to be inappropriate:
1. Hatton has already contributed more than its fair share of housing to the District, with numbers having increased six-fold in the last 20 years, from 140 to 845 units.
2. The 700 new houses at Hatton Park mean the parish now has two distinct settlements, plus a significant scatter of other houses. We now need time to assimilate the massive impact this change has had and develop a cohesive community.
3. Neither Hatton Park nor Hatton Green has the basic facilities needed to support sustainable growth. Hatton Park has a village hall, small general stores and a reasonable bus service, but all children have to travel to school by bus and there is no bus service to the nearest post office or doctors. Hatton Green has a primary school, but this is already over-subscribed and further expansion would only exacerbate the current traffic problems in the village. Otherwise there is a village hall, but only a skeleton bus service with timings that preclude travelling to work by bus. We do not consider these modest, dispersed facilities sufficient to justify designation as a Category 2 village. They certainly don't measure up to the statement in paragraph 7.34 that "a limited amount of development is directed to those villages with a good range of services and public transport to the towns".
4. If the 700 homes at Hatton Park, with their wide range of types and tenures, cannot meet local needs through natural turnover, then it is highly unlikely that 30-80 extra homes, spread over 15 years, will make any difference. Nor is it likely "to encourage new services" as envisaged in paragraph 7.35.
Notwithstanding the above, we recognise that communities cannot stand still and that further development will be required at some stage to sustain the two existing settlements. Indeed, responses to the Parish Questionnaire show that just over a quarter of residents would favour more starter homes, shared ownership or rented homes. Very few, however, would favour more of the larger homes. The issue is how best to satisfy the residents' views.
We do not believe designation as a Category 2 village, with its subsequent implications for the Green Belt, is the best solution.
Local Plan Policy PO16: Green Belt
The Parish Questionnaire shows virtually 80% of residents to be in favour of retaining the Green Belt as it is, though a quarter consider there could be some review of boundaries.
Paragraph 79 of the NPPF says "the essential characteristics of Green Belts are their openness and their permanence". Paragraph 83 goes on to say "Once established, Green Belt boundaries should only be altered in exceptional circumstances" and that authorities "should have regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period".
Taking these statements together, our interpretation is that Green Belts should be essentially permanent; their boundaries, once established (which is the case in Warwickshire), should only be reviewed in exceptional circumstances; and if boundaries are reviewed they should endure beyond the fifteen years of the Local Plan. We question whether the levels of housing being an proposed for Category 2 villages - an average of two to five a year spread over fifteen years - is sufficient to amount to 'exceptional circumstances'. (If all or most were to be built at once however, e.g. very close to our parish at Haseley Manor, then this might constitute exceptional circumstances, but this would almost certainly lead to pressures to release more land.) Because of this we are very concerned that, if village 'envelopes' are created within the Green Belt, the NPPF requires boundaries to be drawn to accommodate expansion beyond the fifteen year period of the current Plan. Notwithstanding the safeguarding provisions in paragraph 85 of the NPPF, we believe this would expose areas to the threat of premature development, which we know from past experience would be extremely difficult to resist.
We certainly believe that creating 'envelopes' for each of the five proposed Category 1 and 2 villages along the A4177/B4439 corridor would fundamentally threaten the integrity of the Green Belt.
In the case of Hatton, with its two very compact settlements, we believe the interests of its residents would best be served by leaving both villages 'washed over' by the Green Belt, leaving any future development to be dealt with as 'limited infilling' or 'limited affordable housing for community needs' in accordance with the NPPF paragraph 89.
Infrastructure
We are surprised that the Plan contains no proposals for improvements to the A4177 and B4439. Both of these roads are extremely dangerous, with the severity of accidents along the stretches at Hatton almost twice the county average (Warwickshire County Council Traffic Accident Statistics pers comm.). Both roads also carry traffic diverted from the M40 and M42 at times when there are incidents on either motorway.
With potentially up to 400 more houses proposed for the five Category 1 and 2 villages along this corridor, the accident risk can only increase and we believe the Local Plan should make provision for infrastructure improvements to minimise the risks.

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Introduction

The Warwickshire Branch of the Campaign to Protect Rural England (CPRE) is a charity registered No 1092486 with over 700 members in Warwickshire. CPRE is very concerned about many aspects of the New Local Plan Preferred Options agreed by the Council on 21st May 2012 and now published for consultation.

Firstly we give our response to the main Preferred Options. We then examine key issues on the Vision, projected growth, population growth assumptions, the Green Belt, and the proposals for employment.


The Preferred Options (PO1 to PO18)


PO1 Level of Growth

We strongly oppose the level of growth of 555 houses/year that PO1 proposes. The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and much of this is by windfall development within the urban areas.

The proposals to impose 100 houses on each of five villages would damage their rural character and unbalance their structure.


PO3 Broad Location of Growth

The proposal is 'growth across the District' including on Green Belt, and in villages. No direction of growth or focus on particular broad locations is proposed. This is contrary to the policy of previous Structure and Local Plans. Those plans protected Green Belt and identifed key locations while ensuring that urban land was re-used, and villages were only asked to accept limited new housing.

No clear reason for the change from past Local Plans has been offered. As those have been successful, the policies and patterns of development that they provided for should be maintained in the new Local Plan.
The extent of windfall development and use of brownfield land in Warwick and Leamington has been high for many years. There is no reason to depart from the practice of encouraging these forms of development.


PO4 Distribution of Sites for Housing

PO4 proposes a large number of greenfield housing sites which are currently Green Belt or greenfield. Most of these would not have been considered at all acceptable in past Local Plans, and we strong oppose the following sites, because they would require release of land from the Green Belt or would affect historic landscapes (such as the approach to Warwick around the east side of the Castle Park).

Sites:

3. South of Gallows Hill, west of Europa Way : harms setting of Castle Park and approach to Warwick from the south
4. West of A452 Kenilworth Road, between Northumberland Road and Old Milverton Lane - Green Belt, and essential part of the open countryside separating Kenilworth and Leamington
5. Blackdown - open countryside, which if developed reduces the separation between Kenilworth and Leamington by a quarter
8. Red House Farm, Lillington - Green Belt, visible land facing southeast
9. Loes Farm, Warwick - extends Woodloes Estate into Green Belt, and undermines tight planning control on north side of Warwick
13. 100 houses in each of 5 villages - this is an arbitrary imposition. Individual villages should be able to determine how much development they wish to accept.
14. 350 houses in smaller villages - there is no basis for such a figure, and most smaller villages should only accept 5-10 dwellings over 15 years if their rural character is to be ensured.

We also believe that Site 6 South of Sydenham, is too large an allocation and only a smaller development should be considered; that Site 2, Myton / West of Europa Way, is high-grade farmland protected from development under past Local Plans for its agricultural value, and its loss would be the end of the remaining green wedge left when employment land was developed east of Europa Way; and the scale of Green Belt release for Site 7, Kenilworth (Thickthorn) needs to be reduced. If these sites are released, this should be only after brownfield sites have been developed and windfall potential within the urban areas has been assessed.


PO5 Affordable Housing

CPRE supports the policy of 40% affordable housing which is carried forward from the 2007 Local Plan. It is strongly opposed to the part of the policy which would allow private sector developments in villages to fund affordable housing. If affordable (rented) housing is permitted in villages, this must be only following a sound assessment of local need, and should not bring with it housing for sale simply to provide funds for the affordable houses.


PO7 Gypsies and Travellers

CPRE supports finding an official site for gypsies. The numbers to be accommodated need reassessment against new policies: some gypsies have property elsewhere, and do not need to live in caravans. CPRE would propose that the gyspy site at Siskin Drive, just inside Coventry, be enlarged or re-sited in the Middlemarch employment area, so that part at least meets the needs of Warwick District.

PO10 Economy

CPRE opposes the provision of employment land north of Leamington on Green Belt. There is no need for major new employment land identification in the District. Surplus employment land and buildings in the towns come on the market continuously and can generally be re-used without any need to allocatec new greenfield land.

There is no shortage of employment land in Warwick District. In a recession, with economic difficulties meaning that land for employment becomes surplus, loss of existing sites to housing is more of a problem than any lack of new greenfield sites.

North of Leamington, proposed in PO8, would be an unsustainable location for employment development. It would be outside the town centres where the focus of employment is supposed to be; it would generate much car traffic; and the main transport routes through the District are south not northof Leamington.

The proposal for the Coventry Gateway around Coventry Airport has no economic justification: it would not be relevant as an employment site for most who live in Warwick and Leamington, is not easy to reach from Warwick District's urban areas, and would compete with the Ansty and Ryton employment locations nearby which are in Rugby District.

Established and new small businesses rarely need any planning permissions for their commercial activities.

Our conclusion is that no development of new employment land in the Green Belt is justified.


PO11 The Historic Environment

The existing (2007) Local Plan contains clear policies to guide conservation and decisions on developments that affect a Conservation Areas. This set of Policies should be generally carried forward, without any simplication (which can cause ambiguity).

A Policy to make the lengths of the Grand Union Canal and Stratford Canal in Warwick District into Conservation Areas is needed. Other Districts with extensive lengths of canal have created linear conservation areas.


PO14 Transport

The proposed new road links and road widenings in the Preferred Options would be harmful to the Green Belt and tend to encourage more car traffic. That would create unsustainable patterns of movement and increased car depenency. By contrast the proposals for the bus network are thin. They focus on Park & Ride provision which is not of importance to residents of the towns.


PO16 Green Belt

The Preferred Options would require major removal of land from the Green Belt for urban development. It would also require the removal of 'washed-over' status of some smaller villages which are currently covered by Green Belt designation. The very special circumstances required to be demonstrated if Green Belt land is to be released for building have not been shown to be justified.




The Key Issues


1. Vision and Growth

1.1 The key aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This reflects a current focus in national government thinking and speeches by Ministers. It fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years.

1.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

1.3 CPRE believes that there should be a much more careful balance between development and the environment than the Preferred Options would achieve. The proposed scale of development would risk being unsustainable and contrary to the NPPF policy that supports sustainable development.

1.4 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

1.5 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.


2. Sustainability

2.1 The National Planning Policy Framework (NPPF) at para 49 sets out the principles of sustainable development. The NPPF says that Sustainability has three aspects, environmental, economic and social. The Preferred Options pay little attention to the environmental aspects of sustainability.

2.2 The term 'sustainable' is used about 120 times in the full Preferred Options report, but this is mostly in relation to economic aspects of sustainability.

2.3 We do not believe that large-scale destruction of open countryside is sustainable development - it is unsustainable. Once lost it will never become available for future generations.

2.4 We acknowledge that a few mentions of sustainability in the proposal do relate to the social aspects such as providing sufficient of the right kinds of housing and facilities.


3. The Projected Housing Requirement

3.1 CPRE is strongly opposed to the proposed level of housebuilding advocated in the Preferred Options.

3.2 The justification for this level of housebuilding is weak, for the following reasons.


1. The ONS projections for Warwick District are arbitrary and probably overstated. They do not yet take account of likely reductions in net migration to the UK or the potential effects of the recession. They assume in-migration at recent levels although this is now reducing rapidly.

2. Projections for individual local authorities are notoriously unreliable because they do not take into account the implications of planning and other policies. Already the 2011 Census (issued in summer 2012) shows that the growth of population in the last decade given at para 4.2 of the preferred Options is nearly 50% too high. Population growth 2001-2011 was not 14,800. It was 10,000 from 2001 to 2011 (126,000 to 136,000).

3. House building rates in Warwick have been very low over the past five years and are likely to pick up only slowly. The rate of housebuilding proposed by Warwick DC in the Preferred Options is well above the rate achieved in the last 10 years and on current economic trends is unachievable.

4. The work by G L Hearn / JGC at Appendix 2 of the SHLAA does not lead clearly to any particular level of population, household or employment growth. Their projections are highly volatile, depending on a range of key assumptions.

5. From statements in the Preferred Options, and made at public meetings during consultation, it seems that Warwick District Council has decided to seek a relatively high level of housing development in the mistaken belief that it will help to boost economic growth. There is no overriding need for major new employment development. If population grows rapidly, it is more likely to result in a change in the balance of commuting, with more Warwick residents working outside the district.

6. The consultants' work on translating population growth into household growth is inadequate. It assumes too high a vacancy rate for new housing stock and fails to consider sharing and institutional population.

3.3 We have other major concerns about the population projections.

3.4 In its commentary on the projections, the Office for National Statistics says - 'Projections are not forecasts and do not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. They provide an indication of the impact that changes in demographic patterns might have on the size and age structure of the population in the future.' Therefore the projections should not be taken literally.

3.5 There are particular questions over two of the assumptions made in the national projections:
* Net international migration, which makes up roughly half the projected population increase, is likely to reduce in future, reflecting a tightening of government policy on this issue. This change will not yet have been picked up by the projections;
* Although there is little sign of this yet, birth rates may fall as a result of the recession and the slow recovery from it.

3.6 The Preferred Options forecast that Warwick District's population will grow by 21,600 between 2010 and 2026, and from this a requirement for about 9,390 extra dwellings is produced. (The average household size would stay at 2.3 persons.) This produces a rate of building of 587 dwellings per annum, not achieved in any past year for some decades

3.7 The suggested rate of building, at 550 dwellings per year, has not been achieved in the District for some decades, if ever. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The Government predicts only a slow recovery from the recession, with a gradual increase in house building rates. Therefore it could be many years before the Preferred Option's desired rate of house building can be achieved, and the past record suggests that it will not be achieved.

3.8 In an earlier consultation in September 2009 Warwick District Council asked for public views on three scenarios for numbers of houses. These were 200 per year, 500 per year and 800 per year. 51% of the public chose 200 per year. Despite this result the Preferred Options propose that over 500 houses be built annually.

3.9 The net in-migration element in the forecast housing requirement is large - 57% of the population growth forecast by the Council's consultants (in the SHMA) would be the result of net in-migration. However in-migration has fallen fast in the last 2 years and there is no clear reason why it should be provided for. If more houses are built, given the location of the District on the M40 and Chiltern Railway route, more inward migration will take place. There is not an objective need to provide for or seek inward migration.

3.10 We consider that the Preferred Options housing figures should be reduced substantially; the 2011 Census results and latest migration data be taken into account, and an objective need recalculated instead of assuming that in-migration should be planned for.


4. Proposed Locations for Housing


4.1 CPRE believes that a number of the major new housing locations proposed would be harmful. See response to PO4, Distribution of sites for housing.

4.2 The NPPF at para 109 states that "the planning system should contribute to and enhance the natural and local environment". This militates against development in the countryside and favours protection of landscapes, animal and plant life, public footpaths and Scenic Views. Further research would identify valued landscapes, geological conservation sites, soils ecosystems, impacts on biodiversity and ecological networks.

4.3 NPPF para 112 states that Local Planning Authorities should take into account the economic and other benefits of the best and most versatile agricultural land and should seek to use areas of poorer quality land in preference to that of a higher quality. Much of the land around Leamington is 'best and most versatile' agricultural land. This places a presumption against its loss to development.

4.4 Clearly any use of green land will require destruction of hedges, ponds and other habitats of animals and plants. It is likely to destroy public footpaths. It will certainly affect the views of countryside which are currently available to visitors, walkers and residents at the edge of the existing built-up area.

4.5 The area of the district which is not in the Green Belt is generally to the south and east of the built up area. While there are constraints here, and location (3) is wholly unacceptable, there is scope for some development at the locations previously considered in the 2009 Core Strategy.

4.6 Three pipelines run to the south-east of Offchurch, Radford Semele and Bishops Tachbrook, but not through the area of land adjacent to Europa Way or between Whitnash and Bistops Tachbrook, so do not appear to be a significant constraint.

4.7 There is some scope for more housing at Hatton Park which has been a successful development that maintains a 'washed-over' Green Belt status.


5. The Green Belt.


5.1 In para 79 of the NPPF, it is stated that "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence."

5.2 Para 80 sets out five purposes of Green Belt. The West Midlands Green Belt to the north of Leamington and Warwick and the south of Kenilworth meets four of the five purposes:
* It prevents urban sprawl
* It prevents towns merging
* It is assisting in safeguarding the countryside from encroachment
* It assists urban regeneration by encouraging recycling of derelict and other urban land.

5.3 NPPF para 83 states that confirmed Green Belt boundaries should only be altered in exceptional circumstances. We are far from convinced by the arguments that the boundaries should be altered. The sole reason appears to be to spread the pain of development on greenfield sites across the District. This is not a planning justification which satisfies the need for exceptional circumstances.

5.4 NPPF 84 makes it clear that sustainable development to be channelled towards urban areas inside the Green Belt boundary and towards towns and villages inset within the Green Belt boundary or towards locations beyond the outer Green Belt boundary.

5.5 As in other parts of the report we see clear conflict with the Localism agenda of the coalition government. The Localism Act gives communities, including neighbourhoods, towns and villages, a procedure for determining for themselves what development should take place and where it should be located.

5.6 NPPF para 87 states "as with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances".

5.7 NPPF para 88 states that "local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations".

5.8 Taking extensive Green Belt land out of the Green Belt and proposing it for housing is the opposite of a sustainable development policy.



6. Employment Land Proposals

6.1 CPRE supports a low-carbon economy; but it has a very long timescale, and must be developed but we are concerned that the proposed Preferred Options will not enable this. In particular, we question the proposal to "distribute development across the district". Established towns (and nearby cities) offer critical mass where homes and jobs can be developed in a balanced way supported by infrastructure such as public transport.

6.2 Substantial development in the countryside, such as the proposed major employment at the Coventry Gateway site, would increase the need to travel with the vast majority by private car. The Preferred Options recognise the importance of the need to reduce travel (e.g. in section 8.30) but do not seem to apply this principle consistently.

6.3 Major development in the countryside would make the principle of "developing an effective and sustainable transport package" very difficult to achieve and undermine the agreed principle of regeneration of urban areas. We support the preferred option (in PO3) to concentrate growth within urban areas but we are concerned about significant development in villages and rural areas.

6.4 We recognise the need to provide land for employment to meet proven local needs but are concerned about the proposed principle to provide land to "encourage the creation of jobs". Sustainable jobs are critically dependent on factors such as people, skills and finance, not just buildings or land. Increasingly, attracting skilled people and knowledge-based businesses to an area is dependent on the quality of the environment: somewhere people want to live as well as work. The social and environmental strands recognised in the NPPF are as important as the economic strand.

6.5 It is essential to keep employment balanced with housing: over-statement of housing numbers leads to over-statement of the need for employment land. We object to the over-allocation of housing (proposed in Section 7.22) to support the proposed Coventry Gateway, which has not been justified.

6.6 We note (from sections 8.21 and 8.22) that the Preferred Options propose some 66 hectares of employment land in the period from 2011 to 2026 and that 43 hectares have already been identified. For the remaining 23 hectares, we agree with the urban-brownfield-first priority and agree with the approach of locating employment with housing where new housing developments are really justified.

6.7 Compared to the remainder of 23 hectares of employment land over 15 years, the Coventry Gateway proposal amounts to over 97 hectares in one rural location in the early years of the strategy period. Such a volume of over-allocation would be indefensible and should not be considered as part of a balanced plan.

There is already a regional investment site at Ansty Park. It has fully developed infrastructure and yet currently vast tracts of empty land off blocked-up site roads. Empty buses frequently serve the mostly-empty site; it has excellent access to major highways but too few occupiers. The duty for local planning authorities to cooperate should mean that this site is supported by WDC rather than undermined with a competitive development in the Green Belt just 8km away.

6.9 Recent planning studies and processes have concluded that there is no need for more employment land in Green Belt. The Inspector's Report for the Examination in Public of the Coventry City Council Core Strategy (April 2010) concluded "There is no current need to allocate any additional employment land outside the city boundary, over and above that available at Ryton, to meet the overall economic objectives of the CS".

6.10 The Warwick District Employment Land Review of April 2009 concluded that "there is an oversupply of land suitable for the development of general industry/distribution that is already committed/allocated in the current Local Plan to accommodate demand in these sectors". The Addendum dated January 2011 noted a continuing decline in demand for B2 and B8 floorspace. While the 2009 Employment Land Review did identify a potential deficit of land suitable for office development, it identified "the area around south west Warwick and Leamington as most attractive both in market and planning terms". The 2011 Addendum noted decreased demand overall but also decreased completions, recommending further study. The earlier preferred development directions remained unchanged.

6.11 These plans and studies confirm there is no need for development of Green Belt land for employment. The plan numbers are backed up by experience on the ground, where for example the ex-Peugeot site at Ryton-on-Dunsmore has been vacant for 6 years and Ansty Park has struggled to find occupiers. We recognise that the Ryton site is in Rugby Borough but paragraphs 178 to 181 of the NPPF make it clear that local authorities must cooperate when drawing up Local Plans. The NPPF confirms that the Government attaches great importance to Green Belts, supports 'brownfield first' and reasserts that inappropriate development should not be approved except in very special circumstances. Need for development has not been proven and there is no evidence of valid special circumstances that would justify development in the Green Belt.

6.12 The Preferred Options consultation document picks up the claim that the Gateway "has the potential to provide in the region of 14,000 jobs" (section 8.33) even though this number is not justified and falls partly within Coventry. There are many examples of large, speculative developments where job creation assumptions are inflated and over-optimistic. New developments can remain half-finished for many years because demand proves to be far lower than anticipated. That would be a particularly damaging outcome for a large development with a devastating impact on the Green Belt to the south of Coventry. The number of jobs 'created', put forward by developers, cannot be relied upon as a measure of sustained economic benefit.

6.13 There are better ways of achieving more and better-quality employment. This is to put the emphasis on technological advance and the proposed "Emphasis on infrastructure": investment in communications technologies for rural areas in order to support small businesses and home offices. Broadband for rural communities continues to fall behind urban areas so rural businesses are increasingly uncompetitive. A well-wired rural community would help achieve both the low-carbon economy and the rural economy objectives. It would also make the district a better place to live and work for knowledge workers.

6.14 Finally, all the evidence indicates that in Warwick District no new development of employment land in the Green Belt is justified.

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I am writing to express my opposition to the District Council's plans to develop on Green Belt Land as shown in their 2012 Preferred Options booklet. The previously published 2009 Core Strategy presented a less expensive option which did not require the use of Green Belt land, and I can see no significant change that has occurred in the intervening period which would justify the elimination of this Green Belt land. Building on the Green Belt is meant to be permitted in 'exceptional' circumstances only and the justification for this in the preferred options booklet is unclear.

The development of this land would not only damage an area which is much loved by the local residents and by many walkers, runners riders and cyclists, but would also lead to the erosion of the gap between Leamington and Kenilworth and eventually contribute the merging of the two communities. New infrastructure would also be required to service these new houses leading to increased traffic and noise pollution in the North of Leamington. The South of the town already has elements of the supporting structure in terms of roads and shops and as such it would seem to make more sense in these times of economic hardship to focus on the less expensive alternative.

1. Level of Development required.

The assumptions for the overall growth of the housing market in WDC was taken prior to the recent publication of the 2011 census results which showed a smaller than expected population for the area, This means the the growth for the period 2001 t0 2011 was less than expected. If this lower than expected growth continues then the demand for extra development in the area should be less than that in the Plan. To add weight to this the figure of 550 new homes per year has never been achieved in a single year let alone for 15 consecutive years. This whole section should be reviewed in the light of the new figures.

2. Sources of Development Land

The level of brownfield site allocation seems to be low. These sites have appeared more frequently in the past and the migration of industrial sites from town centres is by no means complete. We hope that this area could be reviewed.

3. Allocation of new Greenfield Development Land

The allocation of 10% of the development land to the rural areas seems suspiciously arbitrary and appears to be a political decision to "share the pain". Similarly the selection of 5 "larger" villages to absorb 100 new homes is decidedly arbitrary. Firstly, the 5 selected villages do not have any special characteristics over a number of other villages or rural conurbations. The exclusion of Cubbington, Leek Wootton, Bubbenhall and the Hatton Park/King Edwards conurbation seems perverse. Secondly, the choice of villages which are deemed to have the infrastructure to take the extra development puts extra strain on the existing overburdened infrastructure, especially traffic in these areas. An alternative route, to expand the areas with poorer infrastructure so as to improve the quality of life in these areas does nopt seem to have been considered. In the case of Hampton Magna and Hatton Park/Kings Meadow and the West Warwick (Chase Meadow) developments, Hampton Magna's facilities are used in great measure by the other two conurbations. An improvement in their local facilities would improve the quality of life in their communities and relieve the strain on the facilities in Hampton Magna, We use this example as we are well aware of our local situation and feel that there may be other areas that also have other communities that are acting as cuckoos in their nest. This strain on the infrastructure of existing communities could be lessened by improving the infrastructure in the satellite communities by the application of CIL money generated from a modest expansion there.

The New Local Plan has to be evidence-based. The arbitrary choice of the five villages, the arbitrary allocation of the same numbers in each of them and the the policy of adding to the already straining infrastructure of these villages rather than improving the infrastructure of those suffering from lack of amenities all show a lack of being based on any evidence at all . We hope that this whole section could be reviewed

4. The situation of Hampton Magna

Hampton Magna was built on a 1960s brownfield site to wit the Royal Warwickshire Barracks at Budbrooke. It was built in the late 60s/ ealrly 70s and so is in its fifth decade. As such it has well defined historical boundaries, ie the Barracks perimeter. There has been a little infill over the years and the Parish Council invited Warwickshire Rural Community Council to carry out a Housing Needs Survey which identified a need for 5 houses in the Parish. The need for further development is not locally required nor, according to the Parish Plan is it supported by the local residents who gave their views in a long questionnaire that formed the basis for the Plan.

The basic built infrastructure of Hampton Magna has changed very little from the the early 1970s when the building of the houses was completed. The village is served by C class roads that link us to the Warwick/Birmingham road and Warwick/Henley Road. The electricity supply is very similar to that supplying the barracks and the sewerage system was put in by builders during the period of "the lump". The school has bee extended, but is, in essence, still the standard 1960s/70s building that is seen all around the county.

The roads leading to and inside the village become very busy at the peak time, in the morning and evening. The locally generated traffic is increased by the use of the C roads as short cuts from the Birmingham Road to the Henley Road and the A46 and the M40 at junction 15, and by traffic going to and from Warwick Parkway Station. The A 4177 at Stanks roundabout which is the main exit/entry to the village is severely congested every morning and afternoon.

The electricity supply is frequently interrupted for a shorter or longer periods, showing the fragility of the current arrangements

The sewerage system was not adopted by Severn Trent Water Authority until privatisation, when the Authority agreed to adopt the system prior to flotation. The system has not been improved and one of the areas where the system was extended to accommodate a few new house frequently suffers from problems.

The school is very popular and has recently had its standard number increased. Whilst this has improved the viability of the school, it has also lead to a great deal of school time traffic congestion at the beginning and end of school.

The infrastructure of Hampton Magna in these areas is at the limit of its usefulness. There is little that can easily be done to improve the local traffic situation, because of the need to cross canal and railway lines. We are not aware of any plans to improve the electricity or sewerage system locally. The introduction of such a large number of house into this village would lead to a complete overload of these services. We hope that you will look again at the need to use this village as one of the villages for expansion and will take a more pragmatic approach, allowing infill in non village areas and improve the infrastructure in other areas.

5. Overall

The residents of Hampton Magna have long been strong supporters of the green belt, not just around Hampton Magna, but throughout the District. There is a deep suspicion of moving green belt boundaries and if any such changes do prove necessary anywhere in the District it should be done with clarity, leaving no area for doubt or future challenge.

I am absolutely disgusted, alarmed and appalled that 3,330 houses are going to be built in Warwick.
How is it fair that Warwick will be spoilt by over 3,000 more houses being built in South Warwick? This is 37% of the total build proposed in the whole District which is 10,800. 97% of people opposed building in this area during the Core Strategy Consultation. We have had quite enough development in Warwick - Gates, Chase Meadow, Myton Road and other smaller developments. Warwick should not be blighted by yet more housing while other areas in the District are let off lightly.
Warwick at present is a picturesque and historic town with a unique character that residents and visitors alike enjoy. It has always been nestled amongst the beautiful green Warwickshire countryside. This countryside will be obliterated by plans to build on only greenfield sites rather than brownfield sites, which is against the National Planning Policy Framework. Greenfield sites are only supposed to be built on in very special circumstances. The District has 85% green belt but 45% of this is to be built on thus reducing the gap between conurbations. The District say there is nowhere else to build but there were many alternatives in the previous Core Strategy options. Warwick will cease to be the attractive county town that locals and visitors know and love. It will become yet another built up concrete jungle.
None of the plans make any sense because other areas that would welcome more housing, such as rural villages, have not been allocated enough housing. Such villages would be delighted at more development because more people could stay in the village they were born in.
Even the safety of residents will be sacrificed for the new housing; flood zones, such as Europa Way, Gallows Hill and the Banbury Road area, will be built on. This will impact on areas of Warwick which flood, such as Myton Road and Bridge End. Warwick will frequently be under water and residents will have their homes damaged but nobody seems to care about the human cost so long as WDC targets are met.
Warwick already suffers from terrible problems with infrastructure. The traffic problems are atrocious and our roads cannot take any more traffic. Warwick simply was not designed to take the levels of traffic that it does at present and the town is at breaking point. Parking is a nightmare and the sheer volume of cars makes crossing the road difficult and it spoils the overall appearance of the town. These plans do not put infrastructure on the priority list, such as new roads, bridges, schools, extra health provision, police and the fire service. The County admit that they cannot contain the resulting increase in traffic (possibly an extra 6,000+ cars in South Warwick alone) and that there are places where congestion will worsen.
Furthermore, this increase in traffic will result in the air pollution in Warwick becoming a million times worse than it already is. The air quality is some of the worst in the country and is not good for the general health of local people. Air quality in areas of Warwick are already in breach of Air Quality Regulations and will become toxically high. There is no management plan to address these levels. The proposed 40% increase in the town's population over 15 years will inevitably add to the congestion and air pollution. The increase in population as a result of this new housing, will make life in Warwick unbearable and is a threat to public health. Present and future residents of Warwick will be unsafe.
The local plan is seriously flawed and I implore you to think again about allowing these plans to go ahead. The future of Warwick is in your hands and, as a resident who is passionate about this historic town, I shall be sorely disappointed if you do not reconsider these plans. Please reduce the number of houses that are planned for Warwick.

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As I do not believe that WDC has demonstrated the 'exceptional circumstances' necessary to build on green belt land when other non-green belt land is available, the plan suggested must not go ahead. It would set a very worrying precedent which could see Leamington and Kenilworth edge ever closer to each other.
Any idea of sharing out available land for development purposes whether that land is green belt or not must be resisted to allow Leamington to preserve its unique character as a town surrounded by green.
This current plan smacks worryingly of the present government's ideas about preserving areas of special natural beauty. This sounds wonderful until one understands the subtext; most of the countryside is not ESPECIALLY beautiful and is therefore up for development. Let WDC not slide into this slipshod thinking. The countryside to which most of us have access is very precious even if it is not of outstanding natural beauty.
Houses are clearly necessary but please ensure that they are built where infrastructure already exists and where they will not cause Leamington to encroach on precious green belt.
One last thought:
Please do ensure that any houses built are of size, quality and price for those who require housing and not of a type designed to give developers hefty profits.

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New proposed building on green belt land

Green belt land is protected land. If you start to build on it now where will it end? There are far more suitable sites that have already been identified. Green belt is green belt!

Violation of countryside.

We oppose the above because we wish to protect the countryside, natural environment, the right for people to live in or near to a natural environment and the belief that the 'green belt' was established to protect green areas of land between towns.

Objection to plans North Leamington

I am very concerned in reading about the plans being made for housing in Leamington.
1) On what basis has he amount of housing been based on
2) Why use green belt in North Leamington when there is space in the South
3) The infrastructure is already in place in the South
4) Yet again there seems to be a problem, as with the HS2, that proposals are not thought through and green space and country side is not important!

Whilst I believe the plan as currently set out is deeply flawed in many aspects ranging from its fundamental assumptions through to its final proposals I base my objections on two main points:

1. The plan proposes building on Greenbelt Land. Building on Greenbelt should be a final resort and used only when all other options both including re-use of "brownfield" sites are exhausted. The Greenbelt is a valuable resource for all, not just for those living adjacent to it.

2. The plan as set out represents a further step in the merging of Kenilworth, Leamington and Warwick into a single conurbation, a process that has happened by stealth and by design increasingly over the past 40 years. If the council want a single town to be established they should be honest and open about such a proposal. Otherwise the separation, particularly of Leamington and Kenilworth in this case must be maintained.

Re: greenbelt between kenilworth & leamington

We would like to object to the use of greenbelt land between Leamington and Kenilworth for both housing and industrial development and also for the proposed HS2 development.

The greenbelt currently separates Kenilworth and Leamington, and urban sprawl in this area would effectively mean that the towns would merge together.

We think that an increase in the size of Kenilworth in this area would destroy an attractive approach to the town. If more shops and industrial facilities are built then this would only exacerbate the problem of the current empty units available in the town. Road access for this area would create dreadful problems for the existing busy traffic flows.

Kenilworth and Warwick are both historic towns and should be protected for future generations.

Thank you for the Info. I live alone,But have family in Wales & Switzerland who visit occaisionally & as they were brought up in leafy warwickshire are dismayed to find the gradual loss of green belt in warwickshire. They will also be complaining on behalf of the Walkers ,Cyclists. Wildlife habitat & the Natural things that make life worthwhile.Bigger highways,Bigger Superstores,& bigger Vehicles to supply them . One day there will be no Villages ,Our Communities will suffer.One day we may be merged with Coventry. What Heritage are we passing on with the selfishness of some of the plans for our this beautiful County

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