PO4: Distribution of Sites for Housing

Warwick University continues to expand as does the increased need for accommodation for staff & students.
There is no allocation for building new accommodation near to the University which would be much more sustainable. Green Belt could be could be best used adjacent to the University to enable them to walk to the University, instead of relying on them finding accommodation a long way from the University with the need to travel many miles every day by road.

When there is clearly a sufficient area of the district available to accommodate the full allocation of new housing which is not in the green belt, I feel that it is unacceptable to redefine the current green belt areas in order to build the new homes there. This will alter the character of the entire district and is, I feel, just an attempt to spread the grief rather then single out one particular area.

The allocation of between 30 and 80 houses for each Category 2 village will provide a modest amount of housing growth that can be absorbed into the villages without significantly changing local character. The amount of growth proposed under this policy is appropriate to make an effective contribution to supporting local facilities and services. Growth of less than 30 dwellings is unlikely to have a meaningful impact on supporting local services.

As the Council is aware, the Leamington Allotment Societies, through BLAST, made a strong case for the retention of the existing allotment sites. The two sites most at risk were those of the New Milverton Allotment Society and the Binswood (Ex Servicemen) Allotment Society (the Society) as a result of Option 1 of the Options for Growth document.
It is pleasing to note that the land of the two allotment sites is now excluded from the Preferred Options of the draft Local Plan together with part of the agricultural land to the North and West of the sites. Although not absolutely clear from the plans provided with the Consultation Documentation, it seems likely, from the disposition of the land 'North of Milverton', that the allotment land is not at risk from the provision of access to the proposed development land. If confirmed, this is again pleasing to this Society.

There is no mention of agricultural needs in the consultation document and in relation to the Green Belt no mention of the agricultural quality of the land proposed for development. Whilst accepting that housing is important so is and increasingly will be the value of agricultural land. A planning framework driven solely by housing needs cannot provide a balanced set of proposals

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.

My Objection is to do with the Failure to ensure new developments are appropriately distributed across the district
The NLP page 9 (4.11.7)

I broadly support Option 2 detailed in the Strategic Housing Land Availability Assessment but believe that this rebalancing growth towards a) Kenilworth and b) South Harbury Lane, Leamington Spa offers significant benefits compared to the proposed East Milverton preferred option.

3.1 The benefits of developing Kenilworth
A strategy of developing Kenilworth through the development of available, suitable, and deliverable sites at Glasshouse Lane/Crewe Lane (K18) and Woodside Training Centre (K19) would be beneficial as on the following grounds:
* Consistent with Broad Option for Growth Option 2 favoured by WDC
* Consistent with the identified need to greater diversify the demographic profile of Kenilworth
* Develops a better geographical distribution of housing (and business) in the district
* Offers the ability to develop clearly bounded (low value) Green Belt
* Offers greater sustainability for developing transport links to potential Site of Regional Importance
for Employment at the Gateway, Warwick University and Stoneleigh.

3.2 The benefits of developing South Harbury Lane
South Harbury Lane offers significant advantages compared to the East Milverton preferred option.
* South Harbury Lane is non-Green Belt land and has been identified as the second most favourable site for development within WDC and significantly outscores East Milverton.
* The favourability report recognises significant benefits accruing to South Harbury Lane in particular:
- the reduced need to travel
- it better enables sustainable transport
- is more favourable to health and well being
- offers more favourable access to services

Furthermore the Strategic Transport Assessment Overview Report identifies that development of part of the South of Harbury Lane site (close to Europa Way) would have no impact on transport infrastructure needs beyond that already required by other development. Indeed, housing in this location would facilitate better access for those working south and north of Leamington (Jaguar Land Rover or Birmingham) and needing access to the M40. Not all residents of Leamington will choose to work within the locality, particularly if seeking to attract those working in high value industries with regional and national footprints.

Although the sites for housing are more fairly distributed across the District there appears to be a large proportion to the west of Europa Way. Even with road improvements I fear this will lead to congestion on the roads into Warwick because there is only the one bridge across the river and the facilities including the hospital are situated on the other side of the river.
I believe that locations 2,3,10,11 and Bishop's Tachbrook come within the same Parish. That is 3,250 houses, over 30% of the total, which seems to be a very large proportion for one parish.

Baddesley Clinton Parish Council has considered the preferred options set out on page 7 in the Preferred Options booklet for distribution of sites for housing.

After consultation within the village and after consideration by the Parish Council, we, as a Parish Council are broadly in agreement with the preferred option expressed for PO4 in the booklet. We recognise the need for some further development to meet needs of the district and feel the preferred option is a balanced and well thought out approach.

In this response we focus on the broad issues, so feel it is inappropriate to respond in this section other than to note that issues of location often amount to a 'divide and rule' tactic, pitting different areas against each other.

However, under PO10, we do explain why housing should be concentrated within existing urban areas.

Congratulations to Warwick District Council in producing balanced and sustainable proposal for housing development in the district; brownfield development in urban areas to make sensible use of land that becomes available, urban expansion close to industrial development (not to be confused with urban extension synonymous with the mile on mile of suburban sprawl in UK before post-war planning controls or in other countries such as the US) and vitalising villages through the co-location of work and accommodation.

These principles must be upheld during the process leading to the publication of a draft local plan in 2013.

Under PO 10, we make strong and specific criticism of the Garden Suburb proposals. Many of the claimed benefits are bogus, while the low density sprawl is extremely profligate with land and damaging to sustainability of transport and local services.
It would not be difficult to increase the planned average density and the proposed suburban additions around Warwick / Leamington - which cover broadly 3 areas - could be concentrated in only 2 of the three locations. There would still be choices to be made and not easy ones.

Whereas I fully support the aim to widen the distribution of housing sites, the concentration of roughly a 1/3 of all planned housing in south Leamington/Warwick goes against this aim. To put add 2,900 homes (location 2,3 and 10) along or close to Europa Way will hugely exacerbate the existing traffic jams for the A452.

I strongly object the 1600 homes planned for location 3 - South of Gallows Hill/West of Europa Way. Apart from the traffic congestion this will cause, this development will totally change the aspect and rural approach to Warwick and Leamington from the south.

It presents a housing nucleus that occupies former farming land and will encourage future expansion south of Park Farm and east towards New House and Grove farms.

The policy would benefit from clarification as to what "Larger sites" means under bullet 'A'. We note that on page 21 the plan also refers to "Strategic Sites". If they are one and the same, this should be clarified.

Under bullet 'A' the Policy states that a 'Development Brief' will be required for all "Strategic Sites" of over 500 dwellings and that said brief would be prepared jointly by the Council and developers in consultation with the community. In principle, we do not object to the requirement but believe that additional information is required to explain what the purpose of the briefs will be, how they will be brought forward and whether or not it is the Council's intention to formally adopt the document. Regards the last point we would be opposed to the documents being formally adopted on account that it would, due to consultation requirements and ratification by the Council, add further delay to sites being brought forward and developed.

In your review you rightly identify that housing and "its quality, affordability and availability are crucial for a good quality of life". Therefore your plans should not jeopardise that for existing residents. New homes should not come at the cost of potentially depreciating and/or making less appealing others as a result, and my concern is that your proposals of so many houses will change the dynamics of the area. The standard of housing and facilities, particularly on Warwick Gates, is one of the things that appeals to myself and my family - and which brought us to the area from Bristol. If you "dilute" that feel by introducing more affordable and smaller houses will that not change the "feel" of Warwick Gates and its surrounding community? I do not think enough has been done to date to consider the potential negative impacts such developments will have on the Warwick Gates community as a whole, i.e. with schools and catchment areas, and the general ambiance of the area.

A lot of people have resided on Warwick Gates to be within the catchment area of good schools such as Myton. Will these proposals effect the catchment boundaries, forcing existing residents out of Warwick Gates to be within catchment area?Will this then de-value other properties in the Warwick Gates area, if it becomes not such a sought after place to live? Will it lose its appeal as being a family oriented society?
The issue of schooling does not seem to have been addressed in any detail in your proposals, but this must be carefully considered. Any new proposed sites should have its own schools built thus not having any detrimental effect on the existing arrangements.

The other issue to consider is the policing arrangements for the area - what with Warwickshire force making a series of redundancies. Will they have sufficient resource to cover these additional proposed areas?

COMMENT

The King Henry VIII Endowed Trust support the Council's decision to concentrate most development on the edge of the main uban areas within the District but consider suitably located non-Green Belt land should be allocated and released before Green Belt land and sites in less sustainable locations.

Land under the Trust's ownership (SHLAA site ref W35) is located outside the Green Belt and considered well located to Warwick town centre and to existing and proposed social and community infrastructure, including facilities at South West Warwick. The site measures approximately 36.5 hectares and could be brought forward in later phases of plan (i.e. Phases 2 and 3). As a responsible local landowner the Trust would be happy to work with key stakeholders including the District and Town Councils to help realise this development opportunity if favoured over current alternatives in the Preferred Options.

I wish to object to the new local plan. Building should not be allowed by the Council, under any circumstances, on green belt land to this scale when other options are available.
Maybe some of the very many empty office blocks and factory unit areas could be converted or built on to provide low cost housing rather than reducing the essential green belt which creates a pleasant divide between our towns.

I am writing to express my displeasure and disgust at the proposed development plans on the Warwickshire Greenbelt land around Old Milverton, Leamington and Kenilworth.
Please reconsider these plans before an area of natural beauty is destroyed forever!

SAFEGUARDING THE GREEN BELT

I wanted to express my concerns about plans in place to put new roads through our countryside. My husband and I regularly walk through leamington, looking at the lovely countryside and wildlife there. I often take my grandchildren too. We both feel that it would be a shame to put new roads and houses there destroying our green belt.

We would be very grateful if you would take our views on board,

We want to record our opposition to the proposed use of GREEN BELT land between Kenilworth and Leamington.

We are daily users of the Chesford Crossroads from Ashow. The traffic on the A452 has increased to dangerous levels in the last twenty years during the time we have lived near this junction. The council has only introduced a cheap, but effective, dual carriageway system throughout this period. The system maybe effective but does nothing to enhance the appearance of the local environment and in our opinion is a complete eyesore. This alone does not give us much confidence for their future planning and work as much more traffic would automatically result with more houses and businesses using this road.

We believe land south of Leamington is available for development and appears a much more realistic solution.

I object to using our Greenbelt for building
I thought that Greenbelts were to be kept as such for ever
We have lived here since 1956 and the location was one of the reasons we came to live here
I consider it a crime to even think of building on it.
There is enough building round Leamington

Dear Development Policy Manager,

We are writing to express our views about the Local Plan.

We believe that the best option would be to develop land to the south of Leamington Spa, rather than the north. There are several reasons for this. First, we understand that land to the south has previously been identified as being suitable for development by the Council. Developing this land would expand the Heathcote community and help develop the existing local facilities there. Second, it would result in quicker links to the M40, avoiding the need for residents to pass through the centres of Warwick and Leamington. Third, residents would have quick and easy access to the local railway stations. Fourth, residents would be closer to existing employment areas, and fifth it would reduce the need to develop Green Belt.

In contrast, development of land to the north of Leamington Spa would involve Green Belt land and would result in greater traffic through the already congested town centre. It would dramatically increase traffic on the A46 and A445, and it would require a new road to be built, resulting in far greater expenditure than development to the south of the town. The money required to build this road would be better invested in improving the existing infrastructure south of the town.

As residents of the area to the north of Leamington Spa, we believe the development of Green Belt land in this area would have a dramatic detrimental impact on the local community and should only be considered as a last resort. Since sufficient land outside the Green Belt that is suitable for the proposed development is available to the south of Leamington, to the east of Radford Semele and to the south of Bishops Tatchbrook, we can see no compelling reason for developing the Green Belt land to the north of Leamington Spa.

Yours sincerely,

Prof Gregory Challis and Dr Alison Foster

General: The term "preferred options" implies that the decisions have already been made, and that there is little, if any chance of them being changed. This underlines the FACTS that the results of the previous "consultation" have been ignored, so leaving residents with the impression that this consultation will also have no effect.
PO1: 52% of the respondents to the previous consultation opted for the lower number of new houses to be built, on the grounds that this would meet the requirements of current residents and their families. It would not attract further influx of people seeking employment not available in the District, employment which they would only find outside it, further increasing the already unacceptable traffic problems. The Council decided to ignore this view and propose a much larger (100% larger) number of houses. We can only conclude that the Council is bowing to instructions /bribes from Westminster to allow more houses to be built by private developers, since there is no indication anywhere that the Council itself intends to carry out any of this housing growth.
PO2: The infrastructure levy is an essential feature of any increase in the number of houses built in the District. However, it must be levied and spent BEFORE the new housing is occupied. We have already experienced the problems which delaying this expenditure has created in Warwick.
PO3/PO4: There is clearly a preference for a high proportion (almost 50%) of the development to be located in Warwick. There seems very little proposed for the villages. Half the proposed housing development is on the south side of the district. Given that the bulk of the new employment opportunities will not be in the small area of the District, but in the larger employment proposals for Coventry, commuting through the towns will increase, not decrease.
PO5: The balance of the types of new housing should be very carefully scrutinised: too much of recent development has been of small properties and retirement flats, only suitable for short-term occupation by first-time buyers. More of the new housing must be for family use. The proposal that 40% of new housing should be "affordable" is essential, and must be maintained against developers' pressure for its reduction. A better definition of "affordable" is also required
PO6/PO7: Statements of the blindingly obvious.
PO8: The designated employment land must be maintained against the pressure which will be put on the Council by developers. We have already experienced in Tournament Fields the result of this pressure proving effective. There is no indication in the Plan of what percentage of the land will be designated as employment land.
PO9: We note that there will be "support for new retail investment on Leamington Town Centre". Why only Leamington? The other towns are equally deserving of support, though there is no indication that this proposal has any financial backing.
PO10: Forget the concept of "garden towns/suburbs". These were built in an era of weaker planning regulations and allowed a much larger area of land to be taken into use for housing. In the current climate, such land use is not acceptable to the general population. Planning law is about to be relaxed, and the Council must be vigilant in maintaining the quality of development.
PO11: This is a very weak section, "offering help and advice" is not very positive: more concrete proposals, including financial commitment is needed. This is repeated in PO17 where "support" and "seek contributions" are the key words.
PO14 (and un-numbered section following): The road improvements proposed would be of marginal value. The "improvements" to Europa Way and the junctions would be very expensive, and could use up a substantial proportion of the available infrastructure levy, to the detriment of more useful projects, such a schools, health centres and open areas.

I wish to object to the new local plan. Building should not be allowed by the Council, under any circumstances, on green belt land to this scale when other options are available.
Maybe some of the very many empty office blocks and factory unit areas could be converted or built on to provide low cost housing rather than reducing
the essential green belt which creates a pleasant divide between our towns.

We wish to register our objection to the New Local Plan for the following reasons:

1. The development of housing and associated infrastructure planned for the precious green belt land to the north of the town and the construction of a new link road from the A452 to the A46 through Old Milverton, when better alternatives exist involving less cost to the environment and most probably also in monetary terms.
2. We accept that new housing is needed in the district though the estimates of the numbers required look well in excess of reality. We think it would be a tragedy for future generations if Green Belt land is lost when other good alternatives exist such as:
a) Land between Whitnash and Radford Semele and South of Leamington towards Bishop's Tachbrook
b) Hatton where good rail and road access already exists
3. The development does not appear to cater sufficiently for pedestrians and cyclists.

The plan gives the impression that it was started from the premise of taking the Green Belt land and all the verbiage in the plan then sets about trying to justify it.

We very much hope there will be a fundamental re-think before lasting damage is done to our local heritage, which future generations will deplore.

Housing Allocations.
We are concerned at the inclusion of Map 2 in the full document, which appears to include land not shown in the preferred options Map 4. Does this mean that sites shown on this map could potentially be reconsidered as development options?

South of Gallows Hill, west of Europa Way. Option 3.
This site bounds Warwick Castle Park along much of its eastern perimeter.
Development up to Banbury road would be extremely detrimental to the Grade I registered Warwick Castle Park. You will be aware of the history of Warwick Castle Park. The new line of Banbury Road, from the Asps into Warwick was constructed in order to enlarge the park, to enable the construction of the much larger lake, New Waters, which actually extended across the new road, but finally, it was part of the design of the park itself. The second earl, who was responsible for the enlargement of the park was working on his design for the approach to the castle from 1777. Instead of the town and castle coming into view all at once, as it had formerly done, the alignment and landscaping of the road produced a progressive unveiling, beginning with the spire of St Nicholas church which appears in the centre of the line of the road. Gradually parts of the town appear, and then the explosion of the view of the castle from the bridge. This magnificent effect would be irreparably damaged if development were permitted on the scale indicated and so close to the road. This is the setting of the park, the castle and of the town itself.

The eastern verge of the road is well treed over much of this length, but the views between the trees are long ones, as the land is comparatively high. The Technology Park is itself a regrettable but moderate intrusion and the recently constructed access to a caravan park which actually sits on part of the park, and about which we were never consulted, is visual vandalism. However, the existing small suburbs emerge discretely from the landscape and do not offer the visual competition that a mile of sprawling suburb on elevated ground would bring.

We therefore strongly recommend that this option be withdrawn or the boundaries be reconsidered, allowing the immediate view from the road to be rural in character and so respect the setting of the park.
Designating the edge of the development as "amenity" land would not be an acceptable alternative, as this would create suburbia just as much as houses would.

Loes Farm. Option 9
We observe that this proposed allocation has been reduced from the original, presumably to avoid inclusion of the registered landscape of Guys Cliffe. However, the setting of the landscape is wider than the designated area. Contrived views within and out of the gardens are a major characteristic of the landscape. The Register description enumerates the land acquisitions made by Bertie Greatheed in order to create small areas of parkland. Loes Farm was bought for this purpose from the Earl of Warwick in 1824. It gave him control of views to the west of the house, including of the Como Pit, and to Gaveston's Cross. The buildings of Loes farm are mentioned in the register description as an incident in the view.
The development of this part of Loes Farm would therefore have a detrimental impact on the historic designed landscape. It would impinge on important views, and would bring development right to the walls of the kitchen garden, which dates from before 1786.

We are therefore strongly opposed to the inclusion of this site within the preferred options for development.

Other sites
We hope to see more information about the proposals for infill sites in the towns and villages. As the proposals now stand there is the potential for damage to the character of neighbourhoods and adjacent sites. Examples are the well-treed Riverside House site which contributes substantially to the character of New Milverton, and the vague nomination of a hundred houses for Barford, where the locally registered landscape of Barford House is already under siege by a development proposal. We hope that this land will not be assigned for part of the allocation.

There are likely to be similar sites in the other named villages also exposed to damage. It is important that there be design guidance for the development of some infill sites in the towns and in the villages in order to achieve the best outcomes.

Policies
We are pleased to see the intention of excluding garden land from development.

We are also pleased to see the intention expressed in PO 11 to provide policies to protect the historic environment, though we are alarmed that the failure to include draft policies in the present consultation document may result in hasty and imperfect drafting at the next stage.

We hope that the policies that are produced will be at least as strong as those which currently apply. We appreciate that the present recommendations for integrated protection of heritage assets will require considerable re-drafting of the current policies. We also hope that adequate provision will be made for the inclusion of built structures in the local listing regime, as this could give protection to some garden structures which are currently vulnerable.

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.

1 INTRODUCTION
1.1 RPS Planning and Development (RPS) has been instructed by Lenco Investments (Lenco) to
prepare representations to the Warwick District Council New Local Plan Preferred Options
consultation document, in respect of their land interests at Baginton.
1.2 Warwick District Council (the Council) has proposed their Preferred Options in terms of housing
and economic growth and their vision for the district generally over the plan period to 2029.
These are currently being consulted upon until 27 July 2012.
1.3 RPS has made representations on behalf of Lenco to the previous stages of both the Warwick
Local Development Framework and the Coventry Core Strategy, to ensure a suitable approach is
taken to cross boundary development led growth.
1.4 Lenco's land interests at Baginton relate to a site which lies to the south of Baginton village
situated within the Green Belt, as shown at Appendix 1. It is important to note that Lenco has the
controlling interest in the majority of this land.
1.5 The site Lenco has interests in lies to the south of Baginton village, and. The site extends to
approximately 50ha and is in a sustainable location within easy access to Coventry City Centre,
close to the perimeter edge of the airport, with excellent cycle, pedestrian access to the
surrounding areas, and vehicular access to major transport links such as the A45 and A46.
1.6 Whilst the site falls within the local authority area of Warwick District it remains very close to
Coventry's administrative boundary, as well as the major sub regional employment base centred
on Coventry Airport. RPS is aware of the current proposals to expand Coventry Airport, and a housing development at Baginton would support these expansion plans.
1.7 The representations, therefore, address the need for housing growth within Warwick
administrative boundary and suggest that large-scale growth should be situated within close
proximity of employment development to ensure that people can live and work in close proximity.
Such proposals will support the Government's objectives to encourage economic growth in order
to revive the economy. Furthermore, these representations address the need for cross-boundary
growth and for full and proper cross-boundary working to be established between, Warwick,
Coventry and Nuneaton and Bedworth Boroughs as required by the Localism Act and NPPF.
1.8 The following chapter provides details about the site at Baginton, and our comments in response
to the Preferred Options document are provided in Chapter 3 and are set out in the same format
as the Council's response forms.
1.9 RPS are willing to meet with Planning Officers from Warwick District Council again concerning
Lenco's land interests and the New Local Plan process to discuss the potential of the site in
meeting local housing needs.
2 LAND SOUTH OF BAGINTON
2.1 The site Lenco has interests in extends to approximately 50ha and lies to the south of Bagington
village. The site is in a sustainable location close to Coventry City's boundary and the urban
area, and within easy access to the City Centre, and major transport links such as the A45 and
A46. The site, being close to the perimeter edge of the airport, with excellent cycle, pedestrian
and vehicular access, provides an exceptional opportunity for the provision of balanced housing
growth in the most sustainable manner.
Planning Policy
2.2 The Local Plan Preferred Options promotes 10,800 new dwellings within Warwick District for the
plan period up to 2029, at an annual delivery rate of 600 dwellings a year.
2.3 Evidence advanced by the West Midlands regional assembly for the West Midlands RSS
Examination in July 2009 from the Cambridge Centre for Housing and Planning Research,
based on 2006 ONS Household Projections and allowing for the economic downturn, concluded
that Warwick District's housing requirement between 2006 and 2026 was 18,200 dwellings at a
rate of 910 dwellings/year. Whilst the RSS is not longer in place, the evidence base is still to be
taken into account by Local Planning Authorities in preparing development plan documents.
2.4 The 2012 Strategic Housing Market Assessment indicates a requirement of 698 dwellings a year
to meet the affordable housing needs of the District in addition to market housing needs, which
is significantly higher than the level of housing currently being proposed by the Council.
2.5 The 2008 ONS Household Projections predicted an increase of 17,000 households between
2008 and 2028, at a rate of 850 dwellings a year. This represents an additional 150 dwellings a
year than is currently proposed through the Local Plan, which clearly will not meet the District's
identified need for new homes.
2.6 RPS is also aware that the 2012 SHLAA indicates that the District has a supply of deliverable
sites to provide 13,385 dwellings between 2014 and 2029, excluding windfalls, which is greater
than the numbers proposed within the Local Plan. Therefore the Council has identified the
ability to deliver housing sites at a higher annual rate than is currently proposed through the
Preferred Option.
2.7 RPS, on behalf of Lenco, therefore believes that the proposed figure of 10,800 new dwellings is
insufficient and that a higher level of growth would better reflect the projected population
increase and ensure that identified housing needs can be met, as suggested within the evidence
base. The Council cannot meet a higher target without locating housing on greenfield of Green
Belt land, and therefore should consider sustainable locations outside of the urban areas to
ensure housing needs can be appropriately met.
Cross-boundary Growth
2.8 The NPPF states that Local Planning Authorities have a 'duty to co-operate' on cross-boundary
planning issues, in particular for strategic priorities including housing, to meet development
needs which cannot be met solely within their own administrative boundaries.
6 rpsgroup.com
2.9 It has been recognised in Coventry's SHLAA assessment that the Council cannot meet their
housing targets on land within their administrative boundary alone. It is considered, therefore,
that Green Belt locations on the periphery of the urban area should be recognised as
appropriate locations for accommodating future growth.
2.10 The Green Belt south of Coventry was recognised through the Warwick Core Strategy process as
being an appropriate location for accommodating future growth of the City. Although the site is
within Warwick District it lies close to Coventry's administrative boundary, as well as the major
sub regional employment base centred on Coventry Airport.
Coventry Airport
2.11 Whilst both Coventry Airport's major sub regional employment base and Baginton village are
located outside of Coventry's local authority boundary, they are socially and economically
associated and physically adjoin the Coventry urban area. Residential development in this
location at Baginton could balance the existing significant employment base on the southern
side of Coventry, such as those around the airport at Stonebridge Trading Estate and
Middlemarch Business Park, both of which are within a very short distance of the site, as well as
the air freight and terminal employment opportunities.
2.12 RPS is also aware of the current Coventry and Warwickshire Gateway Scheme proposals
(Appendix 2) to expand Coventry Airport, and a housing development at Baginton would support
these expansion plans. RPS recommends that housing supply is focused in those areas where
there are important benefits to be gained where future economic growth is planned.
Site at Baginton
2.13 A residential-led mixed use development at Baginton could contribute sustainably to crossboundary
growth as required by the NPPF, and to meeting both Warwick District and Coventry
City's housing needs by delivering approximately 1,000 new homes either in isolation or as part
of the wider regeneration proposals for the area. The location of the site in relation to the
Gateway proposals is shown at Appendix 3.
2.14 Development at this location would also allow for new facilities and services to be provided,
making the best use of existing and proposed infrastructure. The site can be appropriately
phased over the Local Plan period to develop an available, suitable and deliverable urban
extension proposal.
2.15 The promotional document 'Land south of Baginton: A Sustainable Urban Extension' prepared in
2008 has previously been submitted to the Council and provides further details of how the site
could be sustainably developed.
2.16 In addition to this, extensive technical surveys in relation to flood risk, noise, ecology,
conservation and heritage, landscape, and highways have been undertaken of the site and
submitted to the Council, to demonstrate the site's suitability for a significant residential-led
development either in isolation or in connection with proposals for the wider area. An Air Quality
Assessment will also be undertaken to demonstrate the site's suitability for development.
2.17 RPS, therefore, considers that to help deliver greater sustainable development opportunities, it is
important that sufficient housing land comes forward in areas of proven market demand, such as on this Green Belt site to the south of Baginton, to contribute towards delivery of additional
dwellings and higher levels of growth to meet the needs of both Councils.
2.18 Responses to individual policies and topics within the Preferred Options consultation document
are included in the following chapter

It is submitted that Preferred Options has made insufficient provision of land to meet the full objectvely assessed requirements for housing.
The land edged red is suitable for housing development and should be allocated under the category of sites on the edge of Warwick, Leamington Spa and Whitnash. The site is available within the meaning of paragraph 47 of the Framework. The analysis of this land holding with the Strategic Housing Land Availability assessment is not accurate in the context of this parcel of land. Sufficient evidence has been submitted to demonstrate that this parcel of land is in fact deliverable in tht:
- The site is available now
- The site offers asuitable locatopn for development now and is achievable with a realistic prospect that housing will be delivered within five years. In particualr the site is viable
It is submitted that this land should be included within the sites for release within phase 1. The site extends to 3.12 hectares and could provide up to 90 dwellings.
The concerns identified in te SHLAA (site W12) related to a much larger area of land. This site is sufficiently distanced from the M40 as not to suffer from unacceptable noise disturbance or air pollution. The land lies outside Flood Zone 3B and is not within the Cordon Sanitaire of Longbridge Sewage Works

Letter and representation form attached electronically.

I am very concerned that the SHLAA used as the foundation for this Local plan does not fully identify the value of the North Leamington Greenbelt, particularly that land between Northumberland Road and Old Milverton. Indeed I believe the SHLAA does not equally consider all sites and considerably more effort has gone into identifying benefits of some sites in comparison to others. The whole document should be reviewed and as a consequence of this the proposed development on the Green Belt North of Leamington should be removed from the Local Plan.
I am further concerned that the Local plan places far greater importance (and indeed too greater an importance) on the policies of the Regional Spatial Strategy Policy in comparison to the National Planning Policy Framework. If appropriate importance was placed in the NPPF which is a more recent NATIONAL document, that is not due to become obsolete like the RSS, then the greenbelt sites to the North of Leamington would not be considered as suitable for development.