B. Affordable Housing on Rural Exception Sites

The additional support for including a proprtion of market housing in order to promote viability is most welcome. Future funding for Affordable Housing is likely to be curtailed in the short to medium term, it is therfore both desirable and realistic to engage the private sector to fill this funding gap - however they must be allowed to make a profit or nothing will happen!

"the scheme being located within, or adjacent to, a settlement with a reasonable level of services"

This is an easy excuse not to provide smaller outlying rural areas with further amenities such as sustainable transport and communication links.

Affordable housing must be built only where it meets local need. Anything more will only crate more transport problems of those who need to get to work, those who need to get to doctors dentists and hospitals or children going to school outside the village.

With regard to Warwick District Council's New Local Plan and Preferred Options: I support the numerous objections of the residents of Old Milverton, Blackdown and the views of Jeremy Wright MP in the Courier of July 20th. The source of WDC's evidence for future population growth was successfully (and evidentially) challenged at the Parish council meeting on 16th July. The NPPF is referenced by WDC's new Proposed Local Plan regularly but the content is selectively ignored:
Section 3 - Supporting a prosperous rural economy
* The development of this area will keep infrastructure developments in urban areas and ignore the employment and housing requirements of more rural communities.
Section 4 - Promoting Sustainable transport
* It will increase private traffic through areas used by families and schoolchildren and ignores the requirement for sustainable well-placed transport networks.
Section 5 - Supporting High Quality Communications Infrastructure
* It ignores the need for public transport and high-speed broadband in smaller rural areas.
Section 9 - Protecting Greenbelt Land.
* It dismisses the high value of greenbelt land directly in contradiction of the NPPF.

I refer you to the foreword in the NPPF and its Core Planning Principles. Please follow the requirement of consultation by acting upon the objections of members of the local community with as much vigor as you have done with landowners and development firms. Most of the developers and landowners, particularly in Old Milverton, do not live locally. Financial gain on their behalf does not come with a qualitative cost.

Contrary to Councilor Doody's apparent advice of the 16th of July this year, I will be sending copies of this letter and its objections to my local Members of Parliament. I do not share his alleged opinion that my elected political representatives and their governing processes are a waste of time. I have attached further explanation of my objections below.
Section 9 - Protecting Greenbelt Land.
The area of greenbelt on which development is proposed was identified as such in the last local plan. It was confirmed as of high value by WDC's study of greenbelt not very long ago.
To develop this greenbelt area is to poorly site several thousands of residential houses at the opposite end of town from their road and rail links, main shopping sites and other amenities.
The proposals are contrary to the National Policy Planning Framework's Guidelines on Protecting Greenbelt Land. 'Very special circumstances' do not exist. More suitable land with better transport and amenity links has been identified in south Leamington, closer to most of the aforementioned developments (including new development at the old Ford foundry) which is not green-belt.
The proposed local plan would destroy greenbelt land which for the most part is currently good, economically productive farmland with public access for recreation and provision of views, wildlife habitat, and a barrier for the protection of further farmland that currently prevents urban sprawl.
I hope that the council does not consider the financial gain proposed by development firms more important than the social, environmental and economic needs of its future residents or the benefits derived by current residents from the green-belt land.
Section 3 - Supporting a prosperous rural economy
The smaller villages surrounding Leamington Spa have become commuter dormitories due to lack of infrastructure development and withdrawal of services. The proposed plan will set in motion their complete assimilation into the greater urban area.
The proposed development areas in Warwick University, Coventry Airport and Stoneleigh Park would afford the opportunity for local employment to some of these villages and negate the need for a large, counter-productive block of development to service them. This has obvious economic and ecological benefits.
I agree with the NPPF that there is a need for controlled rural development, it is needed in order to arrest the decline of rural communities, not to write them off completely and leave them years behind their urban cousins in order to maximize on private industry profitability.
Section 4 - Promoting Sustainable transport
Traffic on the Old Milverton and Kenilworth roads is already significant. The proposed northern relief road will do nothing but compound the poor placement of houses and park-and-ride by increasing traffic from north Leamington, through Old Milverton and through housing estates in Milverton where it already conflicts with pedestrian traffic of school children. Flow the other way will increase traffic from north and west Leamington to transport links off the A46 through the same areas.
Expanding the existing Kenilworth-Leamington road to dual carriageway will have a massive impact on long-standing greenbelt and increase traffic from the A46 through Blackdown towards Stoneleigh-park and the routes above.
Development should be concentrated to the south of Leamington keeping the destinations of park and ride nearer to the rail links in Leamington and Warwick, motorway links, shopping, amenities and better transport links which all exist to the south.
This approach would support the NPPF's aims whilst allowing for the larger developments to be focused on land to the south of Leamington and other already brown-field sites. It would also add to the revitalization of Leamington's old town.
Section 5 - Supporting High Quality Communications Infrastructure
The proposed plan states that it has chosen to concentrate development in areas where transport, amenity, communication and recreation already exist. This is clearly not the case as the infrastructure developments in the greenbelt area are huge. They are designed solely to support the proposed expansion of the urban area.
The proposals contain no mention of improving transport infrastructures such as bus, and cycle routes outside of their urban expansion; no mention of high-speed broadband in outlying villages (particularly in green-belt) and only a slight nod in the direction of community led housing - without attempting to include affordable rural housing.
Green-belt in this case is a rural environment; one which is protected for the good of the character, appearance and health of the towns it surrounds. It also contains a working populous who are to be penalized for the sake of convenience and private company income.
One of these villages is now home to 3 generations of my family. I feel that providing a future for my children offering variety and opportunity rather than conurbation and limited options is something worth discussing properly.
Developments over the last 30 or so years have changed the face and character of this area completely. Their continuation is detrimental to the character, nature and vivacity of the area. I would hate to see The NPPF ignored to further add to the urban/rural division and creeping conurbation of the area inflicted by previous planning strategies.

Cubbington Parish Council have discussed the issues contained in the Local Plan Preferred Options published by the District Council and wish to make the following comments:
1. There are considerable concerns regarding the proposal to redefine the boundaries of the Green Belt around rural parishes, including Cubbington. The Parish Council strongly oppose this proposal as, potentially, it could result in the loss of large areas of highly valued countryside which have been protected from development for very many years. If it is eventually decided to proceed with this review, the Parish Council would expect to be consulted about any proposals to change the Green Belt locally. At all costs, the Green Belt controlling the use of the land between Cubbington and Lillington, bordered by Rugby Road, Offchurch Road and Welsh Road must be protected.
2. It is understood that 15 to 20% of the Blackdown development site, designated as Location 5 in the Options, comes within the boundary of the Cubbington parish. This could result in up to 230 dwellings being built on this area alone with the balance of 940 dwellings being built on the adjoining area within the parish of Blackdown. The Parish Council anticipate that this number of additional dwellings, with possibly in excess of over 3000 residents, will have a major impact on the local infrastructure and the social, leisure and shopping facilities in Cubbington. Therefore, should this area be approved for development, the Parish Council's view is that they must be involved in the detailed planning and decisions about how the resulting infrastructure levy will be utilised.
3. It is understood that Old Milverton and Blackdown Joint Parish Council will be making representations regarding the development proposals of this land and Cubbington Parish Council support fully the comments they will be making.
4. In November 2009 a report was published by the Warwickshire Rural Community Council on the outcome of a housing needs survey carried out in the parish. This indicated that there was demand for a small number of affordable dwellings to be built in the parish for occupation by people who had family links with other residents in the parish. A scheme was subsequently devised by the WRCC for seven affordable dwellings to be built on an area of land off Coventry Road. To make this scheme financially viable it was suggested that, if necessary, a small number of additional houses should be built for sale on the open market. These proposals have not yet been able to proceed due to funding not being available through the District Council. However, the Parish Council understand that the matter is now being pursued with the involvement of the Orbit Housing Group. The Parish Council believe that this scheme should be reflected in the Local Plan to help ensure that it can proceed.

The Parish Council support the Local Plan in principal; we have made reference as detailed below to the areas we feel directly impact our Parish.

The Parish Council would request the housing demand produced by the original survey be revisited to take account of the latest data available, such as the 2011 census results, the later figures from the births and deaths register and inward migration figures.

Also the Parish Council would like WDC to reconsider whether they have given sufficient weight to the unprecedented development in the area over the last few years, which, would make extrapolation of recent figures unreliable.

Comments on Preferred Options

P05 Affordable Housing
The Parish Council are unaware of any demonstrable need for local affordable housing, we do not have an infrastructure to support this type of development, such as public transport and community facilities, however, we are in the process of compiling a Parish Plan. With survey results from the local community imminent, we would wish to revisit our comments should results show otherwise

P07 Gypsies and Travellers.
The District Council has to identify a site for travellers within the district, which it has not yet done.
We currently have one unauthorised traveller site within our Parish, which is subject to an enforcement notice, the unauthorised site does not meet the specification laid down in the new Planning Policy Framework, nor does it meet any of the criteria set out in the Preferred Options. We need to emphasize this point so the Kites Nest site, does not become the default option for WDC in the absence of another site being identified. The Parish Council take the view that the whole area, including Coventry and Rugby, which currently have underused Traveller capacity, is taken into account in identifying potential Traveller sites.

P08 Economy
The Preferred Options has identified the old Honiley Airfield as an employment site; we would insist any new development be restricted to the existing planning consent - potential for currently 2,000 jobs.
We request WDC in analysing the need for employment development consider the recent changes at Haseley Manor, which as an employment site could not attract business to the area and is now in the process of being redeveloped as housing.

P01 Greenbelt
The whole of our Parish lies with in the Greenbelt and we would wish it to remain so, if appropriate we would also wish our Parish to be designated as a "green wedge", providing a significant buffer between the conurbations of Kenilworth, Warwick, Coventry and Solihull.
We have a myriad of extremely well used Footpaths, Bridleways and Cycle routes; we wish these to be preserved as an important area for leisure and recreational activities.

We do not wish housing development forced upon us with the removal and restructuring of the Greenbelt boundaries, but we would support some sensitive infill development within our existing settlements.

P018
As a Rural Parish, we do not have any provision of storm drains to alleviate excess surface water and local road floods. We would wish WDC to revisit their strategy on the maintenance of ditches and gulleys and to also ensure landowner responsibility is enforced.

Thank you for giving the NFU West Midlands Region the opportunity to comment on the Preferred Options Consultation. The NFU is a professional body which represents the interests of 75% of all farmers and growers. Our views are on behalf of the farming and land management sector in general and follow discussion with local members.

It would be appropriate by way of an introduction to offer a few general remarks on farming and the planning system. Clearly food security is a key concern. On a global level it is of absolute importance that the world is able to feed itself; but it is equally important that food is produced in Warwickshire in order to meet our own needs.

The challenge in the 21st century is to increase productivity, maximise output, minimise inputs, achieve environmental sustainability and adapt to a changing climate - all of these challenges are ones which British agriculture is very well placed to meet. It is therefore vital that the planning system helps to ensure that farms can evolve and utilise best environmental practice in order to improve efficiencies and reduce carbon emissions. Our detailed comments on the consultation paper are set out below.

PO3 Broad Location of Growth
The NFU is very supportive of the policy of distributing growth across the District as it will facilitate some growth in smaller rural settlements in order that they remain viable and sustainable. We also welcome the assessment of the Green Belt. It is important to review the situation as the pressures and priorities for development do change. Altering the boundaries and removing some areas could have a positive knock on impact on the agricultural businesses located in these areas. It will give them more opportunities to evolve their businesses in order to remain viable into the future. We would like to enquire why the land south of Harbury Lane, Bishops Tachbrook has been designated greenbelt, as this will constrain the farmers business.

PO4 Distribution of Sites for Housing
We have not made a detailed examination of all the locations outlined in PO4. However, where sites are allocated for development the proximity of the land to existing agricultural business must be examined. Sites should not be allocated for residential development if they are found to be in near proximity to for example an existing livestock unit. We are keen to ensure that development in the countryside does not result in conflict between new residents and existing farm businesses.

The NFU welcomes the support in PO4.D. for rural workers dwellings and the conversion of rural buildings on the edge of settlements. When new dwellings are constructed for farm businesses it is important to ensure that they are able to cope with a range of functions. For example they will almost certainly require adequate space for a farm office and boot room. It is important to note that farming families do not have the option of moving house if they should outgrow their home and this must be recognised when planning new accommodation.

The reuse of redundant rural buildings is a key concern for NFU members. Many of these buildings are no longer suitable for modern agricultural uses for a range of reasons. Having no economic use often means that they fall into disrepair. Therefore in our view it is important that they are given the opportunity of a secure future through redevelopment for residential uses.

PO5 Affordable Housing
The NFU welcomes section B which will facilitate the development of affordable housing in rural areas.

PO8 Economy
The NFU welcomes policy that enables growth of rural businesses and supports the diversification of the rural economy. The NPPF states that "To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century". Paragraph 28 of the NPPF contains a very specific reference to supporting a prosperous rural economy; "Planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development". It also states that plans should "promote the development and diversification of agricultural and other land-based rural businesses".

PO14 Transport
The NFU is supportive of the policies aim to provide affordable transport options in villages and rural areas. Unfortunately at the moment there is often no viable alternative to car transport for people who live in rural areas especially if they wish to take up employment.
When considering transport and infrastructure you should be aware that farms and rural businesses are totally reliant on HGV and car transport. Any decisions to target employment away from areas reliant on the road network may have a negative effect upon the rural economy and restrict farm diversification. Tourism also relies on access by private car and new tourism enterprises must not be limited to sites that are accessible by public transport routes.

PO15 Green Infrastructure
Farmers already undertake a range of conservation management measure in order to improve environment quality and enhance biodiversity. This on-going work must be taken into consideration when considering development on farms. Therefore concerns about Green Infrastructure and the creation of Green Wedges should not stifle rural and agricultural development. As we said in the introduction it is possible to increase agricultural productivity whilst continuing to reduce the industry's environmental impacts. By working with farmers and landowners even more can be achieved.
We are concerned by biodiversity offsetting where off site mitigation measures are required. We would welcome the opportunity to discuss how you envisage this working in Warwick District.

PO16 Green Belt
The NFU welcomes the support for farm diversification and rural affordable housing in Policy PO16. These businesses have an essential role in maintaining the local landscape by grazing livestock, maintaining hedgerows and participating in agri-environment schemes. Farms in Green belt areas may need to invest in new buildings or other infrastructure as animal welfare and environmental requirements change. They may also need to diversify their businesses, perhaps by supplying local produce through farm shops. We are also supportive of the flexibility demonstrated in this Green Belt policy as alterations in the boundary must be made in order to support rural development. These changes will help agricultural and rural businesses in the affected areas to develop and evolve in order to ensure their long term viability. However when considering boundary change it is important to safeguard productive agricultural land and it is usually preferable for grade 3 land to be identified for development.

PO18 Flooding and Water
The growth allocations outlined under PO4 will place additional demands on the natural resources of the county. Farmers have a particular interest in this issue as new development will impact upon the surrounding agricultural land. New development sites should have land earmarked for SUDs and green space so that runoff can be captured and managed. We therefore broadly welcome the policy but urge the council to thoroughly investigate these impacts to ensure that adequate water resources and drainage capacity is available to cope with the new demands placed on the District's natural infrastructure.

I hope that you find our contribution to the preferred Options Consultation useful. The NFU is keen to assist the council with the development of planning policy so if you require further information or clarification of any of the points raised in this response please do not hesitate to contact me at the West Midlands Regional Office.