16. Green Belt

16. Green Belt.
The Green Belt is, as stated, a unique planning policy to avoid ribbon development and the joining up of the urban landscape. In the current situation where climate change and the ending of easily available light oil (known as Peak Oil) is already changing the face of our society, it is essential that the land be judged not on whether it is Green Belt or White Belt (unprotected) but on whether it is quality agricultural land. In the coming years we are going to need every square metre of agricultural land to feed ourselves.

Evidence for "exceptional circumstances" has not been provided.

Kenilworth, north Leamington and north Warwick might be better off if the WDC's Local Plan was declared unsound. The NPF would apply, and this would preclude development in the green belt if non-green belt land were available.

Strongest objection to any alteration to green belt, this must not be allowed. It is there for a reason and there is no case to change it. Once the principle of doing this is established the barrier to further changes will be much reduced. it must not be possible to change green belt, the district willl suffer greatly from this.

Although it is pleased that the land of the Binswood Ex Serviceman's Allotment Society (The Society) is now excluded from the proposed devlopment land, the Society has a number of concerns about the designation of part of the North Leamington Green Belt as a site allocated for housing or mixed use development. The Society is particularly concerned about the land 'North of Milverton' but a number of the arguments set out below apply equally to the Blackdown' site.
At Paragraph 80 of the Framework, it is stated that Green Belt serves five purposes;
* to check the unrestricted sprawl of large built up areas;
* to prevent neighbouring towns merging into one another
* to assist in safeguarding the country side from encroachment;
* to preserve the setting and special character of historic town's; and
* to assist in urban regeneration.

The Green Belt between Leamington and Coventry and Kenilworth was established in 1975 as part of the West Midlands Green belt to prevent urban sprawl and the coalescence of urban areas. These objectives remain as the principal purposes of Green Belt in the Framework
At paragraph 83 of the National Planning Policy Framework, states that;
'Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan'.
The principal of change in exceptional circumstances is carried forward from PPG 2. A key statement in PPG 2 is that
'the essential characteristic of green belts is their permanence. Green belts are not intended to appear and disappear at the drop of a hat. 'Once the general extent of a green belt has been approved it should be altered only in exceptional circumstances'. Even the detailed boundaries of the green belt should only rarely be changed'.
As established Green Belt, the Association considers that the second sentence of paragraph 83 applies. and has seen no evidence in the Consultation documents that demonstrate such exceptional circumstances.
Any encroachment into the Green Belt is considered to render it less effective in achieving its purpose, in that it reduces the size of the buffer and it creates a precedent for its continuing attrition. It seems anomalous that we should be making the case for safeguarding to the body which should be doing its utmost to ensure safeguarding.
At paragraph 84 of the National Planning Policy Framework, it is stated that in reviewing Green Belt boundaries, 'authorities should take account of the need to promote sustainable patterns of development. They should consider the consequences for sustainable development of channelling development towards urban area inside the Green Belt boundary towards town and villages inset within the Green Belt or toward locations beyond the outer Green Belt boundary.
The Consultation Document, at 7.19, states that the sustainability appraisal of the options showed that focusing development outside the Green Belt had clear advantages associated with the provision of sustainable transport options and reducing the need to travel. Thus the proposed allocation of Green Belt land fails on the review criteria of paragraph 84 of the Framework. Equally it is clear that development of non-Green Belt land to the South of Leamington does meet the review criteria both in offering more sustainable transport options and in using locations outside the Green Belt.
Of the 12 core land-use planning principles set out in paragraph 17 of the Framework, the first states that planning should empower local people to shape their surroundings. The consultation into the core strategy paper elicited between 700 and 750 responses. Some 40 percent of respondents were against development in North Leamington and some 25 percent against development North of Milverton. The Council response, in perpetuating allocation of these sites, could scarcely be construed as empowering local people to shape their surroundings.
As part of the work on the BLAST response to the Options for Growth, a Bio-Diversity Survey was carried out by the Ecology Unit of Warwickshire County Council. This demonstrated that the allotment sites contained great ecological diversity including the rare and protected European Crested Newt.
An earlier ecological survey prepared by The Habitat Biodiversity Audit Partnership on behalf of the District Council describes the habitat of the land North of Milverton as follows
Although arable dominates this parcel of land there are numerous species of rich mature hedgerows which are valuable to many species as well as being important landscape features. The hedgerows create a network of wildlife corridors through the intensively-farmed landscape and help connect the other important habitats such as the river, strips of woodland, ponds, grasslands and wetlands.
The Society is proud of the diversity of its site; it encourages members to have regard for ecology in the way they work their plots and is deliberately not over vigorous in the maintenance of hedges and verges so as to sustain wildlife. The network of wildlife corridors outlined above is of great significance in the continuing viability of diversity on the allotments and a significant part of the network will be destroyed by the development of the Land North of Milverton. Wildlife generally is at risk from a variety of factors, most notably destruction of habitat and global warming. At PO 10, Built Environment, the Council sets out as an objective 'to protect, enhance and link the natural environment', it patently will fail to do so if it continues to promote development North of Milverton.

Given that 81% of the District is Green Belt and is likely to be the most controversial part of the plan, we would have expected the Green Belt and Green infrastructure sections to be given a more prominent position earlier in the document, rather than on pages 87 and following. Selective grouping of certain chapters could also help to provide more synergy. For example, these chapters are more closely related and could naturally follow on:

* Green Belt
* Green Infrastructure
* Built Environment
* Historic Environment.
* Climate Change
* Flooding & Water

* Housing
* Economy
* Retailing & Town Centres
* Culture & Tourism

I and my husband are vehemently opposed to any plan to develop the greenbelt between Kenilworth and Leamington. We believe it will seriously damage the quality of life of our families and of future generations. We believe that if new homes have to be provided then they should be built upwards in the form of attractive blocks of flats on unused sites in inner city and inner town areas.

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

Dear Sir

Following the consultation meeting at Old Milverton I would like to make the following points:

Why are even thinking of putting this development on Greenbelt land when other Brown and White field sites have not been properly investigated?

Old Milverton and Blackdown do not have the infrastructure for a development of this nature and it would extremely costly and disruptive to put this in place.

Much infrastructure is already in place south of the town.

Employment is mainly south of Leamington and practically none in the area where you are planning to build.

People's views should be heard - I hope you are going to listen to them and not present people with a fait accompli.

Why are you making these changes to the 2009 Core Strategy, which was carefully thought out, in contrast to these recent ideas which appear to lack any imagination or appreciation of this lovely natural area of countryside, which is a fitting divide between Leamington Spa, Old Milverton and Kenilworth. This is something that should not be lost for ever.

I do hope you will listen to the people you represent - you have a duty to do so.

Thank you.

Yours faithfully

Jill Wiglesworth

Having read the Local Plan for North Leamington I would like to register my objections as follows:

* Areas selected for development are Green Belt Land
* According to the National Planning Policy Framework principles - Green Belt Land should only be used in exceptional circumstances
* There are no exceptional circumstances - previously identified non Green Belt land within the district is available, sufficient for future housing needs
* We need to protect our local countryside wherever possible to conserve an important amenity & avoid urban sprawl

Please confirm receipt of this objection,

Yours sincerely

Margaret Bold

I wish to make an objection to the New Local Plan to build on greenbelt land on the under mentioned grounds:

1. Greenbelt land was so designated to preserve parts of the countryside around towns and it is wrong for local authorities to allow building on such land without demonstrating an exceptional case. Whilst the New Local Plan tries to justify the Council's proposal, it does not demonstrate exceptional circumstances. We need to see much more compelling evidence for ignoring available land which is not greenbelt.

2. The evidence given so far strongly suggests a "political" influence which is not what planning should be about. The people of this District did not vote for a Council that would put political expedience before existing planning guidance which is there for the benefit of everybody.

3. There is nothing in the National Planning Policy Framework to support such political decisions, so the District Council should abide by the principles of the NPPF and rely only on planning principles, which include greenbelt protection.

4. Indeed, greenbelt protection is to prevent urban sprawl which is precisely what this New Local Plan proposes.

I am writing to oppose the District Council's plans to develop on Green Belt Land as shown in their 2012 Preferred Options booklet. Nothing has changed since the 2009 Core Strategy, so there cannot be any justification for these fundamental changes now

Please listen to public opinion

I wish to register my concerns and objections over the proposals for the following reasons:
* Overall there appears to be over-provision of housing as projections have been based on a past period of exceptional growth. This growth is unlikely to be sustained and certainly a number of larger employers (attracted over the past 20 years or so) have now left the area.
* Green belt land should not be developed where there are other suitable areas available. There has been no demonstration of the "exceptional circumstances" necessary to build on the Green Belt (ref NPFF). Urban sprawl is being encouraged by the plans to lift the protection offered by Green Belt protection.
* The existing road infrastructure is unable to cope with present traffic flow at peak times and will be unable to support the new development.
* The proposed Northern Relief Road will mean a loss of even more Green Belt land
* The estimated cost of £28 million of the road will only alleviate traffic exiting North Leamington but create further loading on the existing town centre and link roads between Leamington and Warwick/M40 routes. This will divert
* The proposals will lead to the merger of Leamington and Old Milverton/ Kenilworth in the future.
* The area designated for development in North Leamington will be lost as an amenity for exercise and recreation.

One of the goals of the Government National Policy Planning Framework is to protect communities and Green Belt by giving powers to local people to protect the country side and green space they value.

For these reasons please consider the above comments before approving the current proposals.

I am writing to you to formally object to the proposed development in Old Milverton and Blackdown contained in Warwick District Councils' Preferred Options for the "Local plan".

I have a number of specific objection to both the basic nature and the scale of the Preferred Option as follows:

1) This land is used by my family and many of our friends for recreational activities - dog-walking, cycling, running, bird-watching etc. It is of huge value to the local community. My family use it virtually every day and meet people from all over Leamington when we do so. The impact the plan will have on people's general well-being cannot be underestimated.

2) This is Greenbelt land that serves a very specific purpose. I am sure that you must be aware the National Planning Policy Framework (NPPF) states that the Government attaches great importance to Greenbelts and that the fundamental aim of Greenbelt is to prevent urban sprawl by keeping land permanently open. The Greenbelt in Old Milverton and Blackdown fulfils the 5 purposes of Greenbelt set out in the NPPF and therefore should remain as open Greenbelt land for ever. These purposes are

* Prevents the unrestricted sprawl of Leamington to the north

* Prevents the merging of Leamington and Kenilworth

* Helps safeguard the countryside from encroachment

* Helps preserve the setting and special character of Leamington (a historic town)

* Helps urban regeneration, by encouraging the recycling of derelict and other urban land

3) There are other sites which can be developed that are not in the Greenbelt. These sites, which are mainly to the south of Leamington, were included in Warwick District Council's previous plan (the 2009 Core Strategy). Employment opportunities and infrastructure already exists here, and this land should be used in preference to the Greenbelt.

4) The building will completely change the nature of the small area of countryside left after the proposals are implemented, making it effectively unattractive and useless for any of its current users.

5) Communications links into the area will need significant changes and upgrades to cope with the massive increase in local traffic. The costs and general environmental impact for the areas surrounding will be considerable. The additional traffic will also make the current traffic issues seen on Kenilworth road into Leamington much worse - it will obviously be gridlock at busy times

6) Sites to the south of Leamington are significantly more suitable for building due to existing infrastructure and communications links. There is also a significant opportunity to develop "brownfield sites" rather than encroaching into Green Belt.

The NPPF states that Greenbelt boundaries should only be altered in exceptional circumstances. As there are alternative sites, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in Old Milverton and Blackdown and allowing development on this land.

Overall I also wonder at the integrity of the Council that has made this decision. It does not make any sense and the only reasons that logically come to mind are that there decision-making here has not been supported by the correct due diligence, or that there are some vested interests at play.

Please reconsider your Preferred Options.

I am writing to oppose the District Council's plans to develop on Green Belt Land as shown in their 2012 Preferred Options booklet. Nothing has changed since the 2009 Core Strategy, so there cannot be any justification for these fundamental changes now

I object to the proposed development in Old Milverton and Blackdown contained in Warwick District Councils's Preferred Options for the Local plan.

This land has great recreational value to the local community. It is enjoyed by many runners, riders, walkers and cyclists.

The National Planning Policy Framework (NPPF) states that the Government attaches great importance to Greenbelts and that the fundamental aim of Greenbelt is to prevent urban sprawl by keeping land permanently open.

The Greenbelt in Old Milverton and Blackdown fulfils the 5 purposes of Greenbelt set out in the NPPF and therefore should remain as open Greenbelt land for ever. It
* Prevents the unrestricted sprawl of Leamington to the north
* Prevents the merging of Leamington and Kenilworth
* Helps safeguard the countryside from encroachment
* Helps preserve the setting and special character of Leamington (a historic town)
* Helps urban regeneration, by encouraging the recycling of derelict and other urban land
There are other sites which can be developed that are not in the Greenbelt. These sites, which are mainly to the south of Leamington, were included in Warwick District Council's previous plan (the 2009 Core Strategy). Employment opportunities and infrastructure already exists here, and this land should be used in preference to the Greenbelt.

The NPPF states that Greenbelt boundaries should only be altered in exceptional circumstances. As there are alternative sites, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in Old Milverton and Blackdown and allowing development on this land.

Please reconsider your Preferred Options.

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.

We wish to object to the new local plan on the following grounds:

1. WDC has comprehensively failed to overcome, with your plans, the specific need to show that due to "exceptional circumstances" it is deemed necessary to build on Green Belt areas under the National Planning Policy Framework.

2. Furthermore, WDC has not proved a case that there is "insufficient suitable and available sites outside the green belt". On the contrary, WDC has already highlighted available land south of Heathcote and east of A452, Europa Way. WDC has chosen to ignore these two sites in your "Preferred Option Sites". We assert that WDC has taken this approach in order to "spread out" intended new developments. We strongly object to this on the basis that it is nothing more than a political policy when your responsibility in this matter should be governed solely by a planning policy. In short, the WDC "Preferred Option Paper" does not stand up to legal scrutiny in demonstrating the strict evidence required to develop Green Belt which is a core condition of NPF.

3. In addition, WDC has failed to put up a convincing case that it either understands or is aware of the substantial investment in infrastructure that would be required to support the development plans. Before any decision is reached, WDC should provide a comprehensive, detailed and fully costed summary of an infrastructure investment plan and how this would be financed.

Concluding remarks

Planners are notoriously known for producing population and demand projections which so often miss the mark. On the basis of our above objections, we have very little confidence in your figures. If WDC has got the above 3 points glaring wrong, why should it be reasonably expected of local residents to simply accept your over-all future projections upon which you base the new local plan.

Finally, as planners, you have an important responsibility to avoid the merger of existing living locations and spaces into single larger urban areas unless there are exceptional reasons. For example, your plans clearly threatens the current status quo of Leamington Spa, Old Milverton and Kenilworth which maintain their unique characteristics as separate entities. In addition, a great deal of the land that you would consume to the north of Leamington is used for recreation, walking and enjoyment of the countryside. If you choose to develop the greenbelt, this will no longer be the case although you would have failed to demonstrate with your new local plan that you meet all of the conditions and requirements laid down by National Policy before you build on Green Belt.

Scanned Letter

Town's Position
Kenilworth is situated in close proximity to the boundary of Coventry and in places, the Green Belt is less than 600 metres wide. The protection of the Green Belt as a whole, and in particular on the Coventry border, has always been a matter of great importance to the Town Council and it has made this a priority over a number of previous Local Plan consultations.
The population of the Town has grown by 140% in the last 40 years and this has led to the whole of the available land within its boundaries being used for additional housing. This has included in recent years land zoned for employment, as the District had accepted that there was no demand for some of the existing employment land.
Given the tremendous increase in population and the lack of demand for employment land, it was the view of this Council on the previous (subsequently withdrawn) consultation on the preferred options, that there was a clear case for there being no further development within the Town. This was vitally important, as any development that was allowed had to be on the Green Belt surrounding the Town. Those arguments are, we believe, still valid, especially as it is apparent from the Options paper that there are areas of land within the District that are not within the Green Belt, but which it does not intend to zone for development.
The Preferred Options do include land available for development that is not within the Green Belt. It is the Council's view that this should be reflected by requiring the phasing of developments to ensure that non Green Belt land is developed first. In this way, the existence and benefits of the current Green Belt would be extended.
District Council Position
The Town Council does, however, recognise that the District has put forward arguments, supported by the SHLAA and SHMAA surveys, that the Town does require now, and in the next 20 years, a certain amount of housing and employment land, for it to remain sustainable and viable; these will inevitably be in the Green Belt. It further appreciates that, if such developments were to be allowed to proceed, then it is necessary and essential that these should be carried out in the right place and subject to regulation that would enhance the Town and not damage it.
It is further aware, and accepts that it is the view of the District Council and the surveys carried out, that this would mean the addition of some 700/800 houses and provision for employment land and that it proposes that this development should be in the Thickthorn area.
Town Preferences
So that it assimilates better into the Kenilworth community, it is the Town preference that development of such magnitude should be distributed instead of being concentrated on one site. Such an approach would also assist in alleviating the disruption to the town's infrastructure that the planned block development would create.
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With this in mind, we have considered a variety of sites within the Town and since the areas available are all within the Green Belt, have tested those sites on the basis that the following requirements should be met:
1. It must be capable of being protected from further extension by having clear and defendable boundaries.
2. There should be clear separation from any other urban areas so as to avoid ribbon development.
3. It should be capable of having easy access to the Town.
4. It should complement the local community and not form a separate entity.
We applied these tests to the sites we had identified. Overall, we concluded that they would suffer from the major problem, not only of incursion into the Green Belt, but also of lacking defendable boundaries for the future.
Preferred Option Land
We also considered the Thickthorn site on the same requirements basis as described above.
This site has for many years been in danger of exclusion from the Green Belt. On all previous occasions, development has been opposed by the Council because of the danger of opening up the whole of the area bounded by Kenilworth, the highway and Stoneleigh Road.
Our view in regard to this site was as follows:
1. The northern extremity of the proposed development area is shown as the northern boundary of the Wardens Cricket Club. This was felt to be too far in a northerly direction, whilst there was no clear and defensible boundary to protect the Green Belt from further incursion to the north.
2. It would result in the loss of the Cricket Club and Rugby Club and its four training pitches, with the need to relocate them in the Green Belt if they are not to be lost to the Town.
3. This would also effectively double the loss of Green Belt in the Town area if, as we would wish, they were relocated adjacent to the Town.
4. The roads serving this area are subject to considerable congestion now. The addition of perhaps 700/800 houses and business use would add considerably to an existing problem, especially at the Thickthorn Junction, which is a major access point to the Town and its main connection to the dual carriageway.
Whilst we would not wish this area to be developed, we appreciate that the District has this in mind and, if development is to take place in that area, then it would be essential that:
1. The development should terminate at Rockey Lane in order to have a clearly defensible boundary.
2. This would allow the Rugby Club to relocate its number one pitch and Club house to the Cowpatch (being the field to the north of Rockey Lane) and the Cricket Club to
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remain in its current location, which it is understood, would be the Cricket Club's preference. These two grounds within the Green Belt, together with Rockey Lane, would then serve as buffer to development, as well as providing for open space and retaining the very important sporting facilities they provide for the Town.
3. We are aware, however, that the Rugby Club would have difficulty in relocating all of its facilities onto the Cowpatch.
4. If, in those circumstances, it was felt that the inclusion of the Cowpatch should be allowed then the protection of the Green Belt required by the Town Council could be obtained by the dedication of a public open space adjacent to the Cricket Club's southern boundary. This would not only protect the Green Belt but also act as protection to the Cricket Club from being too close to housing.
5. The inevitable traffic congestion at the entrances to this area require very specific planning provisions and, without definitive assurances in the Plan not to increase vehicular movements along Glasshouse Lane West and Birches Lane, then the Town Council would object to the site as a whole
6. There would be a clear need for road improvements at both the Leamington Road and Dalehouse Lane junctions to ease traffic flows. These would need to include the widening of Leamington Road, certainly in the area of the junction, and perhaps the widening of the slip road into the junction, allowing for traffic from the new estate direct access to the highway. Likewise, careful attention would be required at the Dalehouse Lane junction in order to have the same effect and the provision of an island should be considered to ease traffic flows at that access point. Having regard to the importance of these matters, it should be a condition of any development that the road works are carried out in accordance with traffic surveys and a modelling of the effects of the development should be carried out in advance.
7. The internal roads and infrastructure of the area will be equally important. Having regard to the size of the proposals there is a real danger of it being developed piece meal and by different developers. This could lead, as elsewhere in the Town, to the overall theme being distorted. It should therefore be built into the Plan that there should be an overall planning brief agreed before any development is started and that this shall be carried through.
8. Any development on the site would need to meet the requirements of the Plan for Garden Town type layouts, together with the need for the provision of open space, and a road layout that complements these requirements.
9. We feel it will also be necessary to make provision for a Primary School. For the purposes of safety and sustainability, this should be within the site thus allowing children to walk to School where possible.
10. The Local Plan presents an opportunity to include an Inset Plan that takes into account all these requirements. The Planning Department of Warwick District Council should provide a brief on the basis of these requirements, which should form part of the Plan, to assist in the development of the site as part of the local community and a complement to it.
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Effects on the Local Community
These must be taken into account, as the presence of the Town and its facilities are the main reason for making this area so attractive for development and will have a huge effect on its value.
In these circumstances, it is essential for facilities to be expanded and improved to cater for the new development as well as easing the strain on those already existing. This requirement will not only benefit the existing community, but also conserve those facilities and make the Town more attractive.
With this in mind we would expect that funds arising from the development should be provided to help the aspirations of the Town for the expansion of the Civic Centre to include all facilities, including a Theatre.
Further the introduction of 700/800 houses, whilst making the Town Centre more viable, will increase the burden on the Town Centre car parks and would merit the construction of a car park similar to the Waitrose model, namely one and a half storeys.
It will also require the provision of addition medical services by way of at least one more Doctor accompanied by the nursing services that the Surgeries now provide. This will mean that both surgeries serving the Town will require some extension. There will also be further pressure on the Clinic, which will require enhancement to enable it to serve the additional population.
The Rugby Club
The Rugby Club is a very valuable asset to the Community and if it is to be relocated then it is essential to the community that this is adjacent to the Town. This could provide an opportunity for the District to make provision for it at Castle Farm. The opportunity for joint working with the Club could provide an enhanced sporting offer that not only includes Rugby and the current pursuits, but also an Athletics Track. There would be a need to increase the area of the sports centre and this would fall within the Green Belt. It would, however, be immediately adjacent and accessible and to some degree within the Town. The increase of this existing use within the Green Belt would complement the Town.
Open Spaces
There is a need to increase the area of accessible open space within the Town. This is a matter that must also be addressed within the Plan. Whilst the Abbey Fields and Castle Farm and the Common give an impression of the Town enjoying a great deal of open space, Kenilworth does not enjoy as much open space as the other Towns within the District. Even taking into account the Play Area at Burton Green and Crackley Woods, both of which are outside the Town, the area available per 1000 of the population is 4.42 hectares as against the District average of 5.46 hectares and the Proposed Minimum Standard in SPD of 5.66 hectares.
Allotments
The Town and its Community enjoys several allotment gardens that not only provide an ability to grow vegetables and fruit for home consumption, but also the opportunity to enjoy outdoor exercise and recreation, whilst at the same time providing an additional open space for the community.
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The allotments are invaluable to the town and extremely popular, confirmed by the waiting list of 200 applicants, despite additional plots being provided in the last few years. It is essential therefore that an allocation of allotment land be found within the plan to meet and encourage this demand, especially as it will provide the further benefit of further open space.
This problem must be addressed in the new development and for the Town as a whole in the Plan. The provision of additional open space at Castle Farm would be a very useful additional contribution.
The Mere
We are awaiting the results of the feasibility study for the renewal of the Mere adjoining the Castle. This exciting project, adjoining an internationally recognised heritage site, would bring increased economic benefit into the area, as it would make the Town a National Tourist attraction with its Castle and Mere. Further, the additional amenity would enhance the open space available to the community and visitors.
Abbey Fields
Overview. The Abbey Fields are and have been for many years an invaluable centre for peaceful, open-air recreation that is easily accessible from all parts of the Town. We would stress that any Plan affecting the Town should ensure that no encroachment should either be allowed or envisaged. It was, and always has been, used for recreation for the community and children and any intrusion will conflict with those uses. No vehicles or cycles should be allowed within its confines other than for the provision of essential services or maintenance.
Cycle Routes through Abbey Fields. The Town Council would object strongly to the provision of a cycle route through the Fields, as this is contrary to the use envisaged for the fields since they were dedicated to the Town. Furthermore, it would be contrary to the byelaws that currently protect them from such use and which were imposed for the sites protection. Any such intrusion would inevitably conflict with people using the paths and the many children seeking recreation in the Fields; it would be impossible to police from abuse.
The Abbey Fields Play Area. The Council would, however, see some elements of evolution of the current usage as being advantageous and in keeping with the original grants. The Children's Play Area is in need of renovation, as is accepted by the District. When this is able to proceed, it is suggested that this would be an ideal time to reposition it on the bowling green area, which has been redundant for many years. This would provide a secure area for the Play Area and the existing Pavilion could be used as a shelter for accompanying parents. A further benefit of the secure area thus provided would be the exclusion of dogs from the play area.
The Play Area released by this relocation would allow for the expansion of the picnic area adjoining and the provision of a more formal site for the periodic Band Concerts. This would provide a better facility for the community and its visitors and be a better use of the Fields without in any way damaging them or being contrary to the original gift and purpose. It would also enhance the setting of the Barn Museum and improve it as an attraction.
Abbey Fields Car Park. The Town Council has considered and approved the proposed resurfacing of the car park in the fields, subject to such work complying with the advice of English Heritage to protect the underlying monument, and work being included to protect the trees in the Lime Walk.
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The trees form an invaluable asset to the Fields. Relocating the boundary of the parking area away from them and releasing the compaction around their roots caused by parking will improve their life span, although this raises the issue of their age. During the currency of the plan, preparations must be made for their replacement and the preservation of this beautiful part of the Abbey Fields. This should form part of the Plan, as the future of the Walk must be assured for future generations.
The existence of the car park does, however, affect the drainage of the meadow below it and this must be addressed. The meadow below, a very important part of the fields, currently suffers from bad drainage and frequent flooding. This must be improved to increase the recreational use of the area.
Civic Centre
It has been the joint wish of the Town and the District Councils to develop a Civic Centre in Smalley Place. This has begun to take place over the last few years with the relocation of the One Stop Shop to the Library and, latterly, the Town Council, MP, and Town Centre Development Manager, as well as the local Safer Neighbourhood Police Office, to Jubilee House.
It is the clear desire of the local authorities that this process will continue, in the hope that all the services required by the Public shall be available from that site or at least accessible. Further, we would like to see the relocation of the Talisman Theatre to the same area on the basis that this would also provide a venue, not only for the theatre, but also perhaps for use as an occasional Cinema and Meeting Hall in the centre of Town. The relocation of the Theatre would also provide a site for further housing.
There would also be the opportunity for the relocation of the Clinic into Jubilee House. This would provide patients and staff with enhanced accommodation and at the same time release its current site for redevelopment in accordance with the overall plan for the centre. An arrangement of this type would be in keeping with the objective of providing all services to the Community on one site and at the same time would lead to cost savings for the public purse.
This plan would, in our view, be an ideal project to seek support from the monies arising from the developments envisaged in the Local Plan. These facilities will complement and improve the facilities that the Town already enjoys, but would also be available to the persons who relocate to the new areas of the town.
Fire Station
The provision of employment land at Thickthorn could perhaps provide an opportunity to relocate the Fire Station as its current situation is not ideal. Its relocation at Thickthorn would provide an opportunity to build a full-time Station that would be easily accessible to the whole District along the existing and adjacent routes. This would be an advantage to the public purse as this could easily serve the whole District and release the current sites for other purposes.
Schools
As mentioned previously, it will be necessary for a Primary School to be provided for the children of the 700/800 houses likely to be built on the site and this must be provided within the development.
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There will also be additional pressure on the Secondary School at Kenilworth School and it will be necessary for this to be enhanced for that purpose. Kenilworth School is presently housed on two sites, with the Sixth Form located in Rouncil Lane. This might, therefore, be an opportunity for the Sixth Form to be relocated to Leyes Lane and the other site utilized for housing, as it has access already on to local roads and much of the school site is not used. The income generated would provide an opportunity to reinvest and enhance our Secondary School.
Further, the release of this area for housing would compensate for the loss of the area from the Cricket Club from the Preferred Option Plan area.
Railway Station
Finally, Kenilworth has a population in the region of 25,000 and as such must be one, if not the only Town of this size in the country, which does not have the benefit of a Railway Station. Warwickshire County Council has prepared a strong business case for the reintroduction of a Station upon the former station site at the junction of Waverley Road and Priory Road. The additional population that will result from the new development proposals can only strengthen the case already made for a new Station; the Council feels strongly that the suggested site should be included in the Plan. Additionally, it should be shown as a major objective of the Plan and an essential part of its future sustainability.

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.

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.

Letter and representation form attached electronically.

I am emailing to express my concerns over recent announcements for proposals to develop certain green belt areas.

Whilst I agree wholehearted there is a need for more housing in the area, I cannot, agree that the proposed sites are the most suited.

I am Leamington born and bred, I was an estate agent in Leamington when Warwick gates was released for sale, and feel I am well informed as to where there are suitable sites to be developed.

I cannot agree on these proposed sites being the most suitable, knowing the area as I do, and will strongly fight any decisions made that will allow the proposed sites to proceed.

My name and details are below should the need to contact me arise.

Meanwhile myself and my family will continue to follow any announcements that may be made.

I do hope these ludicrous plans are forgotten very soon.

I am emailing to express my concerns over recent announcements for proposals to develop certain green belt areas.

Whilst I agree wholehearted there is a need for more housing in the area, I cannot, agree that the proposed sites are the most suited.

I moved to Leamington from Blackburn 21 years ago, one of the reasons, for the town being such a beautiful one. You are only going spoil this if you develop on these greenbelt areas. We have a dog and small children where we actually walk along these paths that you are talking of demolishing. reconsideration for the original plans must be looked at.

I cannot agree on these proposed sites being the most suitable, knowing the area as I do, and will strongly fight any decisions made that will allow the proposed sites to proceed.

Meanwhile myself and my family will continue to follow any announcements that may be made.

I do hope these ludicrous plans are forgotten very soon.

I take an overall view of Green Belt throughout England and I think that an initiative to stop the spread of buildind on this land has to happen, and the sooner the better. More building means more concrete, more commercialism, more cars, more pollution the nett result of which people will have less time for one another which is already happening to an uncomfortable degree. I am
72 and have already seen
this happening with the result that families are more 'split' today than they were in my youth.

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.

SACRIFICE OF GREEN BELT LAND

The National Policy Planning Framework was crafted to halt the problems of unpopular local plans.

A clear goal of this framework is to protect Green Belt, transferring the control around this to local people. The national guidelines are very clear; they state that there need to be very exceptional circumstances for development to be sanctioned for Green Belt.

The Council has failed to provide the evidence to demonstrate why we have reached these exceptional circumstances.

The estimation of the amount of housing in particular is flawed and based on the rate of growth from the past; the proposed areas for development are a huge over-estimation.
Green belt land should not be developed when other suitable land is available. Other suitable land has already been identified on available land east of the A452 and south of Heathcote. These sites already have the appropriate infrastructure to support these locations. None of these sites, however, are included in the Preferred Options paper. There is also non-green belt land identified in the consultation documents suitable for development which is being ignored in pursuit of the Green Belt sites.

The two proposed areas of Green Belt which are being proposed North of Leamington have no such associated infrastructure and will lead to merging of urban areas which is not supported by town planners.

The overwhelming point, however, is that the identified sites in North Leamington strongly meet the criteria for the purposes of Green Belt land and should therefore be protected from this or any other development.

There has been a suggestion that other green belt sites north of Leamington are to support a policy of 'spreading things around'. This of course is not a professional planning point of view, it is a political one.

The Council exists to represent local people and support Government policy. The protection of Green Belt outlined in such policy should be followed not sidelined. The Council has many choices and there are major consequences of those decisions which must be taken with a high level of quality, professionalism and integrity.... supported by concrete evidence.

I am amazed that this plan is proposed at all, for to me it seems wrong in principle and wrong in detail.
The whole idea of a Green Belt is that it is left green. As a resident living just off the Old Milverton Road, we do so appreciate the green areas either side of the road, and our grandchildren do so love playing in this area. surely it is not beyond the whit of man to find other areas such as round the railway station and industrial areas where housing may be built. In any case, why do this large number of houses have to be built in Leamington Spa in the first place.
The detail too, making a new road from the A452 to the A46, taking up much more land, and with apparent scant regard for the needs of both cyclists and pedestrians.
I do trust that major changes will be made to the Plan before it is passed,

PO1 Preferred Level Of Growth

In summary we agree with the option for the Local Authority to go for a moderate growth. There may be evidence to suggest that higher growth is required but in these challenging economic times and the practical and political pressure the Local authority will be under in making this decision, we believe the moderate growth option is a more realistic and such a pragmatic approach is likely to be achievable.

PO2 Community Infrastructure Levy

We support the idea to bring in a CIL.
One item that is missing from the document is any indication towards New Homes Bonus. This is something we would support as a revenue stream and serve to reinforce your support for Affordable Homes (paid on non s106 schemes only). Again the NHB could be shown to assist in the provision for extra care (under PO5)

PO3 Broad Location of Growth

We support the Preferred option for Growth.

PO4 Distribution of Sites for Housing

We support the establishment of new boundaries. RSL's would like to be involved in discussions with Parish Councils from an early start to dispel the myths around affordable housing and this could assist the provision of housing in these areas.

PO5 Affordable Housing

We agree with the 40% affordable housing on new residential developments with the exception where the scheme is to be delivered as a 100% affordable housing scheme, in these cases the properties can be dealt with under a separate planning condition .
We agree with the housing being held in perpetuity but we would draw attention for a balance. In many cases RSL's will need to show a level of asset churn. The asset however can be ring-fenced to be used soley for the provision of future affordable housing in the district.

In rural terms we support a certain level of market housing but it should be on a case by case basis given the likely high land and sales values generated in many of the District's villages

There is no reference to new Affordable rents. The document does refer to affordability however, but with no mention of the level of affordable rents and with many areas of WDC the level of rents can vary greatly within a 1 mile radius (Micro Markets) Therefore we would recommend some primary data in the document to support your arguments.

PO6 Mixed Communities & Wide Choice Housing

Employment is very high on everyone's agenda currently and there are many threads that tie housing/ construction to this. There are opportunities through apprentices and other work opportunities that can be brought about by new housing and this could be a opportunity to ensure this happens on future sites.

Homes for older people and the link to the Extra Care rented opportunities will remain difficult to deliver with the decline in grant funding form the HCA, & Warwickshire CC .

PO16 Greenbelt

Again we support the option for Green Belt but we would like to be involved in any discussions with parish councils or other interested parties to outline what is affordable housing and dispel any myths.

I am writing to state my opposition to the new local plan which appears to completely contradict the proposals set out in the previous local plan of 2009. Land identified for development then is still available. Now there is to be wholesale development of the green belt north of Leamington Spa and Warwick when this does not seem to have any justification. What are the exceptional circumstances which are supposed to justify such a development? At the meeting I attended at the Warwick Society the only explanation put forward by the planning officer and councillor present was that it would be more profitable for developers! This seems to me to be outrageous! The land previously identified in 2009 is still available and would be easier to develop with existing infrastructure such as roads and access to the M40.

The new proposals impact on areas of Green Belt land which have a high value in preventing urban sprawl between Kenilworth and Warwick/Leamington. Once violated the Green Belt between the historic towns would be liable to repeated further incursions by planners and developers as the principle that Green Belt land should not be built on would be broken forever. The countryside would no longer be protected from encroachment. In the case of the proposed development on Loes Farm the green lung for Woodloes would be lost and the establishment of "parkland" in the remaining space would be like creating a green desert. The amenity value of Woodloes Lane would be destroyed for the runners, walkers and cyclists who now use it. The lane is part of the Millennium Way which is supposed to be a scenic path through the Heart of England! The phase 1 ecology survey of 2008 states unequivocally that this is a special area! What "exceptional circumstances" justify its destruction? The woodpeckers both green and greater spotted which breed here will be disturbed and displaced. There are at least 2 species of bat, great crested newts and a wide variety of birds, with sparrowhawks and buzzards indicating the health of the wildlife pyramid here, all of which merit protection!

Access to the Loes Farm site is proposed from Primrose Hill where it will scythe through ancient hedgerow. The new junction or roundabout will clearly lead to more traffic exiting and entering Woodloes Park onto either the A429 or the Birmingham Road when traffic is already a problem there! The police speed check is sited at exactly the place identified for access indicating police concern about traffic trough the estate at precisely this point.

The new houses at Loes Farm would be seen from the A429 on the hill overlooking the road and would hardly maintain the historic character of Warwick. It is this hiil which effectively screens existing houses from being seen from the Coventry Road. Crossing the road and walking on the footpath to Milverton would presumably lead to more new houses and a new road built on difficult, expensive terrain over the River Avon floodplain. I don't believe that £28 million is a justifiable expense for an access road. Surely any new roads required south of Leamington would not need to be built on flood plain and be much cheaper. I would support development on the former Ridgeway School site although this will again lead to more traffic entering the A429 Coventry Road as this is a "brownfield" site.

The proposals also include "out of town" retail developments threatening the survival of the central shopping areas in Leamington and Warwick. Shops, including excellent independent ones, are clearly struggling at the moment in both town centres. Would it not make better sense to help and encourage town centre shops? I intend to look carefully at the proposals for Warwick town centre because of this and comment in due course.

Finally, the number of houses proposed seems excessive. More than 11,000 new homes for Warwick and Leamington when Coventry, which is 3 times our size is only proposing 17000? Stratford district is only proposing 8000 for a similar area to our own. Why has a buffer of 1400 extra homes been included? Surely this indicates excessive development when new homes already built cannot be sold! I sincerely hope that my views will be taken into consideration and not consigned to the bin as inconvenient.