Mod 1 - Policy DS2

It should not be a priority to meet unmet housing needs from outside the area. This will simply encourage people with jobs elsewhere to live in the area, increasing commuting to work with its consequential impact on the environment and traffic problems locally

The draft local plan does not meet the criteria of "Exceptional circumstances" required to develop this Green Belt land.
The argument that the only land available is in Old Milverton is incorrect. The additional housing required to assist Coventry meeting their targets should be located closer to Coventry. The distance for commuters would increase pollution.
Sufficient land is available at a reasonable rate on the environs of Coventry that can be used without affecting the Green Belt of Old Milverton.
Therefore the Exceptional Circumstances requirements have not been met. The Local Plan significantly underestimates the capacity of land adjacent to Coventry to deliver Coventry's housing needed and therefore the development in Old Milverton is not required.
In a similar case in Cheltenham and Gloucester the Planning Inspector ruled that when releasing land from the Green Belt the "Green value" of the land should be rated and the least Green rated be removed first.
WDC and Coventry City Council have assessed the sites on the edge of Coventry and agreed that they are of a lower Green Belt Value.
Therefore the lower green belt value land should be released for the Local Plan and not Old Milverton land in North Leamington.

The Green Belt has been very effective in preventing Leamington joining with Kenilworth and Warwick. It thus does the job it was designed to do and assist in preventing the area from Wolverhampton to Leamington becoming one metropolis.

The WDC has complied with the duty to work with other local councils (Coventry City). In doing so it has not reacted the information that is included in the Coventry City Local Plan. Cooperating councils should provide housing land close to Coventry. Old Milverton is not close enough to Coventry to support the additional housing needs.

Ref: Old Milverton Lane Development.
The draft local plan does not meet the criteria of "Exceptional circumstances" required to develop this Green Belt land.
The argument that the only land available is in Old Milverton is incorrect. The additional housing required to assist Coventry meeting their targets should be located closer to Coventry. The distance for commuters would increase pollution.
Sufficient land is available at a reasonable rate on the environs of Coventry that can be used without affecting the Green Belt of Old Milverton.
Therefore the Exceptional Circumstances requirements have not been met. The Local Plan significantly underestimates the capacity of land adjacent to Coventry to deliver Coventry's housing needed and therefore the development in Old Milverton is not required.
In a similar case in Cheltenham and Gloucester the Planning Inspector ruled that when releasing land from the Green Belt the "Green value" of the land should be rated and the least Green rated be removed first.
WDC and Coventry City Council have assessed the sites on the edge of Coventry and agreed that they are of a lower Green Belt Value.
Therefore the lower green belt value land should be released for the Local Plan and not Old Milverton land in North Leamington.

The Green Belt has been very effective in preventing Leamington joining with Kenilworth and Warwick. It thus does the job it was designed to do and assist in preventing the area from Wolverhampton to Leamington becoming one metropolis.

The WDC has complied with the duty to work with other local councils (Coventry City). In doing so it has not reacted the information that is included in the Coventry City Local Plan. Cooperating councils should provide housing land close to Coventry. Old Milverton is not close enough to Coventry to support the additional housing needs.

Removal of land north of leamington from the green belt is unsound for several reasons. It is reducing the clear rural definition between leamington spa and kenilworth towns, and spoils the approach in to leamington from the north. Access in and out of leamington spa along the kenilworth road is very congested especially at peak times, and I do not feel that the infrastructure could cope with the additional traffic that such a development would generate.

The removal of the green belt should be stopped.
The area provides a highly valued walking area that is used by 1000s of people as well as schools.
If Coventry requires more housing use the lower value land that is far nearer to the city and would not cause the congestion and infrastructure changes in Old Milverton.
Warwick District Council have not demonstrated the exceptional circumstances required to make the change to the green belt.
A park & ride built near to the A45/M40 junction would be more logical. People mainly work in the south of Leamington .

The removal of the green belt should be stopped.
The area provides a highly valued walking area that is used by 1000s of people as well as schools.
If Coventry requires more housing use the lower value land that is far nearer to the city and would not cause the congestion and infrastructure changes in Old Milverton.
Warwick District Council have not demonstrated the exceptional circumstances required to make the change to the green belt.
A park & ride built near to the A45/M40 junction would be more logical. People mainly work in the south of Leamington .

This development is to support Coventry City Council's housing requirement.The question of sustainability is very evident in this poorly proposed plan.
There are sites closer to Coventry that can be used in preference to the Land North of Milverton.
These would reduce unnecessary commuting and even greater traffic congestion than already exists.
The prospective purchasers of houses built on Land North of Milverton will buy them because they want to live in Leamington not Coventry. Hardly a solution to Coventry's housing problem.

The exceptional circumstances to remove Land North of Milverton from the Green Belt by Warwick District Council to provide Coventry City Council housing have not been met on sustainability grounds.
Development of the Land North of Milverton will lead to extra commuting and greater road traffic on roads already very busy. A totally unnecessary outcome.

For clarity this objection refers to:

Modification: Allocation of land north of Milverton for development

The proposed development is to support coventry city council,s housing needs. There are sustainable sites closer to coventry that should be used in preference to the land north of milverton to reduce unnecessary commuting inevitable congestion and further road construction

The plan is a local plan and should not be seeking to solve housing needs from outside of our district. Coventry should resolve its own problems and not build on green belt land which is several miles away from Leamington and of a lower value of green belt for planning purposes.

We agree with the Inspector that considerably greater provision for new housing must be made - in part to meet unmet need in the SHA; in part to assist with meeting unmet need across the Region; and, fundamentally to provide a substantial and deliverable degree of flexibility should site allocations not come forward as expected. Past performance has not met promised targets by a large degree as Councils have sought to restrict land allocations to the minimum degree necessary.
This may be understandable but is nevertheless unjustified. In order to meet the over-arching objectives of the NPPF, a basic minimum requirement is that clear and deliverable flexibility must be built in to not just meet but also exceed stated targets and deliver essential development through the presumption in favour of sustainable development.
By way of example, the Birmingham Development Plan identifies the need for 37,900 houses to be supplied in Authorities outside its own area. The means by which these are to be supplied is not specified but it is suggested that additional focus is required both in the SHMA AND in neighbouring Authorities. It will NOT be acceptable just to say that discussions are ongoing as a means of complying with the Duty to Cooperate and actually supplying the needed homes.
It is not considered that
● there is a sufficient degree of flexibility in the modified Plan to ensure that housing requirements are met, and
● the sites which the Council have identified to meet their estimated need are neither the most appropriate nor the most sustainable.
● As a result, it is suggested that the Plan is still not "sound" in terms of being positively prepared, justified, effective or consistent with national policy.

Coventry's local plan pledges to provide 'new housing which delivers the quality and mix of homes needed including
Affordable homes
A mix of homes to meet identified needs including homes that are suitable for elderly and vulnerable people'

The land that has been identified is in Leamington and its distance from Coventry certainly would not support elderly and vulnerable people or affordable homes.

The most sustainable location to meet Coventry's needs has not been quantified and the broad locations have not been identified on the proposal map

There is no adequate infrastructure and no sustainable development has been identified. The proposed park and ride scheme into Leamington would not provide any useful links for Coventry. Furthermore the impervious surface of the car park will reduce the area's ability to absorb rainfall and contribute to flooding.
A railway station is not viable - the railway line is in a deep cutting in Old Milverton

The modification does not identify and use land of lower grade green belt land which should be used in preference to high grade agricultural land

It takes no account of the role of the area in providing a recreational and educational space at a time when the increase in disease and illness clearly shows that facilities for exercise and relaxation are important for all ages

No exception circumstances have been demonstrated that warrant the removal of high grade land from green belt

The proposed development north of Milverton is to fulfil the housing shortfall for Coventry, yet it is nearly 10 miles from Coventry
The exceptional circumstances required by the National Planning Policy Framework to remove the land north of Milverton have failed to be adequately demonstrated by Warwick District Council.

It is understood that the development is in support of Coventry City Councils housing need, yet there are suatainable sites closer to the City, than Leamington at nearly 10 miles away. Use of sites closer to the City will reduce the carbon emissions, congestion and infrastructure overload that will inevitably come with the north Leamington site.

Furthermore, people who want to live and work in Coventry are unlikely to be looking at purchasing houses in Leamington/North Milverton so this will not solve Coventry's deficit problem.

Precedence for releasing land from the Green Belt requires the 'value' of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC in co operation with CCC, has assessed sites on the edge of Coventry as being of lower green belt value.
Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green belt value that should be used in preference to the land north of Milverton.

The 'Green Lung' between leamington and Kenilworth will be little more than a mile.

Highly productive farmland will be lost along with long established wildlife habitats.

The local residents will be deprived of an area which is highly valued and sustainable for walking, running , cycling, bird watching and is used by the local schools for educational walks.

The proposed park and ride scheme is unsustainable because

In the absence of dedicated buses, users will have to time their journeys to co-inside with the bus timetable.

The site is too close to Leamington. If it was focused on the A46 roundabout with the A452 Kenilworth/Coventry/ Warwick and Warwick University people might use it.

Shoppers are unlikely to use the park and ride when there is plenty of parking already in Leamington.

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
 There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
 The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
 Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers
 Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
 Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
 There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

I question the Councils authority to 'agree' allocations with adjoining Councils without Consultation. I question the advisability of proposing to build on the Green Belt to meet allocation targets 'agreed' without Consultation

The Richborough Estates Partnership LLP welcome the efforts made by Warwick District Council to respond positively to the Inspector's interim conclusions concerning the level of housing which should be delivered by the Warwick District Local Plan.

Further consideration is given to the appropriateness of the objectively assessed housing need and the proposed housing provision as part of representations submitted by others. Accordingly, as part of these representations no comments are made by Richborough.

The proposed development is to support Coventry's housing needs.
There must be more suitable sites nearer to Coventry which could be used.
The need for commuting inevitable congestion and further road construction.

see attached

see attached

Consultation Response to New Modified Local Plan

We object to the modified Local Plan for the following reasons.

We now have a 6.4 year housing land supply. We note that last year's figures are to be revised by Mr. Barber.

The growth in the number of households remain exaggerated and unnecessary.

So much land has already been approved that the total number of houses will not be built for many, many years, if ever - land banking!

ONS figs show migration into Warwick District will probably be very much less than the JSHMA has indicated.

The NPPF requires 'sustainable development'. The three criteria of sustainability are environmentally, economically and socially sustainable. The development south of Warwick is not sustainable.

Infrastructure

The necessary infrastructure is not in place, nor is the funding to provide it, i.e. transport mitigation, schools, healthcare provision, police and fire and rescue, flood alleviation. There is little information on how this infrastructure can be provided. The Plan is neither sustainable nor deliverable.

The NPPF (17) states that strategies should "deliver sufficient community and cultural facilities and services to meet Local needs". Also (NPPF 162) "Local planning authorities should work with other authorities and providers to:
* assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demands and
* take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."

Yet you confirm that infrastructure will not be put in place before building commences but that you hope that infrastructure will be provided from developers' contributions, whilst admitting that this may not raise enough to cover escalating costs of new roads, bridges, schools, extra health provision, policing, fire service, community centres etc. If left to developers, history has demonstrated this may not happen. Infrastructure needs will then be prioritised and some areas may miss out. You have admitted that infrastructure proposals will be prioritised and there will be a cut-off point when the money runs out. We have seen no architects' proposed site plans showing each area with all the necessary infrastructure in place. You have provided no idea of potential costs at all. You have provided no results of studies at all. Warwick has already lost its police station and fire station, roads are completely congested at peak times, schools are drastically oversubscribed and have no places, the hospital is at breaking point and cannot cope with the load, having day surgeries, evening clinics and Saturdays to clear backlogs and lack of parking leads to innumerable late attendance for appointments, and the police haven't a clue how they can cope with more communities. Utilities such as water, sewers, electricity provision will have to be provided at escalating massive cost. The public sewer discharges to Longbridge Water Treatment Works. Severn Trent currently transport sewage from Longbridge to Coventry by tanker several times a day. They do not have the capacity now to deal with sewage at the Longbridge site and it is inconceivable how they will cope with sewage from another 4,000 houses in Warwick. How many more tankers will be required and at what extra cost?

Transport - Severe Traffic Congestion and Car Dependancy

Extensive sprawling urban development proposed will inevitably exacerbate car dependancy. The transport strategy is car-based, just squeezing more congested traffic on to the existing road network, bridges over the River Avon, and parking. Contrary to transport policies, it would make walking and cycling less attractive, and could not have good public transport. All traffic crosses river on 3 bridges - Castle, Princes Drive, Adelaide Road. Leads to congestion and dimishes trade.

The Park and Ride suggestions are unworkable.

The County's Chief Medical Officer has stated that lack of exercise is related to an increasing number of avoidable deaths in the area - one heart attack per day in Warwickshire! It is noted that a major 'bus company has submitted a scathing 17 page report on the traffic situation and stated that they could not even serve one of the new developments. Buses have not proved to be sustainable. The only service for Myton Road is one per hour and therefore hardly anyone uses it.

Danger to schoolchildren and others is currently problematic on our roads and will be exacerbated near schools such as at Woodloes and Aylesford/Newburgh.. We are given no concrete proposals for new roads, only ideas. A North Leamington relief road suggestion could cost £50million+ and the idea that the A452 could be routed to the Fosse - one of the most dangerous roads in the County is preposterous. The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and on to the M40 will have the opposite effect at the eastern end of Myton Road with the addition of Morrisons and the proposed trading estate and Aldi supermarket all exiting out on to the double roundabout system. The present Plan does not address these traffic problems sufficiently and should be "refused on transport grounds where the residual cumulative impacts of development are severe" (NPPF 32).

The NPPF (34) states that "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised." "A key tool to facilitate this will be a Travel Plan" (NPPF 36). All developments which generate significant amounts of movement should be required to provide a Travel Plan". We have not seen such a Travel Plan.

Myton Road, Banbury Road, Europa Way, Castle Bridge, Emscote Road and Prince's Drive are all highly congested with long queues or at a standstill at peak times including the Town centre and often emergency vehicles cannot negotiate a way through, even via the pavements. If the closed Warwick Fire Station were to be relocated at Queensway, their vehicles would experience increased problems and response times would be worsened. There is a suggestion that Europa Way could be widened but this would exacerbate bottlenecks when the traffic reaches the roundabouts. The County say they can mitigate but not contain the resulting increase in traffic and admit there are places where congestion will worsen. One of the mitigation measures suggested includes a gyratory system at the Castle island which, with its traffic lights etc. will severely harm the setting of the castle in a conservation area. The green space forms the approach to Warwick and views from Warwick Castle. WDC say the area south of Warwick is environmentally sensitive but then put it in for development - why? Traffic would increase at the Butts, the narrowest road in the town and the no right turn plan for St. Nicholas Church Street would impact severely on the economy of Smith Street. Vibrancy of the town centre is important. Think about what the effect will be on people sitting outside cafés in danger of being knocked over and pollution from all the traffic being funnelled through Warwick. People won't want to shop in Warwick because they won't be able to get into the town. It will be the destruction of Warwick and the people who want to shop here. There will be an adverse affect on Tourism.

Air Quality:

The NPPF (17) states that the Plan should "support the transition to a low carbon future" and contribute to "reducing pollution". Also "Local planning authorities should plan for new development in locations and ways which reduce greenhouse gas emissions." (NPPF 95)

The NPPF (17) states that policies should "recognise town centres as the heart of their communities and pursue policies to support their viability and vitality". (30) "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion". Also (NPPF 124) "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

Policy ER.2: Environmental Impact of Development
"The environmental impact of all proposed development on human beings, soil, fauna, flora, water, air, climate, the landscape geology, cultural heritage and material assets must be thoroughly assesse, and measures secured to mitigate adverse environmental effects to acceptable levels. Local plans should include policies to ensure this takes place. The impact of existing sources of environmental pollution on the occupants of any proposed new development should also be taken into account. Ass assessment of environmental impact should take account of, and where possible seek to reduce, uncertainty over the implications of the proposed development. If adverse impacts cannot be mitigated to acceptable levels, development will not be permitted."

Pollution from car exhausts in many streets in Warwick town centre and some in Leamington is already worse than is legally permitted. Figures produced by officers from public health Warwickshire were based on 2011 measurements of roadside nitrogen dioxide concentrations, the main contributor being road traffic.

An Emission Study commissioned by Warwick District Council showed that "Nitrogen dioxide concentrations in the Warwick Air Quality Management Areas currently exceed the annual limit value of 40 µg m-3 at several locations where there is relevant exposure of members of the public. It is unlikely that the limit value will be achieved at some locations on Jury Street until well beyond 2018 without additional control measures. Traffic in Warwick can be very congested and it is likely that the road network is operating at capacity. This study therefore assumes that there will be no growth in traffic between 2011 and 2015."

However this report did not take into account the impact of this increased traffic on our health. The officers could not confirm that they had carried out any modelling on the impact of the increase and what would the impact be on our health. Pollution is strongly linked to irregular heartbeat and lung clotting.

Even more worrying is there are no measurements taken in Warwick of the particulate matter, mainly emitted by diesel engines, which is more dangerous because it goes deep into the lungs. Records show that fifteen times more people die from air pollution related illnesses than die in road accidents.

The Traffic Assessment commissioned states, "Schemes proposed within the modelling at this stage have not been tested to a sufficient level of detail to determine that they are the optimum solution" and "an obvious concern surrounding the implementation of this strategy is that this will result in an increase in the overall levels of traffic travelling through the town centre"!

The traffic congestion that Warwick already suffers will increase by a possible 6,000+ extra cars from extra South Warwick housing alone, let alone the increase from 17,000 new homes throughout the District, bringing with it increased pollution in areas where air quality is already over the limit. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. Air quality remains in breach of these regulations and will become toxically high with the 27% increase in traffic volume resulting from the Local Plan preferred options. There is no management plan to address these levels. The Government says there is a definite link between pollution and traffic causing health problems such as asthma, some cancers, heart problems, etc. The County Council admitted that air quality will suffer as carbon emissions will increase in surburban sprawl. There are schools in the town and in the areas of high traffic congestion such as Myton and Banbury Roads with playgrounds and playing fields and children are already being exposed to nitrous-dioxide above legally permitted levels, risking asthma and all the other health problems associated with pollution. You admitted that you did not know how the carbon emissions could be reduced by the 20% currently necessary. It therefore seems incredible that the large-scale housing developments on the edge of Warwick are suggested with a likely 40% increase in the town's population, over 15 years. This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?
The 2008 Air Quality Action plan for Warwick shows the very worst area being Warwick town centre.

The District Council is required to improve air quality, but the Local Plan and its transport strategy would worsen it. Noise and vibration would also be constant, businesses and tourism would be damaged. Worse, the long-term health of residents of these streets would be even more threatened.

NPPF 124 states, "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

We request that a Health Impact Assessment will be carried out including air quality testing well before any Local Plan in its current form is approved.

I note that the House of Commons' Environmental Audit Committee has published a report on the subject recommending the Government issue new planning guidance to ensure local authorities prioritise air quality in planning decisions. However, neither County Highways nor Public Health Warwickshire use their powers as statutory consultees to robustly object to housing developments on the grounds that they going to impact on the health of all the people enduring the constant traffic congestion.

Brownfield Sites

The NPPF (111) states "Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land) provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land."

So why are we not making it a priority to develop brownfield sites first and regenerate poorer housing in urban areas? There are many more examples of brownfield sites in Warwick District which could be regenerated.

Alternative Sites

The previous Core Strategy identified several other sites with potential for housing. Local villages where there are good transport links and the potential to improve road access should be developed rather than the urban fringe development of Warwick. The Warwick Parkway area provides a first class rail link. Hatton has a station and easy access to the A46 and Barford has immediate access to the M40 and A46. Two other areas of potential for large scale housing provision are Radford Semele and Lapworth which already have infrastructure to cope with further development, with good public transport, roads and a railway station.

This in turn would mean much smaller developments around Warwick would therefore be required. Although you state that there are three gas lines near Bishops Tachbrook. I can see from the map that there is an area to the west which could take some housing whilst avoiding the gas lines. There are other areas which were identified in the Core Strategy options which have not been considered this time, such as the A46 corridor and further development at Sydenham. The commercial units at Sydenham have mostly closed and been boarded up and would offer an ideal brownfield site for development.

Green Belt

The NPPF (79) states "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."

The new Local Plan now incorporates housing in Green Belt at Milverton and Kings Hill. The NPPF (76) states "By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances". "Once established, Green Belt boundaries should only be altered in exceptional circumstances." (NPPF 83) Yet Warwick District Council's reason for allocating development on Green Belt is that "there is nowhere else to build".

NPPF (88) states "When considering any planning application, 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.."

We are objecting to this scale of development which will undoubtedly impact negatively on the character of Warwick and the quality of life of existing residents. We are facing urban sprawl rather than the housing being spread equitably around the District. Less than 10% of housing is proposed for villages, some of which, such as Barford, would welcome more homes including low-cost housing to build up sustainable communities with schools and facilities and meet the need for affordable rural housing. Those that grew up in the villages and wish to remain there would then have the opportunity to do so. We propose that at least another 1,000 could be spread around the villages and the number proposed for Warwick reduced.

Coalescence and Ecology

Green space is essential to separate the towns of Warwick, Whitnash, Leamington and Bishops Tachbrook. An incredible number of homes proposed for Warwick District are to be built on the land south-east of Warwick, covering nearly all of the green space between the Banbury Road, Greys Mallory, Europa Way, Myton and the Technology Park. This would mean estates more than three times the size of Warwick Gates, Woodloes Park or Chase Meadow! The towns would ultimately be amalgamated into one giant urban sprawl.

The area to the west of Europa Way was identified as an area of restraint at the time of planning the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa to prevent the two towns becoming one urban sprawl. The current Local Plan states in para 9.11, "It is important to protect the areas of restraint from development proposals that could alter their predominantly open character. Their value and importance lies in their contribution to the structure and character of the urban area, providing open areas in and around towns and preserving open wedges that separate one urban area from the next." The District has 85% green belt but 45% of this is to be built on, thus reducing the gap between conurbations. The green space threatened is valued rich and versatile agricultural land, essential for food self-sufficiency, environmentally precious landscape with many wildlife habitats and biodiversity including owls, uncommon woodpeckers, roe deer and badgers. Our existing green space provides open space, sports and recreation and such land, including playing fields, should not be built on! The NPPF 109 states "the planning system should contribute to and enhance the natural and local environment by:
* protecting and enhancing valued landscapes, geological conservation interests and soils;
* recognising the wider benefits of ecosystem services;
* minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures."


Loss of Prime Agricultural Land

Housing developments already approved or included in the new Local Plan which are on valued countryside and grade 1 agricultural land which will be essential in 12 to 15 years time.

Historic Environment

The historic environment would directly be damaged by the increase in traffic and by wide new junctions cluttered with traffic lights and signs at beautiful places: in Warwick at Bridge End, over the Castle Bridge, on Castle Hill, and at St John's; and on the approach to Leamington via Europa Way, giving no impression of the beauty of the spa town.

Pinch points at bridges cannot be alleviated and the 300-year old Castle Bridge already carries 20,000 vehicles per day and cannot sustain an increase in traffic without threat to its very structure. We should be trying to reduce this traffic to prevent the bridge collapsing, not increase it. We need an impact assessment to ensure its conservation. English Heritage have offered to help with this.

The NPPF (112) states "As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional."

The precious historic and listed buildings in Warwick are being damaged by traffic vibration and pollution and this problem will only worsen. Increased commuting traffic must not be funnelled through Warwick's congested urban centre.

Flood Risk

The NPPF (94) states that "Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk". Also "Local Plans should take account of climate change over the longer term, including factors such as flood risk....." and (NPPF 99) "When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure." We already have existing green infrastructure to mitigate against water run-off and flood risk the proposals are to build on it!

The NPPF (101) states "The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic Flood Risk Assessment will provide the basis for applying this test." There are other available sites as already stated. "A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall." (NPPF 102)

Europa Way and an area to the south of Gallows Hill are in flood zones and at significant risk of flooding, yet housing is proposed in Flood Zone 1, adjacent to Zones 2 and 3. Areas at risk of flooding have always been designated areas of restraint but you are dispensing with these. More concrete on green fields here which currently soak up heavy rainfall must increase water run-off and impact on the areas of Warwick which already suffer from flooding, especially around Myton Road and Bridge End. You have received photographic evidence of flooding from properties in Myton Crescent and the Malins. When the Warwick Technology Park was created, there were severe flooding problems in the adjacent Myton Gardens. The field donated to Myton school as a restricted covenant playing field has proved to be unusable because of water-logging, demonstrating on-going water-management problems. Even more relevant to the Malins and Myton Crescent was the severe flooding in 2007 caused by the re-orientation of the water run-off flows and the disturbance and removal of top soil from the Round Oak School playing fields behind Myton Crescent. It was only after threats to sue the County Council that remedial action was taken. This consisted of a bund to capture excess run-off and a pump situated in the north-west corner to return water uphill into the drain near the Round Oak School. This action has proved ineffective and inadequate as run-off water has periodically flowed into the gardens in October 2012 and in the recent floods, when the water level reached was only a few inches below the level of the electricity sub-station situated between 26 Myton Crescent and 1 The Malins.

The field at the end of The Malins slopes upwards from The Malins and run-off water from adjacent fields above and to the right and behind also flows towards The Malins and Myton Crescent. When there is a downpour on saturated ground, water flows quickly down, fills up the lower parts of the field and collects in the gardens of nos. 26, 28 and 30 Myton Crescent, and overflows into the gardens of nos. 3 and 12 The Malins and towards no. 1 The Malins and the electricity sub-station. There is little indication that the seriousness of this flooding is being taken into account.

Ignoring flood risk is contrary to NPPF 100 "Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere."

The previous Core Strategy decided that this area may not be needed for development in the future being an area of restraint and the worst area for infrastructural needs. Development is not necessary in these areas of flood risk and should be avoided, certainly not put into the first phase for building. Home-owners would also face being turned down for insurance in postcodes where there is flood risk. This area you have designated for building is vital for flood alleviation and should not be built on at all. At the very least it should be the last designated site.

 
Density

Garden Town suburbs sound admirable but naiïve when you look at the number of buildings proposed and the impact on the environment. This concept did not materialise in Warwick Gates or Chase Meadow and developers will build at high density for increased profit margins. 1,100 houses were first proposed for Chase Meadow and now it is to be 1,600. WDC has no budget for tree maintenance and developers cannot be relied upon to carry this out, as we have seen in other recent developments. Warwick Gates school and Chase Meadow play area never materialised but £1.4m of Chase Meadows developers' contribution was used instead for St. Nicholas Park remediation. They were then allowed to build more houses on the area allocated for sport/play area at CM. After 14 years Chase Meadow still has unadopted roads, only just received its link road to the local school and the prospect of a community centre for sports provision and social interaction. Developers will not be persuaded to build at 30 units per hectare and there is no means of insisting on this. This is just a red herring in our opinion, as are green wedges since you admitted that where these are proposed, you will be reliant on private landowners to permit their development. Once again, funding for this would be dependent on developers' contributions and these monies, being in short supply, would be diverted for other more essential infrastructure.

Coventry and Duty to Co-operate
The National Planning Policy Framework makes clear that local planning authorities should meet their own housing need and meet the needs of other authorities in the same housing market area as far as is consistent with the policies set out in the Framework. This includes policies for the protection of the built and natural environment.
The Duty to Cooperate requires authorities to work effectively on strategic planning matters that cross their administrative boundaries. The Duty to Co-operate is not a duty to agree and local planning authorities are not obliged to accept the unmet needs of other planning authorities if they have robust evidence that this would be inconsistent with the policies set out in the National Planning Policy Framework, for example polices on Green Belt or other environmental constraints.
An authority will need to consider its obligations under the duty to co-operate, the policies of the National Planning Policy Framework taken as a whole and any relevant Local Plan policies when considering requests from others to co-operate on strategic cross boundary matters.
Coventry Council should provide more dwellings for Warwick University students which would free up hundreds of dwellings (including Station House with over 200 student flats) in the South of Leamington to private affordable starter homes and family homes. WDC have recently been forced to change their planning policy because of the problematic increase in HMOS in the District.

It is known that Coventry University in particular has a policy of increasing its international students substantially and that this began in about 2008. The housing need for students, who tend to move between universities fairly often, is substantially different to that of the general population and this should be taken properly into account by the University and the City Council by providing appropriate new accommodation for students to reduce the pressure on family homes. The international student population and the housing provision made for it should be separately identified and accounted for in Coventry's Local Plan that is not taken into account in the Hearn report of Coventry's housing need. The Hearn September 2015 updated assessment report makes only two references to student housing provision and neither take into account the policy change or only relates to student households that utilise normal family homes. Since there were 25,000 students in Coventry in the 2011 census who were living in either in halls or in student only housing and that since then numbers may have risen due to the expansion policy, work should be done to establish the best way to provide housing for this sector of the market.

Coventry's Green Belt

Coventry doesn't want to lose its green belt so it is being allocated to Warwick District. Giving up green belt should be dependent on the quality of the land. Rural areas have more high grade agricultural land than the green belt land in Coventry.

I trust you will include all the above points within the analysis of all the consultation responses.

We object to the modified Local Plan for the following reasons.

We now have a 6.4 year housing land supply. We note that last year's figures are to be revised by Mr. Barber.

The growth in the number of households remain exaggerated and unnecessary.

So much land has already been approved that the total number of houses will not be built for many, many years, if ever - land banking!

ONS figs show migration into Warwick District will probably be very much less than the JSHMA has indicated.

The NPPF requires 'sustainable development'. The three criteria of sustainability are environmentally, economically and socially sustainable. The development south of Warwick is not sustainable.

Infrastructure

The necessary infrastructure is not in place, nor is the funding to provide it, i.e. transport mitigation, schools, healthcare provision, police and fire and rescue, flood alleviation. There is little information on how this infrastructure can be provided. The Plan is neither sustainable nor deliverable.

The NPPF (17) states that strategies should "deliver sufficient community and cultural facilities and services to meet Local needs". Also (NPPF 162) "Local planning authorities should work with other authorities and providers to:
* assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demands and
* take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."

Yet you confirm that infrastructure will not be put in place before building commences but that you hope that infrastructure will be provided from developers' contributions, whilst admitting that this may not raise enough to cover escalating costs of new roads, bridges, schools, extra health provision, policing, fire service, community centres etc. If left to developers, history has demonstrated this may not happen. Infrastructure needs will then be prioritised and some areas may miss out. You have admitted that infrastructure proposals will be prioritised and there will be a cut-off point when the money runs out. We have seen no architects' proposed site plans showing each area with all the necessary infrastructure in place. You have provided no idea of potential costs at all. You have provided no results of studies at all. Warwick has already lost its police station and fire station, roads are completely congested at peak times, schools are drastically oversubscribed and have no places, the hospital is at breaking point and cannot cope with the load, having day surgeries, evening clinics and Saturdays to clear backlogs and lack of parking leads to innumerable late attendance for appointments, and the police haven't a clue how they can cope with more communities. Utilities such as water, sewers, electricity provision will have to be provided at escalating massive cost. The public sewer discharges to Longbridge Water Treatment Works. Severn Trent currently transport sewage from Longbridge to Coventry by tanker several times a day. They do not have the capacity now to deal with sewage at the Longbridge site and it is inconceivable how they will cope with sewage from another 4,000 houses in Warwick. How many more tankers will be required and at what extra cost?

Transport - Severe Traffic Congestion and Car Dependancy

Extensive sprawling urban development proposed will inevitably exacerbate car dependancy. The transport strategy is car-based, just squeezing more congested traffic on to the existing road network, bridges over the River Avon, and parking. Contrary to transport policies, it would make walking and cycling less attractive, and could not have good public transport. All traffic crosses river on 3 bridges - Castle, Princes Drive, Adelaide Road. Leads to congestion and dimishes trade.

The Park and Ride suggestions are unworkable.

The County's Chief Medical Officer has stated that lack of exercise is related to an increasing number of avoidable deaths in the area - one heart attack per day in Warwickshire! It is noted that a major 'bus company has submitted a scathing 17 page report on the traffic situation and stated that they could not even serve one of the new developments. Buses have not proved to be sustainable. The only service for Myton Road is one per hour and therefore hardly anyone uses it.

Danger to schoolchildren and others is currently problematic on our roads and will be exacerbated near schools such as at Woodloes and Aylesford/Newburgh.. We are given no concrete proposals for new roads, only ideas. A North Leamington relief road suggestion could cost £50million+ and the idea that the A452 could be routed to the Fosse - one of the most dangerous roads in the County is preposterous. The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and on to the M40 will have the opposite effect at the eastern end of Myton Road with the addition of Morrisons and the proposed trading estate and Aldi supermarket all exiting out on to the double roundabout system. The present Plan does not address these traffic problems sufficiently and should be "refused on transport grounds where the residual cumulative impacts of development are severe" (NPPF 32).

The NPPF (34) states that "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised." "A key tool to facilitate this will be a Travel Plan" (NPPF 36). All developments which generate significant amounts of movement should be required to provide a Travel Plan". We have not seen such a Travel Plan.

Myton Road, Banbury Road, Europa Way, Castle Bridge, Emscote Road and Prince's Drive are all highly congested with long queues or at a standstill at peak times including the Town centre and often emergency vehicles cannot negotiate a way through, even via the pavements. If the closed Warwick Fire Station were to be relocated at Queensway, their vehicles would experience increased problems and response times would be worsened. There is a suggestion that Europa Way could be widened but this would exacerbate bottlenecks when the traffic reaches the roundabouts. The County say they can mitigate but not contain the resulting increase in traffic and admit there are places where congestion will worsen. One of the mitigation measures suggested includes a gyratory system at the Castle island which, with its traffic lights etc. will severely harm the setting of the castle in a conservation area. The green space forms the approach to Warwick and views from Warwick Castle. WDC say the area south of Warwick is environmentally sensitive but then put it in for development - why? Traffic would increase at the Butts, the narrowest road in the town and the no right turn plan for St. Nicholas Church Street would impact severely on the economy of Smith Street. Vibrancy of the town centre is important. Think about what the effect will be on people sitting outside cafés in danger of being knocked over and pollution from all the traffic being funnelled through Warwick. People won't want to shop in Warwick because they won't be able to get into the town. It will be the destruction of Warwick and the people who want to shop here. There will be an adverse affect on Tourism.

Air Quality:

The NPPF (17) states that the Plan should "support the transition to a low carbon future" and contribute to "reducing pollution". Also "Local planning authorities should plan for new development in locations and ways which reduce greenhouse gas emissions." (NPPF 95)

The NPPF (17) states that policies should "recognise town centres as the heart of their communities and pursue policies to support their viability and vitality". (30) "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion". Also (NPPF 124) "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

Policy ER.2: Environmental Impact of Development
"The environmental impact of all proposed development on human beings, soil, fauna, flora, water, air, climate, the landscape geology, cultural heritage and material assets must be thoroughly assesse, and measures secured to mitigate adverse environmental effects to acceptable levels. Local plans should include policies to ensure this takes place. The impact of existing sources of environmental pollution on the occupants of any proposed new development should also be taken into account. Ass assessment of environmental impact should take account of, and where possible seek to reduce, uncertainty over the implications of the proposed development. If adverse impacts cannot be mitigated to acceptable levels, development will not be permitted."

Pollution from car exhausts in many streets in Warwick town centre and some in Leamington is already worse than is legally permitted. Figures produced by officers from public health Warwickshire were based on 2011 measurements of roadside nitrogen dioxide concentrations, the main contributor being road traffic.

An Emission Study commissioned by Warwick District Council showed that "Nitrogen dioxide concentrations in the Warwick Air Quality Management Areas currently exceed the annual limit value of 40 µg m-3 at several locations where there is relevant exposure of members of the public. It is unlikely that the limit value will be achieved at some locations on Jury Street until well beyond 2018 without additional control measures. Traffic in Warwick can be very congested and it is likely that the road network is operating at capacity. This study therefore assumes that there will be no growth in traffic between 2011 and 2015."

However this report did not take into account the impact of this increased traffic on our health. The officers could not confirm that they had carried out any modelling on the impact of the increase and what would the impact be on our health. Pollution is strongly linked to irregular heartbeat and lung clotting.

Even more worrying is there are no measurements taken in Warwick of the particulate matter, mainly emitted by diesel engines, which is more dangerous because it goes deep into the lungs. Records show that fifteen times more people die from air pollution related illnesses than die in road accidents.

The Traffic Assessment commissioned states, "Schemes proposed within the modelling at this stage have not been tested to a sufficient level of detail to determine that they are the optimum solution" and "an obvious concern surrounding the implementation of this strategy is that this will result in an increase in the overall levels of traffic travelling through the town centre"!

The traffic congestion that Warwick already suffers will increase by a possible 6,000+ extra cars from extra South Warwick housing alone, let alone the increase from 17,000 new homes throughout the District, bringing with it increased pollution in areas where air quality is already over the limit. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. Air quality remains in breach of these regulations and will become toxically high with the 27% increase in traffic volume resulting from the Local Plan preferred options. There is no management plan to address these levels. The Government says there is a definite link between pollution and traffic causing health problems such as asthma, some cancers, heart problems, etc. The County Council admitted that air quality will suffer as carbon emissions will increase in surburban sprawl. There are schools in the town and in the areas of high traffic congestion such as Myton and Banbury Roads with playgrounds and playing fields and children are already being exposed to nitrous-dioxide above legally permitted levels, risking asthma and all the other health problems associated with pollution. You admitted that you did not know how the carbon emissions could be reduced by the 20% currently necessary. It therefore seems incredible that the large-scale housing developments on the edge of Warwick are suggested with a likely 40% increase in the town's population, over 15 years. This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?
The 2008 Air Quality Action plan for Warwick shows the very worst area being Warwick town centre.

The District Council is required to improve air quality, but the Local Plan and its transport strategy would worsen it. Noise and vibration would also be constant, businesses and tourism would be damaged. Worse, the long-term health of residents of these streets would be even more threatened.

NPPF 124 states, "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

We request that a Health Impact Assessment will be carried out including air quality testing well before any Local Plan in its current form is approved.

I note that the House of Commons' Environmental Audit Committee has published a report on the subject recommending the Government issue new planning guidance to ensure local authorities prioritise air quality in planning decisions. However, neither County Highways nor Public Health Warwickshire use their powers as statutory consultees to robustly object to housing developments on the grounds that they going to impact on the health of all the people enduring the constant traffic congestion.

Brownfield Sites

The NPPF (111) states "Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land) provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land."

So why are we not making it a priority to develop brownfield sites first and regenerate poorer housing in urban areas? There are many more examples of brownfield sites in Warwick District which could be regenerated.

Alternative Sites

The previous Core Strategy identified several other sites with potential for housing. Local villages where there are good transport links and the potential to improve road access should be developed rather than the urban fringe development of Warwick. The Warwick Parkway area provides a first class rail link. Hatton has a station and easy access to the A46 and Barford has immediate access to the M40 and A46. Two other areas of potential for large scale housing provision are Radford Semele and Lapworth which already have infrastructure to cope with further development, with good public transport, roads and a railway station.

This in turn would mean much smaller developments around Warwick would therefore be required. Although you state that there are three gas lines near Bishops Tachbrook. I can see from the map that there is an area to the west which could take some housing whilst avoiding the gas lines. There are other areas which were identified in the Core Strategy options which have not been considered this time, such as the A46 corridor and further development at Sydenham. The commercial units at Sydenham have mostly closed and been boarded up and would offer an ideal brownfield site for development.

Green Belt

The NPPF (79) states "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."

The new Local Plan now incorporates housing in Green Belt at Milverton and Kings Hill. The NPPF (76) states "By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances". "Once established, Green Belt boundaries should only be altered in exceptional circumstances." (NPPF 83) Yet Warwick District Council's reason for allocating development on Green Belt is that "there is nowhere else to build".

NPPF (88) states "When considering any planning application, 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.."

We are objecting to this scale of development which will undoubtedly impact negatively on the character of Warwick and the quality of life of existing residents. We are facing urban sprawl rather than the housing being spread equitably around the District. Less than 10% of housing is proposed for villages, some of which, such as Barford, would welcome more homes including low-cost housing to build up sustainable communities with schools and facilities and meet the need for affordable rural housing. Those that grew up in the villages and wish to remain there would then have the opportunity to do so. We propose that at least another 1,000 could be spread around the villages and the number proposed for Warwick reduced.

Coalescence and Ecology

Green space is essential to separate the towns of Warwick, Whitnash, Leamington and Bishops Tachbrook. An incredible number of homes proposed for Warwick District are to be built on the land south-east of Warwick, covering nearly all of the green space between the Banbury Road, Greys Mallory, Europa Way, Myton and the Technology Park. This would mean estates more than three times the size of Warwick Gates, Woodloes Park or Chase Meadow! The towns would ultimately be amalgamated into one giant urban sprawl.

The area to the west of Europa Way was identified as an area of restraint at the time of planning the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa to prevent the two towns becoming one urban sprawl. The current Local Plan states in para 9.11, "It is important to protect the areas of restraint from development proposals that could alter their predominantly open character. Their value and importance lies in their contribution to the structure and character of the urban area, providing open areas in and around towns and preserving open wedges that separate one urban area from the next." The District has 85% green belt but 45% of this is to be built on, thus reducing the gap between conurbations. The green space threatened is valued rich and versatile agricultural land, essential for food self-sufficiency, environmentally precious landscape with many wildlife habitats and biodiversity including owls, uncommon woodpeckers, roe deer and badgers. Our existing green space provides open space, sports and recreation and such land, including playing fields, should not be built on! The NPPF 109 states "the planning system should contribute to and enhance the natural and local environment by:
* protecting and enhancing valued landscapes, geological conservation interests and soils;
* recognising the wider benefits of ecosystem services;
* minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures."


Loss of Prime Agricultural Land

Housing developments already approved or included in the new Local Plan which are on valued countryside and grade 1 agricultural land which will be essential in 12 to 15 years time.

Historic Environment

The historic environment would directly be damaged by the increase in traffic and by wide new junctions cluttered with traffic lights and signs at beautiful places: in Warwick at Bridge End, over the Castle Bridge, on Castle Hill, and at St John's; and on the approach to Leamington via Europa Way, giving no impression of the beauty of the spa town.

Pinch points at bridges cannot be alleviated and the 300-year old Castle Bridge already carries 20,000 vehicles per day and cannot sustain an increase in traffic without threat to its very structure. We should be trying to reduce this traffic to prevent the bridge collapsing, not increase it. We need an impact assessment to ensure its conservation. English Heritage have offered to help with this.

The NPPF (112) states "As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional."

The precious historic and listed buildings in Warwick are being damaged by traffic vibration and pollution and this problem will only worsen. Increased commuting traffic must not be funnelled through Warwick's congested urban centre.

Flood Risk

The NPPF (94) states that "Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk". Also "Local Plans should take account of climate change over the longer term, including factors such as flood risk....." and (NPPF 99) "When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure." We already have existing green infrastructure to mitigate against water run-off and flood risk the proposals are to build on it!

The NPPF (101) states "The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic Flood Risk Assessment will provide the basis for applying this test." There are other available sites as already stated. "A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall." (NPPF 102)

Europa Way and an area to the south of Gallows Hill are in flood zones and at significant risk of flooding, yet housing is proposed in Flood Zone 1, adjacent to Zones 2 and 3. Areas at risk of flooding have always been designated areas of restraint but you are dispensing with these. More concrete on green fields here which currently soak up heavy rainfall must increase water run-off and impact on the areas of Warwick which already suffer from flooding, especially around Myton Road and Bridge End. You have received photographic evidence of flooding from properties in Myton Crescent and the Malins. When the Warwick Technology Park was created, there were severe flooding problems in the adjacent Myton Gardens. The field donated to Myton school as a restricted covenant playing field has proved to be unusable because of water-logging, demonstrating on-going water-management problems. Even more relevant to the Malins and Myton Crescent was the severe flooding in 2007 caused by the re-orientation of the water run-off flows and the disturbance and removal of top soil from the Round Oak School playing fields behind Myton Crescent. It was only after threats to sue the County Council that remedial action was taken. This consisted of a bund to capture excess run-off and a pump situated in the north-west corner to return water uphill into the drain near the Round Oak School. This action has proved ineffective and inadequate as run-off water has periodically flowed into the gardens in October 2012 and in the recent floods, when the water level reached was only a few inches below the level of the electricity sub-station situated between 26 Myton Crescent and 1 The Malins.

The field at the end of The Malins slopes upwards from The Malins and run-off water from adjacent fields above and to the right and behind also flows towards The Malins and Myton Crescent. When there is a downpour on saturated ground, water flows quickly down, fills up the lower parts of the field and collects in the gardens of nos. 26, 28 and 30 Myton Crescent, and overflows into the gardens of nos. 3 and 12 The Malins and towards no. 1 The Malins and the electricity sub-station. There is little indication that the seriousness of this flooding is being taken into account.

Ignoring flood risk is contrary to NPPF 100 "Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere."

The previous Core Strategy decided that this area may not be needed for development in the future being an area of restraint and the worst area for infrastructural needs. Development is not necessary in these areas of flood risk and should be avoided, certainly not put into the first phase for building. Home-owners would also face being turned down for insurance in postcodes where there is flood risk. This area you have designated for building is vital for flood alleviation and should not be built on at all. At the very least it should be the last designated site.

 
Density

Garden Town suburbs sound admirable but naiïve when you look at the number of buildings proposed and the impact on the environment. This concept did not materialise in Warwick Gates or Chase Meadow and developers will build at high density for increased profit margins. 1,100 houses were first proposed for Chase Meadow and now it is to be 1,600. WDC has no budget for tree maintenance and developers cannot be relied upon to carry this out, as we have seen in other recent developments. Warwick Gates school and Chase Meadow play area never materialised but £1.4m of Chase Meadows developers' contribution was used instead for St. Nicholas Park remediation. They were then allowed to build more houses on the area allocated for sport/play area at CM. After 14 years Chase Meadow still has unadopted roads, only just received its link road to the local school and the prospect of a community centre for sports provision and social interaction. Developers will not be persuaded to build at 30 units per hectare and there is no means of insisting on this. This is just a red herring in our opinion, as are green wedges since you admitted that where these are proposed, you will be reliant on private landowners to permit their development. Once again, funding for this would be dependent on developers' contributions and these monies, being in short supply, would be diverted for other more essential infrastructure.

Coventry and Duty to Co-operate
The National Planning Policy Framework makes clear that local planning authorities should meet their own housing need and meet the needs of other authorities in the same housing market area as far as is consistent with the policies set out in the Framework. This includes policies for the protection of the built and natural environment.
The Duty to Cooperate requires authorities to work effectively on strategic planning matters that cross their administrative boundaries. The Duty to Co-operate is not a duty to agree and local planning authorities are not obliged to accept the unmet needs of other planning authorities if they have robust evidence that this would be inconsistent with the policies set out in the National Planning Policy Framework, for example polices on Green Belt or other environmental constraints.
An authority will need to consider its obligations under the duty to co-operate, the policies of the National Planning Policy Framework taken as a whole and any relevant Local Plan policies when considering requests from others to co-operate on strategic cross boundary matters.
Coventry Council should provide more dwellings for Warwick University students which would free up hundreds of dwellings (including Station House with over 200 student flats) in the South of Leamington to private affordable starter homes and family homes. WDC have recently been forced to change their planning policy because of the problematic increase in HMOS in the District.

It is known that Coventry University in particular has a policy of increasing its international students substantially and that this began in about 2008. The housing need for students, who tend to move between universities fairly often, is substantially different to that of the general population and this should be taken properly into account by the University and the City Council by providing appropriate new accommodation for students to reduce the pressure on family homes. The international student population and the housing provision made for it should be separately identified and accounted for in Coventry's Local Plan that is not taken into account in the Hearn report of Coventry's housing need. The Hearn September 2015 updated assessment report makes only two references to student housing provision and neither take into account the policy change or only relates to student households that utilise normal family homes. Since there were 25,000 students in Coventry in the 2011 census who were living in either in halls or in student only housing and that since then numbers may have risen due to the expansion policy, work should be done to establish the best way to provide housing for this sector of the market.

Coventry's Green Belt

Coventry doesn't want to lose its green belt so it is being allocated to Warwick District. Giving up green belt should be dependent on the quality of the land. Rural areas have more high grade agricultural land than the green belt land in Coventry.

I trust you will include all the above points within the analysis of all the consultation responses.

Even though it purports to follow government guidance, the Strategic Housing Market Assessment (SHMA) is not independent and is seriously defective. It has considered only one side of the equation and only those with a vested interest in growth have influenced its findings. Population and household projections have been wrongly used as if they were forecasts. The assumption on headship rates is questionable and the study fails to get to grips adequately with economic issues, commuting, international migration, student needs and affordable housing. Above all, the SHMA acknowledges the high degree of uncertainty about the future but then plumps for a single figure of so-called Objectively Assessed Need (OAN) which is poorly justified. This figure is seriously lacking in credibility. [section 3]

The local authorities in their Memorandum of Understanding have misused the SHMA by adopting the so-called OAN uncritically and indeed adding to it. They have failed to consider whether environmental and other policy factors limit the ability of the area to meet its housing needs. The decisions they have reached about the distribution of housing provision within the housing market area are arbitrary, opaque and extreme, making the proposed plan unsound and unsustainable. The proposal that Warwick District should take the largest share of Coventry's overspill is reckless and wholly unjustified given the Green Belt status of a large part of the district. [section 4]

The Council have failed to demonstrate that nearly 17,000 dwellings can be built in the district by 2029. All the evidence suggests otherwise. Their response to the low level of dwelling completions in the first four years of the plan period is to allocate even more housing, without considering what (if anything) can be done to improve building rates within the existing allocation. As a result, the proposed plan would have a range of undesirable consequences for urban regeneration, vacancy rates and dereliction, commuting, service and infrastructure costs, housing opportunities and loss of Green Belt which neither the Council nor the Sustainability Appraisal have adequately considered. Those negative effects which the Sustainability Appraisal does recognise have played no apparent part in the development of the strategy. Almost half the dwellings to be built on allocated sites are in the Green Belt. The proposed plan is unsustainable and is directly at odds with policy in the National Planning Policy Framework. [sections 5 and 6]

The proposed plan and the cumulative impact of its development proposals would exacerbate problems which the district already faces such as loss of character and environmental quality, traffic congestion and inadequate public transport. Many of the individual housing proposals - particularly those involving substantial loss of Green Belt - cannot be justified and will do great damage. Nearly half of housing development on allocated sites would be in the Green Belt and the proposed plan does not comply with government policy on housing development in the Green Belt. Insufficient consideration has been given to the infrastructure implications of development on such a large scale. [section 7]

The plan is unsound, unsustainable and unworkable. It stems from a deluded view of the growth potential of Coventry and Warwickshire and is contrary to government policy. The plan needs to be fundamentally re-thought and housing provision of between 10,000 and 10,500 dwellings would be much more appropriate and potentially achievable. [section 8]

3. Defects in the Strategic Housing Market Assessment (SHMA)
The SHMA prepared by G L Hearn was intended to be an objective assessment of housing need in Coventry and Warwickshire. While it purports to follow government guidance, it has the following serious defects which fatally undermine its credibility:
* As a general rule, only organisations with a vested interest in increasing housing provision from its already very high level have been consulted. Those able to take a more detached and balanced view were conspicuously excluded. The local authorities themselves have a strong incentive to push house building rates higher and higher thanks to the New Homes Bonus.
* While the terms of reference for the study are reasonably objective, a wealth of e-mail correspondence between the local authorities and the consultants (released under the Freedom of Information Act ) suggests that there was a good deal of manipulation behind the scenes.
* The study rightly uses ONS population and household projections as the baseline for its work, but treats them as if they were forecasts. On the contrary, ONS say ''The population projections have limitations. They are not forecasts (my italics) and do not attempt to predict the impact that future government policies, changing economic circumstances or other factors (for example, government policies on immigration or student fees) might have on demographic behaviour...... As a forecast of the future population they would inevitably be proved wrong, to a greater or lesser extent..... Projections become increasingly uncertain the further they are carried forward into the future'. Hearns have fundamentally erred in treating the projections as forecasts and failing to consider how the policies or other factors that underlie them may change in future. They assume (paragraph 3.34) that uncertainty is mainly attributable to inadequacies in base data, but the effects of future changes in societal trends and public policy are likely to be far more influential. The SHMA never faces up to these issues.
* There is an unexplained anomaly in the use of the projections. The difference from the 2011-based to the 2012-based projections for the HMA is a decrease of 127 dwellings per annum. However, in Hearns' work this results in an increase of between 472 and 572 dwellings per annum . The consultants do not adequately explain this apparent conflict.
* The approach is based on the implicit assumption that new dwellings will meet existing and future housing needs, but this is not the case. Almost 90% of the private housing market involves existing, not new, housing stock. With the exception of starter homes, the great majority of new dwellings are bought by existing home owners. Except in the very long term, prices are insensitive to the volume of new house building and the market is not particularly effective in ensuring that newly arising housing needs are met.
* The study rightly explores a very wide range of scenarios in its attempts to quantify Objectively Assessed Need but fails to critique the underlying methodologies of the different models in which it places its faith. The study plumps for single figures within the range of possible outcomes (often towards the upper end of the range) that are arbitrary or poorly justified. The eventual recommendation that 4,272 dwellings per annum should be built in Coventry and Warwickshire seems to be a black-box generated number instead of being backed up by credible analysis at each step in the process.
* The 'part return to trend' on headship rates is poorly explained and justified. It is far from certain yet whether the cessation of the fall in average household size in recent years is just a 'blip' or the 'new normal' . The factors likely to influence this lead in different directions and give different outcomes. The consultants assume that a reduction in average household size will resume, but there is very little evidence for this;
* The economic forecasts used by Hearns give widely divergent results. The fact that they are based on past development trends is a major weakness, particularly as only a short, probably unrepresentative period has been considered. They also lack explicit assumptions about the productivity relationship between GVA and job growth. Yet the Local Enterprise Partnership is trying to attract high tech and high value added jobs, which would result in a lower number of jobs for a given level of GVA;
* The Strategic Employment Land Study is based on very arbitrary assumptions and data and has not been subjected to critical analysis. The 'talking up' of Coventry's employment prospects in section 4 of the study is very speculative, verging on wishful thinking, and the whole OAN is consistent with a rose-tinted view of economic prospects in Coventry and Warwickshire, bearing in mind past lower than national growth rates and skills shortages . Hearns have suggested upward adjustments to OAN in some areas in relation to economic prospects, but do not seem to have considered downward adjustments in other areas so the analysis is all one way. The equation made between jobs and people is over-simplistic;
* The assumptions about commuting are unrealistic. Commuting patterns change over time and it should be one of the objectives of a plan to reduce longer distance commuting in the interests of sustainability. Conversely however this plan is likely to lead to significant increases in commuting (see Section 6 below). The assumption that the commuting rate will remain as in 2011 is therefore naive and lacks any credibility;
* Much of the increase in population in Coventry over the past ten years or so appears to be related to the growth in student numbers in the city. A huge amount of development of student accommodation has taken place. The SHMA never properly addresses this issue. It fails to consider whether and to what extent these trends are likely to continue into the future; or the extent to which students require separate housing provision (as opposed to living in halls of residence or shared accommodation). Why should there not be a 'partial return to trend' on this issue, as on headship rates?
* International migration is mentioned in section 3, but there is no discussion of whether past trends are likely to continue. The Government is under intense political pressure on this issue and has maintained its target of lowering net in-migration by more than half. The outcome of the EU referendum is also likely to have a bearing on international migration. In recent years, Coventry has taken more than its fair share of in-migrants. There is no reason to think that in-migration to the city can or will continue at anything like recent levels. In Warwick District, net migration (including international migration) has varied greatly from year to year since 1995 and is inherently unpredictable. Also, net migration is influenced by housing and employment provision so there is an element of circularity in any forecast which is based on past trends;
* The relationship between affordable housing and overall housing need is never convincingly established by the study. Affordable housing should be a sub-set of overall need, not an 'add-on', so Hearns' upwards adjustment of OAN to take account of affordability appears unjustified. It is also debatable whether 'affordable housing' is affordable in practice to many new households. There is no evidence that Hearns have taken sufficient account of recent changes in government policy.
To sum up, the SHMA is a seriously flawed piece of work that should not have been used without critical analysis. At best the resultant so-called Objectively Assessed Need is subject to great uncertainty; at worst it is not credible at all.
4. Defects in the Way the SHMA Has Been Interpreted and Used
Government guidance is that Objectively Assessed Need should be a starting point for assessing what housing provision should be. The National Planning Policy Framework (NPPF) recognises that there may be circumstances in which development requirements cannot be met because of the demonstrable lack of environmental capacity.
In a letter in December 2014 , the then minister said 'A Strategic Housing Market Assessment is just the first stage in developing a Local Plan and councils can take account of constraints that indicate that development should be restricted.... The outcome of a Strategic Housing Market Assessment is untested and should not automatically be seen as a proxy for a final housing requirement in Local Plans......Councils will need to consider Strategic Housing Market Assessment evidence carefully and take adequate time to consider whether there are environmental and policy constraints, such as Green Belt, which will impact on their overall final housing requirement.' Unmet needs from neighbouring authorities should be met 'where it is reasonable to do so and consistent with achieving sustainable development' .
The Local Plans Expert Group have drawn attention to a common deficiency in local plans. They conclude that 'despite the clear test set by paragraph 14 of the NPPF, few authorities compile an assessment of the environmental capacity of their area' . They go on to propose that a proportionate Assessment of Environmental Capacity should be an important part of plan making. The local plan making authority should consider the extent to which the plan can meet OAN consistent with the policies of the NPPF.
This type of approach is conspicuously absent in Coventry and Warwickshire. The local authorities in their so-called Memorandum of Understanding and Warwick District Council in its plan have taken a lemming-like approach which is directly at odds with Government policy. They have decided without adequate explanation that Hearn's Objectively Assessed Need of 4,272 dwellings per annum (already an artificially high figure) should be increased still further to a housing target of 4,408. They have then failed to consider whether environmental constraints prevent this new figure being met in its entirety. The Hearn approach and its results have not been subjected to any critical analysis whatsoever and the uncertainty that runs right through the study has simply been ignored. It is sheer folly to pick out a single figure and stick to it come what may. Such an inflexible approach is certain to be found wanting as the implementation of the plan unfolds. Meanwhile a great deal of damage will have been done. The position is even more serious in Warwick because the modification to policy DS20 opens the door for even further housing development in future to meet unspecified housing needs in other areas.
The housing proposals for individual authorities are unjustified, to say the least. Coventry is deemed (without supporting evidence or argument) to be able to accept only 1230 (64%) of its OAN of 1930 per annum. The remaining 700 is distributed (without explanation) between three Warwickshire districts - Nuneaton and Bedworth, Rugby and Warwick. In Warwick's case, this results in proposed housing provision of 18,640 over the full twenty year period to 2031, which is over 55% higher than its own OAN. This is a fundamentally unsustainable and unjustified outcome.
The Warwick Plan gives no explanation of -
a. Why Coventry cannot meet more of its OAN;
b. How the allocation of the excess to other authorities has been decided. The 'redistribution methodology' has not been explained or justified;
c. The account taken of Green Belt, environmental and other policy constraints, both in Coventry and in the surrounding Warwickshire districts, in making this judgement;
d. The wider effects of 'transferring' housing need originating in Coventry to Warwick and other authorities.
The plan also fails to consider the density of new housing development or whether intensification of use of the existing housing stock could be achieved without loss of quality in the urban environment. On most development sites, a density of 35 dwellings per hectare has been automatically assumed, ignoring the variability between sites and their settings and the potential for higher density. By leaving this vital issue unconsidered, the plan fails to provide adequate justification for the link between the vast quantum of new housing development proposed and the huge land area involved.
The Warwick Local Plan is therefore fundamentally unsound and unsustainable, quite apart from its unquestioning reliance on a deeply flawed Strategic Housing Market Assessment. The approach taken is, quite simply, indefensible.
5. Implementation Problems
Government guidance requires the Council to demonstrate the deliverability of the plan . The Council do not seem to have asked themselves whether it is realistic to expect 16,776 dwellings to be built in Warwick District between 2011 and 2029.
The Council claim that 1,483 dwellings were completed in the district during the first four years of the plan period - 2011 to 2015: an average of 371 dwellings per annum. The plan requires an average of 932 dwellings per annum to be built over the full plan period, including those first four years. If dwellings built in the first four years are discounted, the average for the remaining fourteen years rises to 1,092 dwellings per annum, nearly three times the rate achieved in the first four years (during which the economy was growing). It simply cannot be done.
The Housing Trajectory in Appendix A shows very clearly the unreality of what the Council are proposing. Average completions per annum between 2018 and 2022 are assumed to be some 1,730 per annum, nearly five times the rate achieved in the first four years of the plan. The beginning of this period is a mere two years away and the assumption seems to ignore the lead time required to assemble skilled workers on a very large scale.
The plan states that at April 2016 there will be sites with planning permission for 5,161dwellings. It is very difficult to believe that all these permissions will actually be implemented during the plan period, though that is apparently what the plan assumes (in contrast, for example, to the Rugby Local Plan which assumes low take-up of existing permissions). In reality, allocating many more sites is likely to reduce the take-up rate on existing permissions still further. Over-allocation on this scale would effectively destroy the planning strategy because the Council would surrender control to house builders over where and when dwellings would be built. Adding an arbitrary 'element of flexibility' to housing provision , taking it up to a grand total of 17,557 , makes matters even worse.
A figure of 16,776 dwelling completions by 2029 therefore belongs in the realms of fantasy. National and regional studies have shown that the main factor limiting the scale of house building has been the sharp decline in public sector house building. Despite some recent policy announcements, there is little prospect of a significant revival in house building by this sector. Private sector building has been stuck at around 90,000 dwellings per annum nationally since 2008 and the latest RICS survey indicates that growth in private sector house building slowed considerably during the first quarter of 2016. Overall, housing permissions have exceeded starts by about 50,000 dwellings per annum nationally in recent years .
A recent study by The Guardian newspaper showed that the nine largest national house building companies were sitting on planning permissions for 615,000 dwellings. Either they were incapable of building more because of shortages of labour, materials and / or finance; or effective demand is so low that they had no confidence that they could sell houses if they were built, or they chose to limit their output in order to keep house prices artificially high. Some house builders may also see investment in land as an end in itself in view of rising land prices. The truth probably lies in some combination of these factors. House builders have recently been criticised for 'land banking' by the Local Government Association.
So the prospects of 16,776 dwellings being built in Warwick by 2029 are negligible. Even so, house builders continue to press for high levels of provision so that they will have even more scope to pick and choose the sites that will bring them the greatest profits. This is understandable from their point of view, but should never form part of a credible planning strategy.
6. Likely Effects of the Housing Policies
As a result of this serious over-provision, the plan's housing proposals will have a wide range of unintended consequences -
a. The sites that provide developers with the greatest potential profit will tend to be green field sites outside urban areas rather than brownfield sites within them. The momentum behind urban regeneration will therefore be weakened still further and it will become much more difficult to redevelop windfall sites becoming available within the urban area. The Local Plan is right to have made an allowance for windfalls, but the more green field sites they allocate for housing development, the more difficult it will become to benefit from windfall sites;
b. Over-provision of housing can be expected to accelerate vacancy rates, dereliction and decay in the existing stock, particularly in the more marginal housing areas;
c. The displacement of housing from Coventry into Warwickshire will increase longer-distance commuting and lead to greater car dependency. No proper analysis has been done of this vital aspect of the proposals, least of all by the Sustainability Appraisal. Can the road and public transport systems cope with the extra traffic and passengers? With many roads, particularly in the towns of Warwick, Leamington Spa and Kenilworth, close to or above capacity already, the strong suspicion must be that the Warwick plan is unsustainable in transport terms. Where new roads or improvements to existing roads are proposed, insufficient information is given to demonstrate their financial viability or effectiveness in dealing with congestion;
d. A more dispersed pattern of development will lead to higher service and infrastructure costs once existing capacity thresholds have been exceeded, and will divert severely limited public sector resources away from renewal of services and infrastructure within existing urban areas . Developer contributions are rarely sufficient to provide necessary supporting services and facilities in their entirety;
e. Provision at a level not supported by effective demand is particularly destructive of the housing opportunities available to newer, younger and less well-off households: those most likely to be in housing need. New housing will overwhelmingly not be purchased by newer households. It is not valid to assume that a glut of new housing will result in lower prices all round, making the existing stock more affordable to those in housing need. In practice new homes are generally such a small proportion of the total housing stock that they do not have a significant lowering effect on prices;
f. Very substantial areas of Green Belt will be lost, compounded by losses for other purposes such as the sub-regional employment site. Proposed housing development in the plan accounts for some 500 hectares of Green Belt land and much of this is in strategically significant areas where the Green Belt performs vital functions, meeting all or most of the five purposes of Green Belt. It is very revealing that the plan does not make clear that meeting housing needs is not sufficient on its own to constitute the very special circumstances needed to justify inappropriate development in the Green Belt (see below) and that it generally ignores the recommendations of the Joint Green Belt Study;
g. Rigid adherence to forecasts gives only the illusion of certainty, inhibiting necessary adaptations to new problems and unforeseen opportunities . Warwick and the other Coventry and Warwickshire authorities have chosen to adopt a particularly rigid and unresponsive interpretation of present government policy and their proposals are therefore doomed to fail in practice.
These potential impacts of the Warwick Plan's housing proposals render the plan unsustainable and therefore not in compliance with government policy in the National Planning Policy Framework.
In particular, the plan fails to give sufficient weight to two key aspects of government policy:
a. That the presumption in favour of sustainable development does not apply in the Green Belt ;
b. That need for housing will rarely be sufficient to constitute the very special circumstances required for inappropriate development in the Green Belt. In July 2013, Local Government Minister Brandon Lewis said that 'The single issue of unmet demand....is unlikely to outweigh harm to the green belt and other harm to constitute the 'very special circumstances' justifying inappropriate development in the green belt' This was followed by a DCLG policy statement in October 2014 - 'the local planning authority should prepare a strategic housing land availability assessment to establish realistic assumptions about the availability....of land...and take account of any constraints such as green belt which indicate that development should be restricted and which may restrain the ability of an authority to meet its need . This was in turn reflected in Planning Practice Guidance . Yet Warwick District Council, along with the other Coventry and Warwickshire authorities, seems to have ignored this very important element of government policy .
The Sustainability Appraisal has been updated to reflect the latest modifications to the plan and specifically the huge uplift in housing numbers. However it suffers from a major weakness: that it treats the Strategic Housing Market Assessment and the local authority Memorandum of Understanding as givens without subjecting them to sustainability appraisal in their own right. In general it does not apply sufficiently rigorous analysis and places exaggerated faith in mitigation measures. It plays down some negative effects because of uncertainty about the exact form development will take. It also makes some very questionable individual assessments - for example that the effect of high growth on public transport and community services and facilities will be positive, when experience suggests that provision of these facilities and services almost invariably lags well behind housing development, particularly when it takes place as rapidly as is envisaged in this plan. A positive assessment of the high growth options against 'reduce need to travel' also seems fundamentally misguided when such a high proportion of the proposed development involves meeting Coventry's housing needs in Warwick District.
Impact on the Green Belt should have featured as one of the sustainability criteria used to appraise the plan and its policies. Green Belt is simply subsumed within the much wider criterion of 'Prudent Use of Land and Natural Resources' and it tends to get lost in the process. The appraisal frequently pulls its punches, talking for example about the potential for the loss of Green Belt when the strategy entails certainty of massive Green Belt loss.
Nevertheless the Sustainability Appraisal finds that the two high growth options (900 and 1,000 houses per annum) would have negative effects in relation to six of the sustainability criteria used to assess options. This conclusion is effectively ignored in the plan itself and there is no evidence that it has played any part in the development of the strategy. The Council have wrongly assumed that they have no alternative but to meet so-called Objectively Assessed Need in full, plus the huge uplift to meet Coventry's excessive housing needs.
7. Comments on Specific Housing Policies and Proposals and their Justification
My calculations suggest that some 4,575 (49%) of the new dwellings on specifically allocated sites would be in the Green Belt. This is a staggering figure which cannot possibly be reconciled with Government policy as described above. It is difficult to imagine why Warwick District Council, given the large amount of its land area subject to Green Belt policy, agreed to accept by far the largest individual proportion of Coventry's overspill (6,640 dwellings). On the basis of conflict with government policy and the need to preserve a strong Green Belt to secure the continued separation of the towns in the district from each other and from Coventry, I object to all the locations for housing development listed in paragraph 2.81 as having been removed from the Green Belt.
My comments on selected proposals are as follows:
* Kings Hill (H43) - This development would be a huge and totally unwarranted projection of the built-up area of Coventry into the Green Belt and open countryside south of the city. It would doubtless be followed soon afterwards by an application for a boundary revision to extend the city's area. This is an area of good quality landscape which makes an important contribution to the role of the Green Belt in separating Coventry from Kenilworth. The proposal relies heavily on a new railway station and roads but given the long delay in securing reopening of Kenilworth station there can be no guarantee that a station at Kings Hill will be open before development takes place.
* East of Kenilworth (H40) - This long swathe of development would close the Green Belt gap which currently exists between the built-up area of the town and the A46. On rising ground, the development would be very visible from countryside to the east near Ashow and the National Agricultural Centre.
* North of Milverton (H44) - This would constitute a substantial northward extension of Leamington Spa into the Green Belt, bringing it significantly closer to coalescence with Kenilworth. The safeguarding of a large area of additional land for future development makes the present proposal just the thin end of the wedge. The explanation talks blithely about dualling the A452 but this is unlikely to be feasible within the existing built-up area of Leamington and may not be affordable in any case.
* Baginton (H19) - The Rosswood Farm site, almost in line with the airport runway, seems particularly ill chosen from the point of view of noise, air pollution and air safety.
* Barford (H48 et al) - The cumulative impact of these developments would be expected to have a substantial impact on the character of the village.
* Bishops Tachbrook (H49 and H23) - Taken together, development of these sites could be expected to have a profound effect on the character of the village and would involve projections into open countryside to the west and south.
* Cubbington (H50) - A substantial projection of development into pleasant open countryside east of the village.
* Hampton Magna (H51 and H27) - Taken together, these developments would represent a huge extension of the village into Green Belt and open countryside to the south and east, changing the character of the village in the process.
* Leek Wootton (DS NEW 3) - Although a minority of the site was already developed, this does not justify the proposal, which forms a very substantial westward extension of the village into open countryside and Green Belt.
* Whitnash (H-03) - Whitnash is already a peculiarly shaped and poorly accessed urban extension. This large development will add an extension to the extension, taking the village across the railway to the east and making it stick out even more like a sore thumb. It is noticeable that there is no proposal for a railway station to serve it.

Policy DS New 1 includes vague criteria for allocating land for housing south of Warwick. It is wrong in principle to consult without more clear-cut proposals, leaving local people and interest groups in a position of great uncertainty.
The plan is far too deferential towards the growth aspirations of Warwick University. The plan should not give the university carte blanche to do whatever it wishes to do, but that in effect is what is proposed.
A general problem is the heavy reliance on master planning for comprehensive development of the larger proposed housing sites. This will make it even less likely that the housing proposals will be implemented on anything like the timescale envisaged in the housing trajectory, particularly where land is in multiple ownership.
In new paragraph 1.09, the plan talks about new development enhancing the setting of natural and heritage assets. This is delusional and makes a mockery of what little remains of the plan's environmental credentials.
New paragraphs 2.1 to 2.43 talk about taking land out of the Green Belt so that it can be safeguarded for possible future development. In relation to government policy, there is even less of a case for this than where development is claimed to be needed during the plan period, and I have already shown that the latter is contrary to government policy.
I have not found a policy directed towards controlling or influencing the types and sizes of dwelling to be constructed in the district. This plan seems to treat planning for housing as no more than a numbers game and in doing so it ignores government policy that the nature of new housing is important .
8. Conclusions
The housing proposals in the emerging Warwick Local Plan are unworkable, unsustainable, contrary to key elements of Government policy and against the interests of residents of the borough. They are deluded and unsound. They stem from a fundamentally misconceived growth-orientated strategy that reflects wishful thinking about the economic prospects of the sub-region by the Local Enterprise Partnership and the Coventry and Warwickshire local authorities compounded by some far from independent technical work of questionable quality to support it. The proposals give minimal weight to the environment and character of the district, which have hitherto been cornerstones of successive plans. They will result in the Council effectively abandoning control over planning for housing and in a significant reduction in environmental quality.
Much of the problem with the housing strategy stems from Coventry's overweening growth aspirations, which result in dumping large quantities of housing and employment development on neighbouring local authorities. This is counter-productive, unsustainable and unachievable. If Coventry cannot live within its means, it should not simply decant large-scale development to neighbouring authorities with no thought for the consequences..
The question of what would be a realistic and achievable level of housing provision for Warwick between 2011 and 2029 is a matter of judgement rather than calculation. Taking into account all the factors discussed in this Critique, my view is that provision of between 10,000 and 10,500 dwellings would be appropriate. This would have a good prospect of being achieved and would meet the reasonable housing needs of the district, as opposed to the inflated figure assessed by G L Hearn and the huge additional uplift provided through overspill from Coventry. Provision at this level would allow a much higher proportion of development to be on brownfield sites within the urban area (including windfalls) and would require little or no release of Green Belt land for housing.

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