Mod 20 - DS NEW1

The principle of an Area of Growth South of Coventry is supported. The geographic boundaries of this area should be broadly identified NOW as it is believed that not only will additional housing land be required but the Council imply in DS NEW 1 that this area may need to accommodate such additional housing.
It goes on to say that it will identify the most appropriate locations for additional housing; have regard to the future plans for the University and have regards to opportunities on both sides of the local authority boundary.
If certain sites can be "allocated" now, then there is no reason why other sites which fall into this area should not be identified and/or allocated.
Failure to do so as part of this Plan implies that more difficult decisions are being avoided until a later date when there may be an easier passage through the consultation process. The need is clearly known now so this Plan must analyse all the potential sites NOW.
This will allow a full public debate to the ultimate benefit of the soundness of the Plan and ensure that there are no doubts about why the current choice of sites to be allocated appears less than objective and transparent.

New 1.4 confirms that sites in this area, together with related sites within the Coventry boundary, will be coming forward and 1.5 recognises that the University will prepare a Masterplan which will also facilitate development that is not currently known about, but which is likely to come forward.

The identified sites at Cryfield Grange / Land South of Gibbet Hill Road have been identified to the Council; they do adjoin related sites in Coventry; they are likely to come forward early in the Plan period anyway; and it adjoins the current University campus. By any reasoning, this land should be positively considered as part of the current Plan's test of soundness and not left as a future but early additional exercise after the Examination, with less public scrutiny.

The phrase "the Green Belt between Coventry and Kenilworth should be protected; (bullet point 6) implies that WDC attaches no importance to the Green Belt between Leamington and Kenilworth. Nowhere is that Green Belt more at risk than in the Milverton - Blackdown - Chesford area where Kenilworth and Leamington are at their closest distance.

King hill is home Badgers,Muntjac deer,Newts that populate the ponds on kings hill and numerous varieties of birds plus a bat colony .
The land contains the sites of a least two ancient Saxon settlements.
The land is prone to high levels of water in parts .
Why would Warwickshire build a stand alone development next door to Coventry AND Coventry allow this to happen if it were not to receive any benefit from it ie council tax. As i see it Finham would be over whelmed with the extra traffic, noise ,schools and medical services unable to cope. Green lane south in particular is no more than a country lane with its protected ancient hedgerow (mentioned in the Doomsday book) running down the road marking the border between the West Midlands and Warwickshire.Why not build onto existing Towns and Villages !!!!!.

The Alvis sports and social club is under threat from housing. The club is home to football teams of all ages young and older. There is a Netball team ,cricket teams and a bowling team plus a dominoes team and pool team.What would happen to this facility which supports the local community. Does health not matter anymore ?.
Kings hill is an area of beauty and should not be lost. It forms a natural screen of Coventry from Warwickshire as you travel along the A46. Houses would destroy this.Other areas should be considered first and foremost before green fields. Regeneration might cost more but would have less impact on the environment in the long term.

Any decision to lift Green Belt status on this land and agree planning permission for 425+ homes, initially with more in the future, allied to additional development in Burton Green & Cromwell Lane would be highly irresponsible unless and until substantial new provision was made to accommodate the increase traffic that would result.

Any policy makers should first visit the area and witness the traffic queues that already arise along Westwood Heath Road from Cromwell Lane to Kirby Corner roundabout on weekdays mornings as traffic attempts to access:
* Westwood Business Park
* Cannon Park and the A45
* Warwick University and the Kenilworth Road / A46
Likewise in the evenings, queues form back from Cromwell Lane down Westwood Heath Road as people make journeys back to Balsall Common, Kenilworth or Tile Hill.

You should fully take into account that the road across the University of Warwick campus is now restricted to 20 mph and the frequent stops made buses dropping up 80+ plus students at a time cause tail backs not only along Westwood Heath Road but back up to Cannon Park and the A45.

An alternative access route from Westwood to Kenilworth along Crackley Lane, which is already used a 'rat run' to avoid the University Campus is highly unsuited to an increase in traffic and already dangerous to both vehicular traffic and especially cyclists, due it's narrowness, sharp blind corners, and extensive pot holes especially along the verges that cause cyclists and vehicles to utilise the middle of road resulting in close misses, as I am frequently aware of as both a cyclist and driver.

Any development at Westwood would surely require the widening of Crackley Lane as an absolute minimum.

I would also suggest that the route across Warwick campus would need to be re-considered, removing the 20 mph limit, erecting barriers to protect pedestrians and construction walkways across the road instead of having students walking out in front of vehicles as they do today.

The University also now propose a new Sports complex near Kirby Corner which in itself will result in more traffic in the local area.

Furthermore you should be aware of the frequent instances of 'unlit' student cyclists around Westwood Heath, which would become even more of a danger with a rise in traffic. You may refer to the Police Liaison Team at the University to validate that issue / concern.

Finally I would invite the planners to visit the Banner brook development in Coventry and the surrounding roads where the Massey Ferguson plant once existed, on any weekday morning or evening to witness and experience the traffic congestion that has arisen following a similar large scale housing development with no foresight or appreciation of the impact on local traffic and residents. If residents aren't away from their properties by around 8 am and travelling to Westwood Park / Warwick Uni they might as well stay at home until past 9 am, or sit in a queue for an hour. The same fate would face residents of Westwood and Burton Green.

Yes we are told that new homes are required, but great thought and consideration as the infrastructure required to support such developments must be undertaken.

I am very worried about the proposed massive development of 4000 houses to be built on King's Hill. This is low-lying green belt land and the major concern for me is the fact that, as the lowest part of Coventry, it is already susceptible to flooding around Finham Brook. So many houses on that land, will cover the earth where drainage would occur, and water draining off houses, paved drives and roads will have nowhere to go. With climate change and increased rainfall, this can only get worse.

Finham Sewage Works treats sewage from Kenilworth and Stoneleigh, as well as the whole of Coventry. As someone who lives in the area, I can tell you that it is not dealing adequately with it now. Certainly, when you walk past, the smell is quite overpowering, and on hot Summer days, the smell reaches the houses in Finham. How is it going to cope with another community of so many extra houses?

There is no convenient access to King's Hill, unless the enclosing roads are widened dramatically. This would destroy ancient protected hedgerows and oak trees. The old Leamington Road already carries a lot of traffic and is completely congested if any of the surrounding trunk roads and motorways are closed, and they frequently are!

The development will take years to be carried out, involving bulldozers and lorries driving up and down narrow roads - a danger to children - while the extra sewage, gas, electricity, telephone, and water services are installed. Then the bricks, slates, insulation etc. necessary to build the houses themselves will need to be ferried in.

A lot of research has been done by the Finham Resident's Association, which I know you have received - in depth, careful research. Can you honestly say that your modifications cover all their objections adequately? I don't want Finham sinking under sea of flood water and sewage in ten years time, when it is too late to do anything about it.

As a resident of Coventry who has lived on the border of Warwick District Council for 40 years I am writing to place on record my objection to the plan to build on the area known as site ref H43 (Kings Hill).
I have listened to all the arguments both "for" and "against" and I can see no justification for building within this area. I request that these plans are reviewed and turned down on the basis that Coventry has more than enough of its own "brown field" sites to accommodate this house building plan.

See attached

Comments concerning WDC plan modifications
Modification 20 Paragraph 2.54
Policies Map 35

With reference to the above proposals in the WDC plan modifications, I am a resident of Cromwell Lane and have already responded to the Coventry local plan but since the building of 425 homes South of Westwood Heath road as proposed in the WDC plan will have a very serious impact on the wider area I would like to make the following comments and objections.
* I do not believe the proposal for these homes is sound as it does not take account of the traffic and infrastructure difficulties which already exist in this area and which will be made infinitely worse with the addition of 425 homes and around 800 extra cars.
* The Coventry Plan is already proposing 240 homes to the West of Cromwell lane with no suggestion of any infrastructure improvements in the area apart from 'considering resident's parking schemes in adjacent roads.'
* The general area of Tile Hill, Cromwell Lane and Westwood Heath is already badly congested for large parts of the day due to the opening of the flyover in 2005, the construction in recent years of approximately 2000 new homes in the wider area, the extra traffic and parking problems caused by the Centro operation of the park and ride facility at Tile Hill station which is oversubscribed every working day, the large number of HGV vehicles which use these minor roads on a daily basis from Logistic facilities with no direct access to major roads and the large amount of traffic which uses Cromwell Lane/Westwood Heath roads as a through route to the A46, the University of Warwick and beyond.
* The proposed HS2 works at Burton Green are scheduled to last from 2016 to 2026 and will involve major works in the area around the A46/Stoneleigh Rd junction, the construction of a compound east of the A46, major works at Bockendon Rd. and the actual construction works at Burton Green. The published vehicle movement schedules show a large amount of HGV and general traffic in the area for the next 10 years which must have an impact on local minor roads.
* To make the plans of both Coventry and Warwick sound for this area the issues above have to be addressed and an overall infrastructure scheme for the area formulated which will mitigate if not completely solve these problems. Otherwise the proposals for both these developments are not sustainable and therefore not sound.
* In the event of these proposals going ahead, I believe that no building works should commence until the HS2 project is completed in 2026 to prevent the area being swamped with construction and other traffic

See attached

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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The Club notes that the Council's draft local plan has identified Kings Hill for the development of 4,000 houses and in doing so it has included the land that the Club leases from Coventry City Council as part of this development.
In reflecting on these proposals the Club wish to state that given the information currently available it opposes the housing development and wishes to remain on its existing location and continue to develop our facilities for the local community. This position is consistent with the PPS and other Policies - specifically Para 74 of the NPPF:
74. Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.
To this end the Club feels that the Local Plan should more clearly reference the opportunity to develop the community, social and sporting offer to the new population through the development of the Club given the right circumstances. The Club has therefore commented on the modifications to the Local Plan as attached.
We also note the lack of any communication with us concerning your planned development and would expect that we will be included in all future communications regarding this proposed development. The Club wish to work with Warwick District Council, Coventry City Council and all relevant National sports' Governing Bodies to best meet the Club's facility needs now and into the future.
If you have any questions or would like further clarification on any of the information provided then please do not hesitate to contact me.

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The proposals would mean an equivalent number of houses of twice as many as are already in the Finham area of Coventry. This would need a large increase in the water treatment plant capacity.

Coventry is already densely populated, to propose this many new dwellings concentrated in one area will greatly exacerbate the situation.

There is no allowance for any green belt land between the two housing areas.
It seems a hurriedly prepared plan with no in depth study to its overall effects and with little time for proper public consultation.

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We write on behalf of Taylor Wimpey UK Ltd in respect of their land interests on land at Old Budbrooke Road, Hampton Magna. A site location plan is enclosed with these representations at Appendix 1 alongside a leaflet detailing the development proposals for the Site at Appendix 2.


The site is not part of a proposed allocation, with sites H27 (130 dwellings) and H51 (115 dwellings) being proposed for allocation in Hampton Magna. However, for the reasons set out below, we consider that given its sustainable location and proximity to services and facilities within the village the land in the control of Taylor Wimpey UK Ltd provides a better option for sustainably meeting the needs of Hampton Magna in the future and is capable of delivering circa 140 dwellings.


The Site occupies a sustainable location situated to the north-east of Hampton Magna. It is bordered to the south by residential development, to the west by Old Budbrooke Road, to the north by a farm track and then the Warwick Parkway railway station and to the east by Stanks Farm building and a disused sewage works. The boundaries to the site form logical and defensible boundaries and the site offers the opportunity to add sensibly to the built form of the village. The site would offer good pedestrian linkages, particularly to the railway station to the north of the site, along with the provision of substantial areas of public open space and landscape buffers to the north and south of the site.

In comparison to the proposed allocations within Hampton Magna, the site offers logical access direct from the Old Budbrooke Road, whereas the proposed allocations offer little opportunity for direct access, particularly for construction other than through the centre of the village itself. Furthermore, we consider that the landscape impact of the proposals to the south of the village will be greater as they benefit from inferior boundaries and levels of containment.


In relation to this Site, we comment Main Modifications as follows:

Mod 4 - Policy DS6

Whilst we are generally supportive of the Council's approach to increasing the housing target, taking account of unmet needs to assist the HMA in meeting the requirements of


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the NPPF and satisfying the Duty -to-Cooperate, we remain concerned that the level of uplift at the HMA and District levels is insufficient.

We enclose at Appendix 3 a critique of the Council's position on meeting housing needs across the HMA.

At this time, we are of the view that the housing requirement for the HMA over the period (2011-2031) should be a minimum of 100,200 dwellings (5,010 dpa), with our updated and preferred methodology increasing this to 126,000 (6,300 dpa).

For Warwick District we consider that the OAN is a minimum of 20,800 dwellings (1,040 dpa), with our updated and preferred methodology increasing this to 23,400 dwellings (1,170 dpa).


The figures for Warwick do not take account of any need to redistribute housing within the HMA based on the Duty-to-Cooperate and Local Authorities, such as Coventry City, being unable to meet their own housing needs.

Mod 6 - Policy DS7

Notwithstanding our response to Mod 4, and the contention that the housing requirement should be increased further to 23,400 dwellings (1,170 dpa) for Warwick District over the period 2011- 2031 (not accounting for unmet needs within the Coventry HMA), we wish to comment on the amended Policy DS7, which sets out how the housing requirement will be met.


The Council has proposed to allow for the delivery of an additional 811 dwellings over and above the proposed requirement of 16,766 dwellings for the Plan period (2011- 2029). Regardless of any changes to the housing requirement, we support the approach of the Council in seeking to allocate additional land; as such an approach adds significantly to the soundness of the Council's approach by providing a positively prepared Plan that will be more effective in delivering the minimum housing needs of the area, and is flexible to changing demands over the Plan period.


The inclusion of safeguarded land will also play a key role in achieving these outcomes, which is supported in the NPPF at paragraph 14 - where Councils are asked to provide sufficient flexibility to adapt to rapid change in meeting OAN.

The proposed approach to allocations and safeguarding land will also assist the Council in demonstrating that they have been both aspirational and realistic in progressing the Plan in accordance with paragraph 154 of the NPPF; with the slight overprovision allowing for any slippages in the delivery of the strategic sites within the District - which may be particularly helpful given the proximity of a number of allocations to the south of Warwick/Leamington Spa - and maximising the chance of a five year housing land supply being demonstrable over the Plan period.


Mod 7 - Para's 2.21 to 2.24

Further to our suggestion for the provision of appropriate flexibility in the Plan, we note the housing trajectory that sits behind Policy DS7, which depicts the timeline for the delivery of housing over the Plan period.

The trajectory is seeking a sharp increase, from circa 850 forecast completions in 2015/16 to a minimum of circa 1,400 dpa over the period 2017/18 - 2022/23.

Such an increase is considerable, and to maximise the chances of this being delivered then the Council will require as many deliverable sites as possible to come forward to help meet this need.

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We would therefore be supportive of land being allocated at Old Budbrooke Road in Hampton Magna for housing development, which is capable of early delivery and would assist in meeting its OAHN.

Mod 9 - Para's 2.37 and 2.38

We have no specific comments to make, other than to agree with the justification for releasing sites from the Green Belt to meet the needs of the Housing Market Area.

Furthermore, we note that the NPPF requires at paragraph 47 for the needs of the HMA to be met, however, how this is distributed across the District is a matter of planning judgement for the Council taking account of a number of considerations. As an example, elsewhere in the HMA it can be seen that North Warwickshire has adopted a Sound Plan in accordance with the NPPF that includes within it 500 dwellings to meet the needs of Tamworth without any sites immediately adjacent to the urban area from which unmet needs are originating.


Consequently, we consider that paragraph 2.38 should be amended to simply state:
'In selecting sites on the edge of urban areas, non‐Green Belt sites are‐ favoured over Green Belt sites where possible. However, where there are no suitable non Green Belt alternatives to meet an identified need, sites are removed from the Green Belt to enable development to take place which will help to meet the needs of the Housing Market Area. This applies to land to meet the needs of Coventry, Leamington, Kenilworth, some of the villages and land on the edge of Lillington to assist in the regeneration of the area.' (added / deleted)

Mods 10 and 11 - Policy DS11 and Para's 2.41 to 2.53

We disagree with the proposed allocations made in Hampton Magna, as we consider that the land under the control of Taylor Wimpey at Old Budbrooke Road is superior and offers a more sustainable and logical extension to the settlement of Hampton Magna.

We have commented previously on the suitability of the Site to deliver residential dwellings and enclose a leaflet which demonstrates how the Site could sensible be delivered (Appendix 2), as well as technical notes updating the position in relation to ecology/archaeology/agriculture and highways/drainage at Appendix 4 and 5 respectively.

Given the above, we object to the Plan on the basis that this Site is not included within it, either instead of or alongside H27 and H51.

Indeed, we note that the update to the Landscape Sensitivity and Ecological & Geological Study (Landscape Assessment Update - 2014) upgraded the classification of part of Site H27 to a 'High-medium' landscape sensitivity to residential development as opposed to a 'High' sensitivity. We would however point out that there is no evidence or justification behind this alteration as the only focus was around land to the east of Hampton Magna under reference HM_05. Site H51 remains assessed as having 'High' landscape sensitivity.

In addition we would add that Taylor Wimpey's site is subject to 'High -medium' landscape sensitivity to residential development and the assessment set out that "...there is potential for a small amount [of development] between the existing settlement edge along Blandford Way/Arras Boulevard/Gould Road and Stanks Farm. However, this would need to include a substantial landscape buffer in order to strengthen the green corridor along the railway and prevent any physical or visual link to Warwick..." As can be seen in Appendix 2, we note are aware of the need to provide appropriate landscaping and have incorporated this in to the proposals for the Site from an early stage.

We therefore consider that the land in the control of Taylor Wimpey offers a suitable and preferable extension Hampton Magna.

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Mod 16 - Para 2.81

As set out previously we consider that the site offers the opportunity for release of Green Belt to provide for additional sustainable housing growth throughout the Plan period.

In 2015, the Council undertook a review of the Joint Green Belt Study (Parcel WA2) which also includes the proposed allocations of Sites H27 and H51. The parcel scored 15/20 in this assessment.

However, the scale of the parcel did not allow for an accurate assessment of this Site and thus we have prepared our own Landscape and Visual Appraisal of the Site - which respects the boundaries of the Site. This is enclosed at Appendix 6 and summarises that the Site is "...well related to the existing housing area and benefit from robust boundaries, including Old Budbrooke Road, the railway line and the A46 Warwick Bypass... subject to the sensitive design, detailing and layout, development at the Site would not result in urban sprawl; nor represent an encroachment into the wider countryside; it would not impact on local heritage assets; nor would it materially contribute to the coalescence with the neighbouring settlement at Warwick. Accordingly, development could be accommodated without resulting in significant landscape and visual effects, or offending the objectives of Green Belt policy."


Mod 20 - Policy DS NEW 1 Directions for Growth South of Coventry

In relation to this Policy, we wish to support the Council in their approach to capping of the assumed delivery of the Westwood Heath and Kings Hill sites due to infrastructure and delivery rates respectively.

It is important in meeting the needs of the HMA that the Council are realistic in this regard in order to ensure that the Plan is effective and deliverable by 2029.

Given the timescales for adoption of the Plan and progressing a site of the scale of Kings Hill, 1,800 dwellings by 2029 should be considered aspirational - and in order to ensure that the Plan remains realistic, consider that no uplift to this figure is appropriate. Indeed, the Council should ensure that they are fully confident of the build rates suggested being delivered before progressing the Plan.


Conclusion

We trust that you will take these comments are helpful in progressing the Plan. Should you require any further information, do not hesitate to contact me as per the details on this letter.

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