H47 - Barford - Land south of Wasperton Lane

Showing comments and forms 1 to 17 of 17

Object

Proposed Modifications January 2016

Representation ID: 68471

Received: 21/04/2016

Respondent: Barford Residents Association

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Summary
* Barford cannot accept the additional housing proposed as the infrastructure, roads, drainage, medical facilities, etc is not satisfactory.
* New residents with a need to travel some distance to work, will cause unneccessary congestion and pollution.
* The rapid increase in population will destroy the village community

Full text:

Dear Sir,
I have tried to use the on-line system to comment on the 2 new areas H47 and H48 that are in Barford - but cannot respond to both sites - it appears only H47 is available.

The objections to both these sites are similar in that they will further add to the strain on the village infrastructure and are inappropriate at this time for our village.
The original Local Plan proposed 70 - 90 houses over 15 years from 2015 - 2030
Since then Planning permission has been granted for :-
60 houses on Nursery Meadows
26 houses behind Wilkins Close
8 Houses North of Wasperton Lane
7 houses at Barford Garage
8 houses on Westham Lane

109 houses in total and now another 75 are being imposed.

This is over twice the original allocation A village community cannot accommodate this number of new residents in such a short space of time and the result will be that separate fractions will be formed and the inclusive village community will be destroyed

Barford is known for it's independence and for the village community which is prepared to work had to create facilities - e.g the Community Shop, Improvements to the playing fields.
The creation of these facilities has rendered the village more desirable and more sustainable - but no improvements have been made to other elements of the infrastructure. The drainage is insufficient, there is a poor and infrequent public transport and there are no medical facilities.

With poor public transport any new houses are likely to have at least 2 cars which will contribute to the congested traffic problems we have morning and night. Church Street and High street is already a busy route to work in South Leamington with traffic from Wellesbourne and the motorway at J15 leaving the by-pass to go through the village at busy periods. Add a further 75 households from Barford (and also proposed large housing developments in Wellesbourne) to this already congested route and traffic will be at a standstill. The frustration this will cause will lead to more accidents and injuries.
It is unsound to propose more housing in Barford. The housing proposed is required to satisfy the needs of Coventry - 13 miles away. Residents working in the Coventry area will need to use their cars causing pollution and congestion on the roads.

There are slight differences in the traffic problems exiting for H47 and H48, but both sites are problematical.
H47 - 30 houses - Land South of Wasperton Lane will be expected to access the main road system turning West and through Barford - but the sight lines to the East are not great. If the traffic does turn East to access the M40 South then this will increase the traffic on what is effectively a single track road - without passing places. The large articulated lorries travelling at over 40 mph that presently use the road will be inconvenienced !

H48 - 45 houses - Land south of Westham Lane, will be expected to access the main road system through Bremridge Close. As this development has been designed without sufficient off-road parking additional cars will have difficulty getting through and cause noise, pollution and extra congestion.

Object

Proposed Modifications January 2016

Representation ID: 68605

Received: 22/04/2016

Respondent: G Bell

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Like so many residents, I am dismayed at the prospect of even more houses within the village. The infrastructure within the village is stretched beyond capacity each working day, as the chosen route for an ever increasing number of commuters. Each previous plan or commitment re housing is dismissed, with no consideration for residents. Squeezing an ever increasing number of houses into an ever decreasing space is not the answer to housing 'problems' deemed to exist elsewhere. The quality of the village, and those who live within it, is diminished by these proposals.

Full text:

Like so many residents, I am dismayed at the prospect of even more houses within the village. The infrastructure within the village is stretched beyond capacity each working day, as the chosen route for an ever increasing number of commuters. Each previous plan or commitment re housing is dismissed, with no consideration for residents. Squeezing an ever increasing number of houses into an ever decreasing space is not the answer to housing 'problems' deemed to exist elsewhere. The quality of the village, and those who live within it, is diminished by these proposals.

Object

Proposed Modifications January 2016

Representation ID: 68657

Received: 16/04/2016

Respondent: Mr Stephen Price

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Substantial housing expansion over time - impacts on existing infrastructure, increasing levels of traffic and associated pollution.
Journeys to work are by car - poor public transport.
New housing should be closer to areas of employment, both for the environment and the health of villagers.
Issues around road safety

Full text:

I wish to object to the inclusion of further housing sites in Barford village in the Plan.
The village has already had substantial housing expansion over the last few years, which has led to strains on the existing infrastructure and increasing levels of traffic and associated pollution, particularly over the early morning and afternoon periods.
Every working person in Barford and the surrounding area has to travel to work and with minimal public transport, this journey is by car.
If new housing is to be built in the area, then logically it should be built closer to areas of employment, both for the environment and the health of villagers.
Personally I have had two vehicles written off by this increased traffic when parked outside my house - it is only a matter of time before someone is killed or seriously injured.

Object

Proposed Modifications January 2016

Representation ID: 68661

Received: 16/04/2016

Respondent: Mrs Tracy Rutter

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Restricted and inadequate infrastructure
High levels of traffic
Impact on historic environment
Adverse impact on character of village

Full text:

I am a resident of Barford and have been for the past 4 1/2 years. Our house is on Church Street.
I lived in Old Milverton as a youngster and witnessed the surrounding countryside dwindling year on year. Today, Warwick, Leamington, Whitnash, Southam, Bishop's Tachbrook etc.have all merged to create one concrete, traffic ridden, jungle.
I feel very privileged to live in Barford, but it did not come cheap and our Council Tax is a constant reminder. However, I feel concerned that your proposal is going to take away everything that is cherished by its residents. Barford has accommodated new housing and another couple of sites have been granted. I get the impression that for the sake of Coventry you plan to sacrifice Barford.
I work in Warwick. Already, the amount of traffic has reached a worrying level and there is another huge housing project afoot to be sited on the Banbury road. It worries me that the old Warwick bridge will collapse under the weight of its ever increasing demand.

I would be very grateful if you could carry out more surveys prior to making your countless decisions:

Invite the decision makers to come from London and visit us in Barford. Get them to study the flood plains and make them aware of our restricted infrastructure. Let them witness the level of traffic, especially the 'rat run' through the village. Request that they speak to Mr John Murphy and Mr Alan Rhead about their proposals. Ask them to consider what effect that this is having on our Historic town of Warwick.
One never knows what good these letters do and I steered clear of them in the past, but as a Health care professional I feel that I have a duty of care to raise these issues.
Thanking you in anticipation of reading this and I am aware that your hands may be tied, but please try and defend us against the army of people working in London, who appear totally ignorant or just plain dismissive of our needs and concerns for what is already land on the brink being merged into the ever increasing concrete conurbation.

Object

Proposed Modifications January 2016

Representation ID: 68679

Received: 15/04/2016

Respondent: Mr Brian Tovey

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to proposals: -
- adverse impact on residential amenity, facilities and services
- congestion
- impact on environment

Full text:

As a long term resident of Barford, I have witnessed it's unfortunate environmental decline due to unwanted housing developments, increased traffic and pressure on local amenities which have impacted greatly on its general infrastructure and village life.

To build even more houses in a village which is already over developed is unnecessary and would have a disproportionate effect on our school, roads and environment. We often have grid lock at peak periods and access to the bypass between 8.00 - 9.00 a.m and Leamington / Warwick would rival a London suburb for traffic congestion. This is the result of political short term planning without a thought or regard for the local community. Enough is enough. Planners have already spoilt our lovely village, please no more development in Barford. There are plenty of other areas which can absorb an increase in housing with little impact, Longbridge for example.

To add weight to my views, I would ask you to drive from Longbridge Island to Barford through the village to Warwick or Leamington at 8.15 a.m. / 8.45 a.m. or return journey between 5.00 p.m. and 6.00 p.m. Friday afternoon being the worst. Whilst you are in the village, check how many vehicles take absolutely no notice of the 30 mph speed warnings which light up when exceeding the limit. You will find around 50% of drivers take no notice and this is a road onto which WDC are proposing even more housing.

Our infrastructure and environment are now at breaking point. WDC are responsible for this, now act responsibly.

Object

Proposed Modifications January 2016

Representation ID: 68706

Received: 19/04/2016

Respondent: Mr Tom Hainey

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Objection on the houses built to accommodate Coventry's needs:
- this plan will exacerbate the traffic and pollution.
- in barford's case this would require a round trip of c. 26 miles, which would be undertaken by car as the bus service is very restricted.
- this will affect the environment because of the increased pollution.

Full text:

I was taken aback to be informed by Barford Parish Council that it was the intention to increase the number of houses planned to be built within Barford. I had posted objections to the previous plans based on issues around

- Additional stress on infrastructure, especially from increased traffic
- Environmental concerns, especially additional pollution
- Issues around problems with local school places and access to local doctors etc.

I was slightly perplexed when the latest proposal to increase the houses to be built within Barford was to accommodate the needs of Coventry, due to lack of sites to build within the boundaries of Coventry. I am slightly confused that no sites to accommodate Coventry's needs could not be found closer to the city. The need to build houses all around Warwickshire seems to only exacerbate the traffic and pollution issues that would be generated by the assumed travel to and from Coventry from these new locations. In Barford's case this would require a round trip of c. 26 miles, which would predominantly be undertaken by car, since the bus service is very restricted. Based on this approach we could be building houses in Warwickshire in 50 years time to accommodate the needs of London!!!

I strongly object to these latest changes in the WDC Local Plan, based on even more pressure and stress on the issues already raised and stated above. I cannot believe that there are no locations closer to Coventry to provide the required additional housing forecast for Coventry. Perhaps if this lack of space is based on 'Green Belt' or other such restrictions in the land around Coventry, I suggest it may be time to revisit and alter these restrictions.

Object

Proposed Modifications January 2016

Representation ID: 68707

Received: 22/04/2016

Respondent: Mr Edward Kirkby

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Building houses for the people of Coventry in Warwickshire village will bring major disruption to Badford and increase in population.
Current planning proposal does not take into account the needs of the village, the demand on its infrastructure like sewerage nor of the impact of increasing numbers of commuting traffic.

Full text:

Please accept this email as a record of my formal objection to the H48 & H47 components of the Barford New Local Plan.
My objections are based on the following comments / observations:
The Warwick District Council Local Plan of 2013 allocated a maximum of 90 houses to Barford. The Barford Neighbourhood Plan, which was produced following Government recommendations that Local Communities should have more say in Local Affairs has been totally ignored. This is despite an immense amount of effort by the Barford community to support the need for new housing. The maximum number of 90 has already been exceeded with 109 houses been built / planned. We understand that the Barford Neighbourhood Plan has been side lined and the Local 2013 Plan has been rejected by Government because it did not meet the housing needs of Coventry. Whilst we are naturally sympathetic to the housing needs of the people of Coventry, surely building houses nearly 20 miles away in a sleepy Warwickshire village with nothing like the infrastructure they are used to will only bring unhappiness to the those people of Coventry and major disruption to Barford, which is already struggling to accommodate the substantial increase in population.
The current planning proposals are simply not taking into account the needs of the village, the demand on its infrastructure e.g., sewerage nor of the impact of increasing numbers of commuting traffic.
Your plans are too much too soon and will destroy the community of Barford.

Object

Proposed Modifications January 2016

Representation ID: 68713

Received: 18/04/2016

Respondent: Toby Jones

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

- Not properly reviewed the Greenbelt boundary within the district to effectively plan the delivery of houses north of Warwick and Leamington Spa.
- Development is too fast - will have an adverse impact upon the cohesion of the community.
- increase in traffic and number of accidents.
- need proper access and design

Full text:

1 - Need
These houses clearly do not meet a current local demand but that of Coventry overspill. They would be better suited further to the north along the A46. It remains disappointing that WDC has not sought to properly review the Greenbelt boundary within the District in order to effectively plan the delivery of houses north of Warwick and Leamington Spa.

2 - Community Cohesion
Communities can only grow at a certain pace. Any faster and the special qualities that help to bind them start to break and strain. We were promised 100 or so additional houses in this plan period, which we accepted. This additional development so soon would have a tangible and adverse impact upon the cohesion of our community. We do not want to be another anonymous settlement (the way Wellesbourne has gone). Sure we need development, but limit the pace of delivery in villages to a sustainable level.

It would be a tragedy if the fruits of our fantastic community effort (the shop and the playing fields) were used as an excuse to deliver unsustainable further growth that would serve to harm that very same community.

3 -Traffic
As an unfortunate byproduct of highway improvements at Gallows Hill, Barford has become a route of choice to access Warwick Business Park. The traffic baseline seems to have substantially increased on Bridge Street, High Street and Church Street recently
The Gallows Hill traffic combined with a busy A429 means that it can take up to 10 minutes to get out of the village onto the bypass in the morning. Further houses will exacerbate the problem and without wishing to be over dramatic, I suspect at some stage impatience will cause another fatality or serious accident.

4 - Access and Design.
If these sites are to be imposed on us, then I urge careful and meaningful design. Taylor Wimpey together with WDC have proved incapable of delivering anything other than the lowest possible design standards on Nursery Meadows. In a village characterised by red brick walls, WDC and Taylor Wimpey felt that it was appropriate in the Conservation Area to deliver the primary access road sandwiched between a derelict post and rail fence and a close board fence with a couple hanging baskets nailed to it!. In the future when the fence has been partly replaced and stained various colours (and the hanging baskets have long since rusted away), it will look like a slum. Add to this the fact that the main axis of the approach road is terminated by the blank rear wall of a double garage. It really is awful. Please don't let these lowest possible standards carry on to "Phase 2".

Area H48 is tucked away behind properties along Wellesbourne Road. It would be easy for it to become yet another isolated enclave of development remote from its access to Wellesbourne Road. I urge any proposals to include meaningful green infrastructure including linked green spaces and paths / cycleways that form part of a useful and interesting network around the village. The new development should be "knitted in" to the existing social and built fabric and not isolated from it.

Object

Proposed Modifications January 2016

Representation ID: 68739

Received: 22/04/2016

Respondent: Mr Ken Hope

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

- The rate of growth in Barford is well over the rate of sustainability.
- Badford is being turned into a high grade housing estate for wealthy commuters, it will no longer be a village for all types of people.
- Due to the delay in accepting the local plan, more un-needed houses in the community.
- The growth rate of the village is accelerating so the remaining ones should not be built for 10-15 years.
- Increase in the housing will increase the school and commuter traffic.

Full text:

I am entering my objections to items H47 and H48 in Barford for the revised Local Plan

The rate of growth of the village of Barford is well over the rate of sustainability.

My main objections are as follows

1. For an undefined reason Barford has been upgraded to a 'growth' village. It is being turned into a high grade housing estate for wealthy commuters. It will no longer be a village for all grades of people.

2. Because of the delays in getting the Local Plan accepted, there have been a number of 'infill' permissions granted over and above previously agreed figures. And over and above the Neighbourhood Plan agreed figures. This seems to be a ploy to ignore any agreed planning figures - more delays have meant more un-needed houses for the community.

3. The growth rate of the village housing is accelerating. It has been a greater than 10% growth over this 5 year period. It is important that there must be a period of consolidation so that the extra 75 houses are not built until the occupiers have been absorbed into the community. The remaining ones should not be built until a further ten of the fifteen years have passed.

4. Because of the great planned increase in housing to the south and the north of Warwick, the school and commuter traffic will be increased much much further. The WCC method of estimating traffic based on the 24 hour number of vehicles rather than the peak hours is in effect non existent. Part of the Local Plan should include the REAL measured traffic volumes with genuine estimates of increase due to the additional building. The High St / Church St peaks are already running at well over 12 vehicles per minute for the morning 1 to 2 hours. This can only get worse and there should be an alternative route for the Warwick southern by-pass.

Object

Proposed Modifications January 2016

Representation ID: 68773

Received: 21/04/2016

Respondent: Ms Sue Machado

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

- Provide the Extra Housing required nearer to job opportunities and adequate current transport infrastructure rather than exacerbating the congestion problems on the narrow village roads and motorways in and around Barford.
- Cars are parked over pavements congesting the main roads through Baford.
- Proposed 75 houses will increase the number of cars around 150 on village roads.
- The village sewage system is overloaded and other infrastructure is already at maximum tolerance.

Full text:

WDC Local Plan 2013 allocated 70-90 houses to Barford. The Barford Neighbourhood Plan, under Government recommendation that Local Communities should have more say in Local Affairs. Despite such outstanding effort by that Committee on our behalf 109 houses (already exceeding our quota) have been granted Planning Permission in Barford. The Barford Neighbourhood Plan has been side lined and the Local 2013 Plan has been rejected by Government because it did not meet the housing needs of Coventry.

It is now up to Planners to provide the Extra Housing required nearer to job opportunities and adequate current transport infrastructure rather than exacerbating the congestion problems on the narrow village roads and motorways in and around Barford.

The Current Proposals under discussion proposes a further 75 Houses.
Doubling the number of houses of the 2013 Local Plan is unacceptable.

The number of Parking Places in New Housing developments fall far short of acceptable for each house and do not address the issue of extra public spaces for visitors. Cars are parking over pavements on development sites and congesting the main roads through Barford. New proposals do not acknowledge this Planning failure.

Transport Bus Routes offer 1 bus per hour to Leamington and Stratford. There are few buses direct to Coventry. To reach Coventry in time to get to work at 09.00 hrs a bus leaves Barford at 06.52. The earliest bus returning after 17.00hrs is at 17.36 arriving in Barford at 18.44.
All options are UNACCEPTABLE and we can therefore expect another 150 cars from the proposed 75 houses on Village roads.

The Village sewage system, (a 5" pipe running the length of Wellesbourne Road) is already overloaded. Other Infrastuctures are already at maximum tolerance.

Object

Proposed Modifications January 2016

Representation ID: 68810

Received: 28/04/2016

Respondent: Mr Alan Roberts

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

Representation Summary:

Housing would be unsustainable in retaining the rural character of the village and would cause harm to the environment.

Full text:

See attached

Attachments:

Object

Proposed Modifications January 2016

Representation ID: 68943

Received: 20/04/2016

Respondent: Peter Langley

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The cumulative impact of these developments would be expected to have a substantial impact on the character of the village.

Full text:

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.

Object

Proposed Modifications January 2016

Representation ID: 69096

Received: 22/04/2016

Respondent: St. John's College, Oxford

Agent: Savills (L&P) Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The College supports the location of allocations set out in the Local Plan concentrating the majority of growth to the most sustainable locations. The Local Plan continues to support the status of Barford as a Growth Village, due to its existing services and facilities. The College maintains that Barford is a sustainable location for development and that the Local Plan is in accordance with the "golden thread" running through the planning system of sustainable development. The College supports in principle the identification of H47 Land South of Wasperton Lane within the Policy, but object to the extent of the allocation. The allocation should be amended to include the College's wider landownership to accommodate circa 210 dwellings.

Full text:

See attached

Object

Proposed Modifications January 2016

Representation ID: 69142

Received: 22/04/2016

Respondent: Mr Ken Hope

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object: -
- Barford not a growth village
- infill permissions granted in addition to agreed figures / Neighbourhood Plan figures
- growth rate accelerating - more than 10% growth over last five years. additional housing shouldn't be built until new housing absorbed,
- additional traffic will be generated

Full text:

I am entering my objections to items H47 and H48 in Barford for the revised Local Plan

The rate of growth of the village of Barford is well over the rate of sustainability.

My main objections are as follows

1. For an undefined reason Barford has been upgraded to a 'growth' village. It is being turned into a high grade housing estate for wealthy commuters. It will no longer be a village for all grades of people.

2. Because of the delays in getting the Local Plan accepted, there have been a number of 'infill' permissions granted over and above previously agreed figures. And over and above the Neighbourhood Plan agreed figures. This seems to be a ploy to ignore any agreed planning figures - more delays have meant more un-needed houses for the community.

3. The growth rate of the village housing is accelerating. It has been a greater than 10% growth over this 5 year period. It is important that there must be a period of consolidation so that the extra 75 houses are not built until the occupiers have been absorbed into the community. The remaining ones should not be built until a further ten of the fifteen years have passed.

4. Because of the great planned increase in housing to the south and the north of Warwick, the school and commuter traffic will be increased much much further. The WCC method of estimating traffic based on the 24 hour number of vehicles rather than the peak hours is in effect non existent. Part of the Local Plan should include the REAL measured traffic volumes with genuine estimates of increase due to the additional building. The High St / Church St peaks are already running at well over 12 vehicles per minute for the morning 1 to 2 hours. This can only get worse and there should be an alternative route for the Warwick southern by-pass.

Object

Proposed Modifications January 2016

Representation ID: 69189

Received: 13/04/2016

Respondent: Barford, Sherbourne and Wasperton Joint Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Accept need to accommodate Coventry overspill but 1/3 should not be passed to WDC - should be placed close to north and Coventry
More allocation should have been made in green belt and nearer source of need
Impact of new sites on local roads has not been adequately considered
Inadequate consultation

Full text:

See attached

Attachments:

Object

Proposed Modifications January 2016

Representation ID: 69576

Received: 21/04/2016

Respondent: Mr Rod Scott

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Additional housing required to meet Coventry's needs so will cause additional traffic - increase congestion and pollution
Mains drainage does not have sufficient capacity
Lack of public facilities and services
Adverse impact on village character of unsustainable growth

Full text:

See attached
The on-line response procedure did not allow comments to H47 and H 48 (the sections which apply to Barford - H48 is missing from the list in Appendix B

* H19 - Baginton - Land north of Rosswood Farm
* H47 - Barford - Land south of Wasperton Lane
* H49 - Bishops Tachbrook - Seven Acre Close
* H
As you can see from the section below - it is not possible to comment on H48 as there is no pencil Icon to click

INSERTED: H47 INSERTED: Barford - Land south of Wasperton Lane INSERTED: 30 INSERTED:0
INSERTED:H48 INSERTED: Barford - Land South of Westham Lane INSERTED: 45 INSERTED:0
H23 Bishops Tachbrook - Land south of the school INSERTED:Included in
commitments 0

The response form (attached) requires specialist knowledge to comment on the 'soundness' of the plan and as such will have deterred many people. The cynical observer might be misled into thinking that comments are not wanted.
Ps - I have just noted this proposed deletion which is inserted without reference or explanation. (following)
It appears that the rate of growth of villages was seen as an important factor - but is now to be sacrificed.
Probably - that says it all - Housing provision numbers is the only consideration - where the houses are, whether they are sustainable - the effect on existing communities are all of no importance.

Village Allocations
INSERTED: 2.56 The majority of the village housing allocations are located on the edge of the existing limits to the built up areas of the village in locations which will provide natural extensions, DELETED: Large sites of over 50 dwellings will be brought forward in phases (see Policy H10) so that the growth of the village can take place more slowly and in proportion to the size of the settlement. This will provide a greater opportunity for the new communities to integrate into the life of the village and for housing to meet local needswhich will change over the lifetime of the Plan.

Attachments:

Object

Proposed Modifications January 2016

Representation ID: 70131

Received: 19/04/2016

Respondent: Mr. Charles Cadogan

Agent: Carter Jonas

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Our client holds a lifetime tenancy under the Agricultural Holdings Act 1986 and strongly objects to the principle of developing the land for housing. I attach a Site Plan showing the land subject to this representation.
Policy DS11 identifies a new total of 50 allocated housing sites including the subject of this representation; It is suggested that the land could accommodate approximately 30 dwellings.
The site comprises 1.31 ha agricultural land on the eastern edge of Barford. The land subject to this representation forms part of a larger, well-defined, parcel of agricultural land. Wasperton Farmhouse, a Grade II listed building, is located approximately 200 metres to the south.
Based on the identified NPPF and Local Plan policies, which are material considerations, allocation of this Grade 2 agricultural land for housing development is not acceptable in principle as the local planning authority should be safeguarding the best and most versatile agricultural land and seeking to develop on poorer quality land.
Development of the site would result not only in the perpetual loss of 1.31 hectares of Grade 2 agricultural land but also have a detrimental effect on the quality of the larger (approx.18 hectares) land parcel affecting the overall agricultural enterprise opportunity that it presents.
2. Physical Constraints and Impacts identified in the SHLAA
Physical constraints and potential development impacts put into question the overall suitability of the site for development in the SHLAA. The site is identified as having a high/medium landscape value. The risk of development encourages erosion of the agricultural landscape and also sprawl. There is a risk of surface water flooding on parts of the site. The development would have detrimental effect on the character of the open countryside and setting of the village.
3. Effect on the Setting of the Listed Building
The site abuts the track which provides an access to the listed building from Wasperton Lane. Development would bring the built area much closer to the listed building which is currently surrounded largely by open countryside and would result in substantial harm of the setting of the listed building contrary to the Local Plan and NPPF.
4. Emerging Neighbourhood Development Plan
Barford, Sherbourne and Wasperton Joint Parish Council have prepared a Neighbourhood Development Plan (NDP). Once adopted, it will be a material consideration. Policy B1 (Future Housing Development) does not consider this as a preferred housing site.
Wasperton Lane is identified specifically as a 'Green Corridor'. Paragraph 5.39 identifies the views west along Wasperton Lane as being a protected view or vista.

Full text:

See attached