Issue and Options 2023
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Results for Keep Our Green Belt Green, Coventry and Warwickshire search
New search• Issue S6: A review of Green Belt boundaries Green Belt boundaries should remain as they are. Housing should be concentrated within existing boundaries. A greater density of housing will reduce carbon emissions. Research shows that suburban homes produce 2 to 4 times as much CO2/person as city centre dwellings. All of the land taken out of green belt for unmet Coventry need should now be returned to green belt, as the alleged population bonanza never happened – specifically land between Coventry, Kenilworth, and Warwick University should be returned to green belt. I endorse the CPRE document attached.
The local plan must require Brownfield be developed first, before building on open green fields. According to the latest published brownfield registers, there are very substantial areas of brownfield currently available [806ha] , sufficient for 32,245 homes. Even if one accepts the HEDNA, which I do not, this would provide housebuilding land for 8-9 years of building in the Coventry and Warwickshire housing market area at 3,500 dwellings/year. As policy measure, no green field land should be allocated for development until a plan review, and any following plan r eview, determines that therre is an actual need for green field land, to service the realistic population growth of t he area – At the first 5 year review of the plan, we will be able to see the result of windfalls, and make an interim assessment of housing need on the basis of local evidence [births, deaths, school populations, electoral role, job creation, car registrations, NI registrations, gas and electric use, student migration, etc]. The There should be an explicit commitment to brownfield first in accord with the Secretary of State’s, letter of 5 Dec 2022 to MPs which announces a section entitled “Brownfield first”. Local authority date ha brownfield north warks mar2022 13.61 rugby mar2020 17.14 Coventry 2022 102.5376 Warwick 2022 72.05 Stratford 2019 600.784 806.1216 homes at 40/ha 32,245
No: The HEDNA is NOT a reasonable basis for assessing future need because: 1. It assumes a very low level of windfalls, just 220/yr, when the actual figures have averaged 901/year. 1. If the actual average since 2011 – 901 - is used, the plan is in surplus: 5,255 excess house spaces in 2040; 3610 excess in 2045. 1965 in 2050. 2. The HEDNA wrongly assumes that the ONS treatment of births and deaths in the Mid Year Estimates is broadly correct, after adjusting fertiility rates. The graph below, shows a sharp divergence between what ONS predicted in SNPP2014 [which is calculated in the same way as the MYE], and reality, especially in Coventry. 1. Across the region, and especially in Coventry, ONS has grossly overestimated births, and underestimated deaths. In 2021 The overestimate of births in the HMA was 1700 [comparing actual vs SNPP2014] . Converseley, in 2019, the last ‘normal’ year before the pandemic, deaths across the HMA were underestimated by 633. Taking births and deaths together, natural change was overestimated by [1700+633] = 2333 in a single year. If this gap between forecast and reality continued across the plan, housing need would be overestimated by 27,387. 2. ONS forecasts of births and deaths [in the SNPP and MYE] are NOT a reliable basis for projecting future population change and consequent housing need. We disagree with the underlined statement in the HEDNA, “5.122 When looking at migration our starting point is to consider how different migration has been over the 2011-21 period than was previously estimated by ONS. Essentially the difference in population growth between the two sources is likely to be attributable to migration, this is on the basis that it is expected that births and deaths have been fairly well recorded by ONS. While we trust the recording of births and deaths, we do not accept at all the ONS forward forecast of births and deaths – adjusting fertility and mortality rates upward will make these forecasts worse, not better if ONS trend assumptions, of increasing births, and decreasing deaths, are followed. . Q-H1-2: If your answer to H1-1 is No, what would be a more appropriate approach to calculating future housing needs for this Local Plan? WE NEED TO SEE THE FULL MODELLING. It is impossible to critically evaluate the HEDNA because the underlying spreadsheets have been concealed. EIR requests to all of the HMA local authorities for the modelling beneath the HEDNA were refused on the grounds that the information is confidential. This is an absurd claim. Without being able to see the working, and the assumptions, the public cannot exercise it’s right, under the Aarhus convention to participate in Environmental decision making. We are being told by Iceni “Trust us. These are our conclusions.” This totally prevents proper scrutiny. In contrast, ONS, despite their other failings, does make available the full components based spreadsheets for future growth, including births, deaths, internal immigration and emigration, international immigration and emigration, and cross border migration. The best guide to future housing need, at present, is to forecast forward the actual population growth of the last 10 years and housing completions. This is the best data we have, as rough and ready as it may be. Current data, about migration, is extremely poor, both for international migration and internal migration. At the very least, any model should include 1) knowledge of the movement of foreign students, which can be obtained from HESA data and the Home office exit checks data. Student movement needs close attention. For Coventry, in 2014-15, the SNPP hugely understated emigration among foreign students, at the two Coventry universities by 3,500-4,000/yr. Population modelling must include the latest administrative data including the electoral role, car ownership, gas and electric usage, refuse collected, housing completions, pensions and benefits, numbers of student accommodations, school populations, jobs created, economic growth, NI registrations, new GP registrations, vaccinations etc. The HEDNA has not incorporated most of these figures. The SNPP rely on unreliable sources: the International Passenger Survey for international migration, and GP registrations for internal migration. There is better information available.
Land within the Green Belt should not be safeguarded for future infrastructure schemes
the development strategy of South Warwickshire should be both deliverable and viable
I support a focus on growth in areas of high levels of connectivity. However, consideration of small settlement location C.17 South Coventry should not overlook that this area is included in the Warwick Local Plan and as a result outline permission had already been granted for 425 dwellings. Similarly, where outline permission has been granted at Kings Hill [ for 2500 homes] , at Thickthorn, Glass Lane and Crewe Lane . This area, south of Coventry, while it may have good connectivity, is already very congested. New development in this area, should not be considered because it would completely wipe out the gap between Coventry and Kenilworth.
Issue S6: A review of Green Belt boundaries As stated above, there should be a moratorium on green field or green belt building for 5 to 10 years, to see how house building needs evolve, and to include real information about population change. In that time Green Belt boundaries should not be changed.
