Preferred Options

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Object

Preferred Options

PO1: Preferred Level of Growth

Representation ID: 48980

Received: 16/10/2012

Respondent: Friends of the Earth

Representation Summary:

Development and investment should be concentrated on the regeneration of the major urban centres of the region.
Continued population growth and expansion of the urban areas is not sustainable in the long term and expansion should be minimised to retain the countryside for future generations.
Development on greenfield land risks destroying the quality of the environment
that presently makes the District such an attractive place to live.
Most local people support lower levels of growth. There are 13 alternative projections in the SHMA, which does not specifically recommend any of them. We are very concerned that only three have been chosen, apparently arbitrarily, for further consideration. It is clear that this is critical for the future of the District, and there is no justification given for the selection of the projections chosen.
Housing demand is not directly connected with economic activity but is more because the District is a pleasant place to live. It should be noted that housing growth is not essential for a healthy economy

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Support

Preferred Options

PO2: Community Infrastructure Levy

Representation ID: 48981

Received: 16/10/2012

Respondent: Friends of the Earth

Representation Summary:

Support

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Support

Preferred Options

PO3: Broad Location of Growth

Representation ID: 48982

Received: 16/10/2012

Respondent: Friends of the Earth

Representation Summary:

Generally support this Preferred Option, but not all its supporting notes or locations of growth.

Proposed density of housing on brownfield land could be at least doubled without any loss of design quality.

Paragraph 7.14 is fundamentally flawed, in that the proposals for 'Garden Suburbs' would in fact increase sprawl around the towns, and in fact destroy the 'rural character' rather than preserve it. Low density suburbia, no matter how well designed, can never be a good replacement for real countryside.

Proposed densities (30 dph) are too low and higher densities (100 to 200 dph)could reduce demand for greenfield land and is achievable. It is possible to achieve such densities with the benefit of good design without compromising the character of our towns and the quality of public open spaces.

There is inconsistency about denisties - 100 dph at Fire Station and only 35 dph at Blackdown.

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Object

Preferred Options

Mixed Communities and a Wide Choice of Homes

Representation ID: 48984

Received: 16/10/2012

Respondent: Friends of the Earth

Representation Summary:

Proposed densities are too low and result in too much landtake. It is possible to design high quality new develop ment at 100 or even 200 dph.
Concentration should b on smaller units rather than family housing to enable larger units to be freed up for younger families

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Object

Preferred Options

PO4: Distribution of Sites for Housing

Representation ID: 48985

Received: 16/10/2012

Respondent: Friends of the Earth

Representation Summary:

Do not support the Northern Relief Road - not be a sustainable policy as it would lead to more use of the private car at the expense of more sustainable forms of transport. It would be contradictory to other policies in the Local Plan.

The choice of sites should be determined by the quality of the proposed land in both Landscape Value and Agricultural Quality terms. This is very much the thinking in the NPPF.

If allocations need to be made, that they should first take place in locations outside the Green Belt rather than in it. Support brownfield allocations.

If greenfield allocations need to be made, we support the allocation of land 'West of Europa Way (W08/ W21), and suggest this should be allocated first, as this is of low to medium landscape value and it is close to employment areas therefore potentially minimising travel to work distances and associated CO2 emissions.

If further allocations are to be made, we support the allocation of land of Medium Landscape Value at Campion School /Whitnash East /South Sydenham (L10/L39); Golf Lane, Whitnash (L11); and Woodside Farm, Whitnash (L14).

Do not support the development of land at Guys Cliffe, Blackdown, Gallows Hill, The Asps, Red House Farm, Northumberland Road or North of Milverton.

Warwick Gates (W20) should be retained as employment land.unless it can be shown that there are more suitable sites for employment available,

If it is necessary to include development in the Kenilworth area, we support the Preferred Option of development at Thickthorn, Kenilworth (K01), as long as a significant proportion of the site is allocated for employment uses.

Development to the south of Leamington Spa and Warwick is generally closer to existing employment areas and transport links than the areas to the north of the towns, so 'cross town trips' (para.7.31) would be minimised by allocating land in the south.

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Support

Preferred Options

PO5: Affordable Housing

Representation ID: 48986

Received: 16/10/2012

Respondent: Friends of the Earth

Representation Summary:

We strongly support the policy that affordable housing is retained as such in perpetuity, and for people with a local connection in rural areas. This is important if sites are to be justified in rural areas. The affordable housing policies seem to be well thought out and reasoned.

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Object

Preferred Options

PO6: Mixed Communities & Wide Choice of Housing

Representation ID: 48989

Received: 16/10/2012

Respondent: Friends of the Earth

Representation Summary:

Disappointed that a figure of 30dph is being used and it is assumed that predominantly houses will be needed when it is clear that the majority of new households over the plan period are likely to be single-person households. There are many recent residential schemes for one and two-person households where 100 to 200dph have been achieved.

The SHMA report suggests the District should make a concerted effort to create 'suitable smaller units' of housing, rather than concentrate on the provision of family houses - if older people move to smaller units, this could free up larger units for younger families. The data shows that 5,700 households could relocate into one or two bedroom units from 3 or 4 bedroom properties.

It would be possible to increase densities on some or all of the sites earmarked for development. There also seems to be some confusion about densities allowed for in the housing figures proposed for some of the sites.

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Object

Preferred Options

PO8: Economy

Representation ID: 48990

Received: 16/10/2012

Respondent: Friends of the Earth

Representation Summary:

Development based on a supposed need for economic growth. Growth per se is unnecessary and unsustainable for a stable economy.
Less land is needed to provide similar numbers of jobs. The figures suggest that there is little need to allocate more employment land.
B1 uses require smaller buildings for the same floorspace as B2 and B8 uses. Has this been allowed for?
Gateway: development and investment should be concentrated on the regeneration of urban centres - there are suitable brownfield sites in Coventry where development could be located rather in the Green Belt. Support paragraph 8.21 that 'further work is needed to clarify this figure in relation to more up to date economic and demographic projections and to examine the impact of potential development at the Coventry and Warwickshire Gateway site'

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Object

Preferred Options

PO10: Built Environment

Representation ID: 48991

Received: 16/10/2012

Respondent: Friends of the Earth

Representation Summary:

'Garden Suburbs' proposals may involve large areas of low-density housing which would use more acreage than if planned to a higher density. It is vital to minimise the land take of new developments. It is possible to plan for higher densities without compromising design and landscaping.

Gardens Towns Prospectus is idealistic and provides little guidance on incorporating this into existing settlements. and densities are low compared to current housing practice. Thiis conventional suburbia with an extravagant use of space and the'benefits' of 'Garden Suburbs' can be achieved at higher densities.

The easiest way of providing affordable homes is to provide more smaller homes and increase the density of them.
Proposals for low-density family housing are in sharp contrast with the type of housing which is likely to be needed, single person housing, mainly for the over 65's -

Need a more proactive policy on reuse of vacant properties and to promote 'homes above shops' to help revitalise urban areas.

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Object

Preferred Options

PO9: Retailing & Town Centres

Representation ID: 48992

Received: 16/10/2012

Respondent: Friends of the Earth

Representation Summary:

Retail study is out of date and is based on demand which assumes growth in population and supercedced requirements from the RSS. NPPF does not require LPAs to plan for retail growth. Do not support proposals for additional retail-led development in Leamington. In addition this policy to encourage people to travel from other parts of the region to do their shopping is unsustainable and in conlfict with transport policies. It could affect Old Town trade.

One worry is that the Study itself says (para 4.3) 'a significant improvement in one centre holds the threat /promise of drawing trade from others'.

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