Revised Development Strategy

1.1 We strongly oppose the scale of housing growth that the Development Strategy proposes. The The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

1.2 The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and unless much of this is by windfall development within the urban areas.

1.3 The proposals to impose 100-150 houses on each of five villages, and 70-90 on five others, would in most cases damage their rural character and unbalance their structure.


2. Principles of the Development Strategy

2.1 A main aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years. There is no demand from the residents of the area for this aim and it has not been subject to public participation as to whether it should be the principle underlying the Plan.

2.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

2.3 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

2.4 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.

2.5 The justification for the scale of housing proposed is not made. The ONS and SHMA figures include a large element of in-migration of population into the area. It is this assumption of in-migration that leads to the high household numbers forecast and the claim that 12,300 houses are required between 2011 and 2028. The Development Strategy fails to show the actual household increase that would result from accurate application of the 2011 Census and trends in migration in most recent years.

2.6 Other representations set out the reasons for a lower housing requirement, 5,300 over the period 2011-2028 or 250 new dwellings per year. This is an achievable and acceptable level of housing provision and should be adopted by the Council. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The annual housebuilding rate proposed in the Development Strategy has not been achieved in the past and is unrealistic.

2.7 The justification for the high housing numbers is expressed by the Council as being to 'achieve economic growth rates in line with national forecasts' (para 4.1.6). Para 4.1.10 claims that economic growth in the District is linked to providing additional houses. The aim therefore appears to be to encourage in-migration by providing more housing so that more employment is provided in the area to create more 'GVA' (growth).

Not only has this aim of the Development Strategy not been subject to public consultation; it is is wholly contrary to the interests of Warwick District. It is the attractiveness of the District's towns, villages and countryside and the strict control on development that makes it economically successful. The employment growth (much in small businesses and people working from home) has not required new employment land and there has been relatively little rebuilding of existing office accommodation. There is in fact a surplus of employment land and some is not used (see paras 4.5.18-20) while the District already 'has a good range of land within its employment portfolio'. No case has been made for releasing any greenfield land for employment over what is already available.



3. Proposed Locations for Housing Development

3.1 The previous consultation (Preferred Options) proposed 'growth across the District' including on Green Belt, and in villages. The large-scale development of Green Belt north of Leamington has been withdrawn, but Green Belt development at Thickthorn, Kenilworth, at Cubbington, and adjacent to certain villages now 'washed over' by Green Belt is still proposed. The proposals for development in Green Belt at Hampton Magna, Lapworth (Kingswood), Burton Green, and Baginton are strongly opposed.

3.2 The scale of development between Warwick, Warwick Castle Park, Leamington, Whitnash and Bishops Tachbook is unacceptably large. A rural landscape which is not 'urban fringe' but valuable agricultural land would be urbanised. The eastern side of Warwick Castle Park, which past policy has kept rural, would be partly built-up. Harbury Lane should remain the southern boundary of the built-up area of Warwick & Leamington, a function it has performed effectively since the Warwick Technology Park and the housing location known as 'Warwick Gates' were developed under past Plans.

3.3 This major location would not only develop valuable open countryside. It would be car-served development since it would be too far from the town centres for walking, cycling facilities are limited, the railway stations are not near it and bus services in the District have low useage and are not generally attractive. The traffic impact of the development proposed would be so great that Warwick's historic town centre would be heavily congested and polluted by the additional traffic. Routes in and out of central Leamington area already congested at peak hours and condiktions would worsen.

3.4 The proposals for 100-150 houses at each of the non-Green Belt villages - Radford Semele, Bishops Tachbook and Barford - would overwhelm these villages. Smaller numbers may be acceptable over a long period but not development on that scale.

3.5 These housing proposals are not sustainable development, in contrast to the three brownfield site proposals within Leamington Spa which meet sustainability prlnciples.


4. Gypsies and Travellers

4.1 CPRE has commented separately on the Gypsy and Traveller Sites consultation document. We would emphasise the opportunity to co-operate with Coventry City Council to expand provision at Siskin Drive, where the boundary runs through the existing employment areas.


5. Proposals for Employment Land

5.1 In August 2012 we responded to WDC's Preferred Options raising issues including the amount and location of employment land proposed in the emerging plan. Our conclusion on employment land in 2012 was that "no new development of employment land in the Green Belt is justified". The Revised Development Strategy increases our concerns that WDC's emerging plan is unsound.

5.2 Section 3.5 of the Revised Development Strategy (May 2013) summarises sustainable development principles including "avoiding coalescence". But WDC's proposals fail to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The proposals are not sustainable.

5.3 There is in fact an excess of employment land already available in Warwick District. The issue of the amount of employment land is mainly caused by WDC's approach to the assessment of Employment Land Requirements. This approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in the proposed policy RDS6 which specifies that 22.5 hectares of new employment land should be allocated between 2011 and 2029, mostly in the Green Belt.

5.4 Table 4 shows the detail behind the claimed deficit; this is reproduced below.

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 16.5
C. Potential redevelopment of existing employment areas 13.5
D. Total gross employment requirement (demand) 66

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Balance to be allocated 17.5
(15 to 25)


5.5 Section 4.5.8 then takes the bottom line (Row H 'Balance to be allocated') figure of 17.5ha and increases this figure to 22.5ha in order "to allow for flexibility and the assumptions used in modelling and forecasting". The latter 'buffer' of 5ha overlaps with the Item B 'Margin to provide flexibility of supply' of 16.5ha. This is double counting. Error in modelling/ forecasting can go either way (plus or minus), not just one direction. The claim that "it is reasonable to provide an additional 22.5 hectares of employment land" is entirely unreasonable.

5.6 The established requirement (Item A) is 36ha; against this, 16.5ha 'Margin to provide flexibility of supply' is itself excessive: almost 50% extra on top of the established demand of 36ha in order to provide 'choice'; this seems to be an unjustified excessive amount of flexibility. The environment cannot afford such generous luxury of flexibility. A 10% contingency should be sufficient 3.6ha rather than 16.5ha.

5.7 The final component in the demand side of the table above is Item C 'Potential redevelopment of existing employment areas', amounting to 13.5ha. Although this seems at first sight to be supply rather than demand, more employment land is claimed to be needed because of the unjustified change of use of existing employment land, removing it all from the employment portfolio and allocating it to housing. Sections 4.5.19-4.5.20 (and 4.2.4) describe the proposal to remove 19.5ha of existing employment land and replace it with 13.5ha of new employment land.

5.8 The proposal to take all of this land out of the employment portfolio conflicts with other sections of the consultation document. Section 4.3.9 makes quite clear that some of the 'tired' employment land could be released for housing development. No justification is provided for taking all of the land out of employment use; there seems to be no reason why such employment land should not be redeveloped for continuing employment purposes (if demand is really there). It is extreme to assume that all of this land will be 'lost' to employment uses. It is not acceptable to take brownfield land in urban areas out of the employment portfolio and replace it with greenfield land outside urban areas, much in the Green Belt. The strategy should be to improve effective use of the 19.5ha for continuing employment use.

5.9 Established numbers in the above table show the base demand as 36ha (Item A) and the base supply as 48ha (Item F). The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample flexibility and margin for error. A corrected version of Table 4 is provided below:

Table 4 Revised

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 3.6
C. Increased effectiveness of use of existing employment areas 0
D. Total gross employment requirement (demand) 39.6

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Excess providing even more contingency and flexibility 8.9



5.10 Through double counting, unreasonable buffers and unjustified changes of use, WDC has transformed an excess of employment land of 8.9ha into a misleading claimed deficit of 22.5ha. This cannot be justified. The misleading claimed deficit is then used to try to justify development of new employment land in the Green Belt (section 4.6):
* Thickthorn (8ha) between Kenilworth and the A46;
* Part of the Coventry Gateway site (6.5ha) around Baginton and Coventry Airport.

5.11 By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

5.12 The Revised Development Strategy goes on to allocate a "Sub-Regional Employment Site" (Policy RDS8). Section 5.5 is based on an extant planning application, presenting claims from the planning application as though they were sufficient justification for the District's development strategy.

5.13 The first issue with Section 5.5 is evident in its title: the meaning of 'sub-regional' is not defined. The Regional Spatial Strategy has been abolished but the justification in section 5.5 still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with the the abolition of the RSS and makes the proposed strategy unsound. The long- established economic partnership in the area is CSW - Coventry, Solihull and Warwickshire - but the Revised Development Strategy focuses on the Coventry & Warwickshire City Deal and the CWLEP. In practice, the 'sub-region' is an artificial construct with no proven need.

5.14 While Section 5.5 purports to be describing a generic employment site for predominantly B1, B2 and B8 uses, it depends on the justification for the specific uses proposed in the Coventry Gateway application even though this focuses on the Gateway's proposed B1(b) (research and development) sub-class, for example. Policy RDS8 as described when the consultation document was written (before the planning committee considered the Coventry Gateway application in June 2013) is little more than pre-determination of the Coventry Gateway application.

5.15 Even if a 'sub-regional' need were justified, no justification is provided for siting it entirely in Warwick District and in the Green Belt. Considering that any 'sub-region' contains at least Coventry, North Warwickshire, Nuneaton & Bedworth, Rugby, Stratford upon Avon and Warwick, what is the justification for locating the 'sub-regional employment site' within Warwick District? Policy RDS8 would either take jobs from areas with greater need (unemployment is considerably higher in Coventry and Rugby, for example) or add further to the excess of employment land in Warwick District. The proposed site location undermines the well-established principle of urban regeneration, fails to recognise the brownfield-first policy (e.g. NPPF section 111) and would be inappropriate development in the Green Belt. Locating a major employment site in a rural area would increase the need to travel, particularly by car. The proposed criteria claimed to justify such a development in the Green Belt depend on policies of the abolished RSS (e.g. Coventry & Nuneaton Regeneration Zone) and vague concepts such as 'sub-regional need'.

5.16 The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". Policy RDS8 fails to meet this requirement. The proposed policy is not justified, it would damage the environment and it should be removed.

1.1 We strongly oppose the scale of housing growth that the Development Strategy proposes. The The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

1.2 The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and unless much of this is by windfall development within the urban areas.

1.3 The proposals to impose 100-150 houses on each of five villages, and 70-90 on five others, would in most cases damage their rural character and unbalance their structure.


2. Principles of the Development Strategy

2.1 A main aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years. There is no demand from the residents of the area for this aim and it has not been subject to public participation as to whether it should be the principle underlying the Plan.

2.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

2.3 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

2.4 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.

2.5 The justification for the scale of housing proposed is not made. The ONS and SHMA figures include a large element of in-migration of population into the area. It is this assumption of in-migration that leads to the high household numbers forecast and the claim that 12,300 houses are required between 2011 and 2028. The Development Strategy fails to show the actual household increase that would result from accurate application of the 2011 Census and trends in migration in most recent years.

2.6 Other representations set out the reasons for a lower housing requirement, 5,300 over the period 2011-2028 or 250 new dwellings per year. This is an achievable and acceptable level of housing provision and should be adopted by the Council. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The annual housebuilding rate proposed in the Development Strategy has not been achieved in the past and is unrealistic.

2.7 The justification for the high housing numbers is expressed by the Council as being to 'achieve economic growth rates in line with national forecasts' (para 4.1.6). Para 4.1.10 claims that economic growth in the District is linked to providing additional houses. The aim therefore appears to be to encourage in-migration by providing more housing so that more employment is provided in the area to create more 'GVA' (growth).

Not only has this aim of the Development Strategy not been subject to public consultation; it is is wholly contrary to the interests of Warwick District. It is the attractiveness of the District's towns, villages and countryside and the strict control on development that makes it economically successful. The employment growth (much in small businesses and people working from home) has not required new employment land and there has been relatively little rebuilding of existing office accommodation. There is in fact a surplus of employment land and some is not used (see paras 4.5.18-20) while the District already 'has a good range of land within its employment portfolio'. No case has been made for releasing any greenfield land for employment over what is already available.



3. Proposed Locations for Housing Development

3.1 The previous consultation (Preferred Options) proposed 'growth across the District' including on Green Belt, and in villages. The large-scale development of Green Belt north of Leamington has been withdrawn, but Green Belt development at Thickthorn, Kenilworth, at Cubbington, and adjacent to certain villages now 'washed over' by Green Belt is still proposed. The proposals for development in Green Belt at Hampton Magna, Lapworth (Kingswood), Burton Green, and Baginton are strongly opposed.

3.2 The scale of development between Warwick, Warwick Castle Park, Leamington, Whitnash and Bishops Tachbook is unacceptably large. A rural landscape which is not 'urban fringe' but valuable agricultural land would be urbanised. The eastern side of Warwick Castle Park, which past policy has kept rural, would be partly built-up. Harbury Lane should remain the southern boundary of the built-up area of Warwick & Leamington, a function it has performed effectively since the Warwick Technology Park and the housing location known as 'Warwick Gates' were developed under past Plans.

3.3 This major location would not only develop valuable open countryside. It would be car-served development since it would be too far from the town centres for walking, cycling facilities are limited, the railway stations are not near it and bus services in the District have low useage and are not generally attractive. The traffic impact of the development proposed would be so great that Warwick's historic town centre would be heavily congested and polluted by the additional traffic. Routes in and out of central Leamington area already congested at peak hours and condiktions would worsen.

3.4 The proposals for 100-150 houses at each of the non-Green Belt villages - Radford Semele, Bishops Tachbook and Barford - would overwhelm these villages. Smaller numbers may be acceptable over a long period but not development on that scale.

3.5 These housing proposals are not sustainable development, in contrast to the three brownfield site proposals within Leamington Spa which meet sustainability prlnciples.


4. Gypsies and Travellers

4.1 CPRE has commented separately on the Gypsy and Traveller Sites consultation document. We would emphasise the opportunity to co-operate with Coventry City Council to expand provision at Siskin Drive, where the boundary runs through the existing employment areas.


5. Proposals for Employment Land

5.1 In August 2012 we responded to WDC's Preferred Options raising issues including the amount and location of employment land proposed in the emerging plan. Our conclusion on employment land in 2012 was that "no new development of employment land in the Green Belt is justified". The Revised Development Strategy increases our concerns that WDC's emerging plan is unsound.

5.2 Section 3.5 of the Revised Development Strategy (May 2013) summarises sustainable development principles including "avoiding coalescence". But WDC's proposals fail to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The proposals are not sustainable.

5.3 There is in fact an excess of employment land already available in Warwick District. The issue of the amount of employment land is mainly caused by WDC's approach to the assessment of Employment Land Requirements. This approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in the proposed policy RDS6 which specifies that 22.5 hectares of new employment land should be allocated between 2011 and 2029, mostly in the Green Belt.

5.4 Table 4 shows the detail behind the claimed deficit; this is reproduced below.

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 16.5
C. Potential redevelopment of existing employment areas 13.5
D. Total gross employment requirement (demand) 66

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Balance to be allocated 17.5
(15 to 25)


5.5 Section 4.5.8 then takes the bottom line (Row H 'Balance to be allocated') figure of 17.5ha and increases this figure to 22.5ha in order "to allow for flexibility and the assumptions used in modelling and forecasting". The latter 'buffer' of 5ha overlaps with the Item B 'Margin to provide flexibility of supply' of 16.5ha. This is double counting. Error in modelling/ forecasting can go either way (plus or minus), not just one direction. The claim that "it is reasonable to provide an additional 22.5 hectares of employment land" is entirely unreasonable.

5.6 The established requirement (Item A) is 36ha; against this, 16.5ha 'Margin to provide flexibility of supply' is itself excessive: almost 50% extra on top of the established demand of 36ha in order to provide 'choice'; this seems to be an unjustified excessive amount of flexibility. The environment cannot afford such generous luxury of flexibility. A 10% contingency should be sufficient 3.6ha rather than 16.5ha.

5.7 The final component in the demand side of the table above is Item C 'Potential redevelopment of existing employment areas', amounting to 13.5ha. Although this seems at first sight to be supply rather than demand, more employment land is claimed to be needed because of the unjustified change of use of existing employment land, removing it all from the employment portfolio and allocating it to housing. Sections 4.5.19-4.5.20 (and 4.2.4) describe the proposal to remove 19.5ha of existing employment land and replace it with 13.5ha of new employment land.

5.8 The proposal to take all of this land out of the employment portfolio conflicts with other sections of the consultation document. Section 4.3.9 makes quite clear that some of the 'tired' employment land could be released for housing development. No justification is provided for taking all of the land out of employment use; there seems to be no reason why such employment land should not be redeveloped for continuing employment purposes (if demand is really there). It is extreme to assume that all of this land will be 'lost' to employment uses. It is not acceptable to take brownfield land in urban areas out of the employment portfolio and replace it with greenfield land outside urban areas, much in the Green Belt. The strategy should be to improve effective use of the 19.5ha for continuing employment use.

5.9 Established numbers in the above table show the base demand as 36ha (Item A) and the base supply as 48ha (Item F). The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample flexibility and margin for error. A corrected version of Table 4 is provided below:

Table 4 Revised

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 3.6
C. Increased effectiveness of use of existing employment areas 0
D. Total gross employment requirement (demand) 39.6

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Excess providing even more contingency and flexibility 8.9



5.10 Through double counting, unreasonable buffers and unjustified changes of use, WDC has transformed an excess of employment land of 8.9ha into a misleading claimed deficit of 22.5ha. This cannot be justified. The misleading claimed deficit is then used to try to justify development of new employment land in the Green Belt (section 4.6):
* Thickthorn (8ha) between Kenilworth and the A46;
* Part of the Coventry Gateway site (6.5ha) around Baginton and Coventry Airport.

5.11 By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

5.12 The Revised Development Strategy goes on to allocate a "Sub-Regional Employment Site" (Policy RDS8). Section 5.5 is based on an extant planning application, presenting claims from the planning application as though they were sufficient justification for the District's development strategy.

5.13 The first issue with Section 5.5 is evident in its title: the meaning of 'sub-regional' is not defined. The Regional Spatial Strategy has been abolished but the justification in section 5.5 still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with the the abolition of the RSS and makes the proposed strategy unsound. The long- established economic partnership in the area is CSW - Coventry, Solihull and Warwickshire - but the Revised Development Strategy focuses on the Coventry & Warwickshire City Deal and the CWLEP. In practice, the 'sub-region' is an artificial construct with no proven need.

5.14 While Section 5.5 purports to be describing a generic employment site for predominantly B1, B2 and B8 uses, it depends on the justification for the specific uses proposed in the Coventry Gateway application even though this focuses on the Gateway's proposed B1(b) (research and development) sub-class, for example. Policy RDS8 as described when the consultation document was written (before the planning committee considered the Coventry Gateway application in June 2013) is little more than pre-determination of the Coventry Gateway application.

5.15 Even if a 'sub-regional' need were justified, no justification is provided for siting it entirely in Warwick District and in the Green Belt. Considering that any 'sub-region' contains at least Coventry, North Warwickshire, Nuneaton & Bedworth, Rugby, Stratford upon Avon and Warwick, what is the justification for locating the 'sub-regional employment site' within Warwick District? Policy RDS8 would either take jobs from areas with greater need (unemployment is considerably higher in Coventry and Rugby, for example) or add further to the excess of employment land in Warwick District. The proposed site location undermines the well-established principle of urban regeneration, fails to recognise the brownfield-first policy (e.g. NPPF section 111) and would be inappropriate development in the Green Belt. Locating a major employment site in a rural area would increase the need to travel, particularly by car. The proposed criteria claimed to justify such a development in the Green Belt depend on policies of the abolished RSS (e.g. Coventry & Nuneaton Regeneration Zone) and vague concepts such as 'sub-regional need'.

5.16 The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". Policy RDS8 fails to meet this requirement. The proposed policy is not justified, it would damage the environment and it should be removed.

1.1 We strongly oppose the scale of housing growth that the Development Strategy proposes. The The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

1.2 The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and unless much of this is by windfall development within the urban areas.

1.3 The proposals to impose 100-150 houses on each of five villages, and 70-90 on five others, would in most cases damage their rural character and unbalance their structure.


2. Principles of the Development Strategy

2.1 A main aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years. There is no demand from the residents of the area for this aim and it has not been subject to public participation as to whether it should be the principle underlying the Plan.

2.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

2.3 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

2.4 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.

2.5 The justification for the scale of housing proposed is not made. The ONS and SHMA figures include a large element of in-migration of population into the area. It is this assumption of in-migration that leads to the high household numbers forecast and the claim that 12,300 houses are required between 2011 and 2028. The Development Strategy fails to show the actual household increase that would result from accurate application of the 2011 Census and trends in migration in most recent years.

2.6 Other representations set out the reasons for a lower housing requirement, 5,300 over the period 2011-2028 or 250 new dwellings per year. This is an achievable and acceptable level of housing provision and should be adopted by the Council. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The annual housebuilding rate proposed in the Development Strategy has not been achieved in the past and is unrealistic.

2.7 The justification for the high housing numbers is expressed by the Council as being to 'achieve economic growth rates in line with national forecasts' (para 4.1.6). Para 4.1.10 claims that economic growth in the District is linked to providing additional houses. The aim therefore appears to be to encourage in-migration by providing more housing so that more employment is provided in the area to create more 'GVA' (growth).

Not only has this aim of the Development Strategy not been subject to public consultation; it is is wholly contrary to the interests of Warwick District. It is the attractiveness of the District's towns, villages and countryside and the strict control on development that makes it economically successful. The employment growth (much in small businesses and people working from home) has not required new employment land and there has been relatively little rebuilding of existing office accommodation. There is in fact a surplus of employment land and some is not used (see paras 4.5.18-20) while the District already 'has a good range of land within its employment portfolio'. No case has been made for releasing any greenfield land for employment over what is already available.



3. Proposed Locations for Housing Development

3.1 The previous consultation (Preferred Options) proposed 'growth across the District' including on Green Belt, and in villages. The large-scale development of Green Belt north of Leamington has been withdrawn, but Green Belt development at Thickthorn, Kenilworth, at Cubbington, and adjacent to certain villages now 'washed over' by Green Belt is still proposed. The proposals for development in Green Belt at Hampton Magna, Lapworth (Kingswood), Burton Green, and Baginton are strongly opposed.

3.2 The scale of development between Warwick, Warwick Castle Park, Leamington, Whitnash and Bishops Tachbook is unacceptably large. A rural landscape which is not 'urban fringe' but valuable agricultural land would be urbanised. The eastern side of Warwick Castle Park, which past policy has kept rural, would be partly built-up. Harbury Lane should remain the southern boundary of the built-up area of Warwick & Leamington, a function it has performed effectively since the Warwick Technology Park and the housing location known as 'Warwick Gates' were developed under past Plans.

3.3 This major location would not only develop valuable open countryside. It would be car-served development since it would be too far from the town centres for walking, cycling facilities are limited, the railway stations are not near it and bus services in the District have low useage and are not generally attractive. The traffic impact of the development proposed would be so great that Warwick's historic town centre would be heavily congested and polluted by the additional traffic. Routes in and out of central Leamington area already congested at peak hours and condiktions would worsen.

3.4 The proposals for 100-150 houses at each of the non-Green Belt villages - Radford Semele, Bishops Tachbook and Barford - would overwhelm these villages. Smaller numbers may be acceptable over a long period but not development on that scale.

3.5 These housing proposals are not sustainable development, in contrast to the three brownfield site proposals within Leamington Spa which meet sustainability prlnciples.


4. Gypsies and Travellers

4.1 CPRE has commented separately on the Gypsy and Traveller Sites consultation document. We would emphasise the opportunity to co-operate with Coventry City Council to expand provision at Siskin Drive, where the boundary runs through the existing employment areas.


5. Proposals for Employment Land

5.1 In August 2012 we responded to WDC's Preferred Options raising issues including the amount and location of employment land proposed in the emerging plan. Our conclusion on employment land in 2012 was that "no new development of employment land in the Green Belt is justified". The Revised Development Strategy increases our concerns that WDC's emerging plan is unsound.

5.2 Section 3.5 of the Revised Development Strategy (May 2013) summarises sustainable development principles including "avoiding coalescence". But WDC's proposals fail to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The proposals are not sustainable.

5.3 There is in fact an excess of employment land already available in Warwick District. The issue of the amount of employment land is mainly caused by WDC's approach to the assessment of Employment Land Requirements. This approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in the proposed policy RDS6 which specifies that 22.5 hectares of new employment land should be allocated between 2011 and 2029, mostly in the Green Belt.

5.4 Table 4 shows the detail behind the claimed deficit; this is reproduced below.

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 16.5
C. Potential redevelopment of existing employment areas 13.5
D. Total gross employment requirement (demand) 66

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Balance to be allocated 17.5
(15 to 25)


5.5 Section 4.5.8 then takes the bottom line (Row H 'Balance to be allocated') figure of 17.5ha and increases this figure to 22.5ha in order "to allow for flexibility and the assumptions used in modelling and forecasting". The latter 'buffer' of 5ha overlaps with the Item B 'Margin to provide flexibility of supply' of 16.5ha. This is double counting. Error in modelling/ forecasting can go either way (plus or minus), not just one direction. The claim that "it is reasonable to provide an additional 22.5 hectares of employment land" is entirely unreasonable.

5.6 The established requirement (Item A) is 36ha; against this, 16.5ha 'Margin to provide flexibility of supply' is itself excessive: almost 50% extra on top of the established demand of 36ha in order to provide 'choice'; this seems to be an unjustified excessive amount of flexibility. The environment cannot afford such generous luxury of flexibility. A 10% contingency should be sufficient 3.6ha rather than 16.5ha.

5.7 The final component in the demand side of the table above is Item C 'Potential redevelopment of existing employment areas', amounting to 13.5ha. Although this seems at first sight to be supply rather than demand, more employment land is claimed to be needed because of the unjustified change of use of existing employment land, removing it all from the employment portfolio and allocating it to housing. Sections 4.5.19-4.5.20 (and 4.2.4) describe the proposal to remove 19.5ha of existing employment land and replace it with 13.5ha of new employment land.

5.8 The proposal to take all of this land out of the employment portfolio conflicts with other sections of the consultation document. Section 4.3.9 makes quite clear that some of the 'tired' employment land could be released for housing development. No justification is provided for taking all of the land out of employment use; there seems to be no reason why such employment land should not be redeveloped for continuing employment purposes (if demand is really there). It is extreme to assume that all of this land will be 'lost' to employment uses. It is not acceptable to take brownfield land in urban areas out of the employment portfolio and replace it with greenfield land outside urban areas, much in the Green Belt. The strategy should be to improve effective use of the 19.5ha for continuing employment use.

5.9 Established numbers in the above table show the base demand as 36ha (Item A) and the base supply as 48ha (Item F). The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample flexibility and margin for error. A corrected version of Table 4 is provided below:

Table 4 Revised

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 3.6
C. Increased effectiveness of use of existing employment areas 0
D. Total gross employment requirement (demand) 39.6

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Excess providing even more contingency and flexibility 8.9



5.10 Through double counting, unreasonable buffers and unjustified changes of use, WDC has transformed an excess of employment land of 8.9ha into a misleading claimed deficit of 22.5ha. This cannot be justified. The misleading claimed deficit is then used to try to justify development of new employment land in the Green Belt (section 4.6):
* Thickthorn (8ha) between Kenilworth and the A46;
* Part of the Coventry Gateway site (6.5ha) around Baginton and Coventry Airport.

5.11 By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

5.12 The Revised Development Strategy goes on to allocate a "Sub-Regional Employment Site" (Policy RDS8). Section 5.5 is based on an extant planning application, presenting claims from the planning application as though they were sufficient justification for the District's development strategy.

5.13 The first issue with Section 5.5 is evident in its title: the meaning of 'sub-regional' is not defined. The Regional Spatial Strategy has been abolished but the justification in section 5.5 still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with the the abolition of the RSS and makes the proposed strategy unsound. The long- established economic partnership in the area is CSW - Coventry, Solihull and Warwickshire - but the Revised Development Strategy focuses on the Coventry & Warwickshire City Deal and the CWLEP. In practice, the 'sub-region' is an artificial construct with no proven need.

5.14 While Section 5.5 purports to be describing a generic employment site for predominantly B1, B2 and B8 uses, it depends on the justification for the specific uses proposed in the Coventry Gateway application even though this focuses on the Gateway's proposed B1(b) (research and development) sub-class, for example. Policy RDS8 as described when the consultation document was written (before the planning committee considered the Coventry Gateway application in June 2013) is little more than pre-determination of the Coventry Gateway application.

5.15 Even if a 'sub-regional' need were justified, no justification is provided for siting it entirely in Warwick District and in the Green Belt. Considering that any 'sub-region' contains at least Coventry, North Warwickshire, Nuneaton & Bedworth, Rugby, Stratford upon Avon and Warwick, what is the justification for locating the 'sub-regional employment site' within Warwick District? Policy RDS8 would either take jobs from areas with greater need (unemployment is considerably higher in Coventry and Rugby, for example) or add further to the excess of employment land in Warwick District. The proposed site location undermines the well-established principle of urban regeneration, fails to recognise the brownfield-first policy (e.g. NPPF section 111) and would be inappropriate development in the Green Belt. Locating a major employment site in a rural area would increase the need to travel, particularly by car. The proposed criteria claimed to justify such a development in the Green Belt depend on policies of the abolished RSS (e.g. Coventry & Nuneaton Regeneration Zone) and vague concepts such as 'sub-regional need'.

5.16 The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". Policy RDS8 fails to meet this requirement. The proposed policy is not justified, it would damage the environment and it should be removed.

1.1 We strongly oppose the scale of housing growth that the Development Strategy proposes. The The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

1.2 The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and unless much of this is by windfall development within the urban areas.

1.3 The proposals to impose 100-150 houses on each of five villages, and 70-90 on five others, would in most cases damage their rural character and unbalance their structure.


2. Principles of the Development Strategy

2.1 A main aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years. There is no demand from the residents of the area for this aim and it has not been subject to public participation as to whether it should be the principle underlying the Plan.

2.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

2.3 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

2.4 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.

2.5 The justification for the scale of housing proposed is not made. The ONS and SHMA figures include a large element of in-migration of population into the area. It is this assumption of in-migration that leads to the high household numbers forecast and the claim that 12,300 houses are required between 2011 and 2028. The Development Strategy fails to show the actual household increase that would result from accurate application of the 2011 Census and trends in migration in most recent years.

2.6 Other representations set out the reasons for a lower housing requirement, 5,300 over the period 2011-2028 or 250 new dwellings per year. This is an achievable and acceptable level of housing provision and should be adopted by the Council. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The annual housebuilding rate proposed in the Development Strategy has not been achieved in the past and is unrealistic.

2.7 The justification for the high housing numbers is expressed by the Council as being to 'achieve economic growth rates in line with national forecasts' (para 4.1.6). Para 4.1.10 claims that economic growth in the District is linked to providing additional houses. The aim therefore appears to be to encourage in-migration by providing more housing so that more employment is provided in the area to create more 'GVA' (growth).

Not only has this aim of the Development Strategy not been subject to public consultation; it is is wholly contrary to the interests of Warwick District. It is the attractiveness of the District's towns, villages and countryside and the strict control on development that makes it economically successful. The employment growth (much in small businesses and people working from home) has not required new employment land and there has been relatively little rebuilding of existing office accommodation. There is in fact a surplus of employment land and some is not used (see paras 4.5.18-20) while the District already 'has a good range of land within its employment portfolio'. No case has been made for releasing any greenfield land for employment over what is already available.



3. Proposed Locations for Housing Development

3.1 The previous consultation (Preferred Options) proposed 'growth across the District' including on Green Belt, and in villages. The large-scale development of Green Belt north of Leamington has been withdrawn, but Green Belt development at Thickthorn, Kenilworth, at Cubbington, and adjacent to certain villages now 'washed over' by Green Belt is still proposed. The proposals for development in Green Belt at Hampton Magna, Lapworth (Kingswood), Burton Green, and Baginton are strongly opposed.

3.2 The scale of development between Warwick, Warwick Castle Park, Leamington, Whitnash and Bishops Tachbook is unacceptably large. A rural landscape which is not 'urban fringe' but valuable agricultural land would be urbanised. The eastern side of Warwick Castle Park, which past policy has kept rural, would be partly built-up. Harbury Lane should remain the southern boundary of the built-up area of Warwick & Leamington, a function it has performed effectively since the Warwick Technology Park and the housing location known as 'Warwick Gates' were developed under past Plans.

3.3 This major location would not only develop valuable open countryside. It would be car-served development since it would be too far from the town centres for walking, cycling facilities are limited, the railway stations are not near it and bus services in the District have low useage and are not generally attractive. The traffic impact of the development proposed would be so great that Warwick's historic town centre would be heavily congested and polluted by the additional traffic. Routes in and out of central Leamington area already congested at peak hours and condiktions would worsen.

3.4 The proposals for 100-150 houses at each of the non-Green Belt villages - Radford Semele, Bishops Tachbook and Barford - would overwhelm these villages. Smaller numbers may be acceptable over a long period but not development on that scale.

3.5 These housing proposals are not sustainable development, in contrast to the three brownfield site proposals within Leamington Spa which meet sustainability prlnciples.


4. Gypsies and Travellers

4.1 CPRE has commented separately on the Gypsy and Traveller Sites consultation document. We would emphasise the opportunity to co-operate with Coventry City Council to expand provision at Siskin Drive, where the boundary runs through the existing employment areas.


5. Proposals for Employment Land

5.1 In August 2012 we responded to WDC's Preferred Options raising issues including the amount and location of employment land proposed in the emerging plan. Our conclusion on employment land in 2012 was that "no new development of employment land in the Green Belt is justified". The Revised Development Strategy increases our concerns that WDC's emerging plan is unsound.

5.2 Section 3.5 of the Revised Development Strategy (May 2013) summarises sustainable development principles including "avoiding coalescence". But WDC's proposals fail to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The proposals are not sustainable.

5.3 There is in fact an excess of employment land already available in Warwick District. The issue of the amount of employment land is mainly caused by WDC's approach to the assessment of Employment Land Requirements. This approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in the proposed policy RDS6 which specifies that 22.5 hectares of new employment land should be allocated between 2011 and 2029, mostly in the Green Belt.

5.4 Table 4 shows the detail behind the claimed deficit; this is reproduced below.

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 16.5
C. Potential redevelopment of existing employment areas 13.5
D. Total gross employment requirement (demand) 66

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Balance to be allocated 17.5
(15 to 25)


5.5 Section 4.5.8 then takes the bottom line (Row H 'Balance to be allocated') figure of 17.5ha and increases this figure to 22.5ha in order "to allow for flexibility and the assumptions used in modelling and forecasting". The latter 'buffer' of 5ha overlaps with the Item B 'Margin to provide flexibility of supply' of 16.5ha. This is double counting. Error in modelling/ forecasting can go either way (plus or minus), not just one direction. The claim that "it is reasonable to provide an additional 22.5 hectares of employment land" is entirely unreasonable.

5.6 The established requirement (Item A) is 36ha; against this, 16.5ha 'Margin to provide flexibility of supply' is itself excessive: almost 50% extra on top of the established demand of 36ha in order to provide 'choice'; this seems to be an unjustified excessive amount of flexibility. The environment cannot afford such generous luxury of flexibility. A 10% contingency should be sufficient 3.6ha rather than 16.5ha.

5.7 The final component in the demand side of the table above is Item C 'Potential redevelopment of existing employment areas', amounting to 13.5ha. Although this seems at first sight to be supply rather than demand, more employment land is claimed to be needed because of the unjustified change of use of existing employment land, removing it all from the employment portfolio and allocating it to housing. Sections 4.5.19-4.5.20 (and 4.2.4) describe the proposal to remove 19.5ha of existing employment land and replace it with 13.5ha of new employment land.

5.8 The proposal to take all of this land out of the employment portfolio conflicts with other sections of the consultation document. Section 4.3.9 makes quite clear that some of the 'tired' employment land could be released for housing development. No justification is provided for taking all of the land out of employment use; there seems to be no reason why such employment land should not be redeveloped for continuing employment purposes (if demand is really there). It is extreme to assume that all of this land will be 'lost' to employment uses. It is not acceptable to take brownfield land in urban areas out of the employment portfolio and replace it with greenfield land outside urban areas, much in the Green Belt. The strategy should be to improve effective use of the 19.5ha for continuing employment use.

5.9 Established numbers in the above table show the base demand as 36ha (Item A) and the base supply as 48ha (Item F). The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample flexibility and margin for error. A corrected version of Table 4 is provided below:

Table 4 Revised

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 3.6
C. Increased effectiveness of use of existing employment areas 0
D. Total gross employment requirement (demand) 39.6

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Excess providing even more contingency and flexibility 8.9



5.10 Through double counting, unreasonable buffers and unjustified changes of use, WDC has transformed an excess of employment land of 8.9ha into a misleading claimed deficit of 22.5ha. This cannot be justified. The misleading claimed deficit is then used to try to justify development of new employment land in the Green Belt (section 4.6):
* Thickthorn (8ha) between Kenilworth and the A46;
* Part of the Coventry Gateway site (6.5ha) around Baginton and Coventry Airport.

5.11 By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

5.12 The Revised Development Strategy goes on to allocate a "Sub-Regional Employment Site" (Policy RDS8). Section 5.5 is based on an extant planning application, presenting claims from the planning application as though they were sufficient justification for the District's development strategy.

5.13 The first issue with Section 5.5 is evident in its title: the meaning of 'sub-regional' is not defined. The Regional Spatial Strategy has been abolished but the justification in section 5.5 still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with the the abolition of the RSS and makes the proposed strategy unsound. The long- established economic partnership in the area is CSW - Coventry, Solihull and Warwickshire - but the Revised Development Strategy focuses on the Coventry & Warwickshire City Deal and the CWLEP. In practice, the 'sub-region' is an artificial construct with no proven need.

5.14 While Section 5.5 purports to be describing a generic employment site for predominantly B1, B2 and B8 uses, it depends on the justification for the specific uses proposed in the Coventry Gateway application even though this focuses on the Gateway's proposed B1(b) (research and development) sub-class, for example. Policy RDS8 as described when the consultation document was written (before the planning committee considered the Coventry Gateway application in June 2013) is little more than pre-determination of the Coventry Gateway application.

5.15 Even if a 'sub-regional' need were justified, no justification is provided for siting it entirely in Warwick District and in the Green Belt. Considering that any 'sub-region' contains at least Coventry, North Warwickshire, Nuneaton & Bedworth, Rugby, Stratford upon Avon and Warwick, what is the justification for locating the 'sub-regional employment site' within Warwick District? Policy RDS8 would either take jobs from areas with greater need (unemployment is considerably higher in Coventry and Rugby, for example) or add further to the excess of employment land in Warwick District. The proposed site location undermines the well-established principle of urban regeneration, fails to recognise the brownfield-first policy (e.g. NPPF section 111) and would be inappropriate development in the Green Belt. Locating a major employment site in a rural area would increase the need to travel, particularly by car. The proposed criteria claimed to justify such a development in the Green Belt depend on policies of the abolished RSS (e.g. Coventry & Nuneaton Regeneration Zone) and vague concepts such as 'sub-regional need'.

5.16 The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". Policy RDS8 fails to meet this requirement. The proposed policy is not justified, it would damage the environment and it should be removed.

1.1 We strongly oppose the scale of housing growth that the Development Strategy proposes. The The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

1.2 The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and unless much of this is by windfall development within the urban areas.

1.3 The proposals to impose 100-150 houses on each of five villages, and 70-90 on five others, would in most cases damage their rural character and unbalance their structure.


2. Principles of the Development Strategy

2.1 A main aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years. There is no demand from the residents of the area for this aim and it has not been subject to public participation as to whether it should be the principle underlying the Plan.

2.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

2.3 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

2.4 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.

2.5 The justification for the scale of housing proposed is not made. The ONS and SHMA figures include a large element of in-migration of population into the area. It is this assumption of in-migration that leads to the high household numbers forecast and the claim that 12,300 houses are required between 2011 and 2028. The Development Strategy fails to show the actual household increase that would result from accurate application of the 2011 Census and trends in migration in most recent years.

2.6 Other representations set out the reasons for a lower housing requirement, 5,300 over the period 2011-2028 or 250 new dwellings per year. This is an achievable and acceptable level of housing provision and should be adopted by the Council. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The annual housebuilding rate proposed in the Development Strategy has not been achieved in the past and is unrealistic.

2.7 The justification for the high housing numbers is expressed by the Council as being to 'achieve economic growth rates in line with national forecasts' (para 4.1.6). Para 4.1.10 claims that economic growth in the District is linked to providing additional houses. The aim therefore appears to be to encourage in-migration by providing more housing so that more employment is provided in the area to create more 'GVA' (growth).

Not only has this aim of the Development Strategy not been subject to public consultation; it is is wholly contrary to the interests of Warwick District. It is the attractiveness of the District's towns, villages and countryside and the strict control on development that makes it economically successful. The employment growth (much in small businesses and people working from home) has not required new employment land and there has been relatively little rebuilding of existing office accommodation. There is in fact a surplus of employment land and some is not used (see paras 4.5.18-20) while the District already 'has a good range of land within its employment portfolio'. No case has been made for releasing any greenfield land for employment over what is already available.



3. Proposed Locations for Housing Development

3.1 The previous consultation (Preferred Options) proposed 'growth across the District' including on Green Belt, and in villages. The large-scale development of Green Belt north of Leamington has been withdrawn, but Green Belt development at Thickthorn, Kenilworth, at Cubbington, and adjacent to certain villages now 'washed over' by Green Belt is still proposed. The proposals for development in Green Belt at Hampton Magna, Lapworth (Kingswood), Burton Green, and Baginton are strongly opposed.

3.2 The scale of development between Warwick, Warwick Castle Park, Leamington, Whitnash and Bishops Tachbook is unacceptably large. A rural landscape which is not 'urban fringe' but valuable agricultural land would be urbanised. The eastern side of Warwick Castle Park, which past policy has kept rural, would be partly built-up. Harbury Lane should remain the southern boundary of the built-up area of Warwick & Leamington, a function it has performed effectively since the Warwick Technology Park and the housing location known as 'Warwick Gates' were developed under past Plans.

3.3 This major location would not only develop valuable open countryside. It would be car-served development since it would be too far from the town centres for walking, cycling facilities are limited, the railway stations are not near it and bus services in the District have low useage and are not generally attractive. The traffic impact of the development proposed would be so great that Warwick's historic town centre would be heavily congested and polluted by the additional traffic. Routes in and out of central Leamington area already congested at peak hours and condiktions would worsen.

3.4 The proposals for 100-150 houses at each of the non-Green Belt villages - Radford Semele, Bishops Tachbook and Barford - would overwhelm these villages. Smaller numbers may be acceptable over a long period but not development on that scale.

3.5 These housing proposals are not sustainable development, in contrast to the three brownfield site proposals within Leamington Spa which meet sustainability prlnciples.


4. Gypsies and Travellers

4.1 CPRE has commented separately on the Gypsy and Traveller Sites consultation document. We would emphasise the opportunity to co-operate with Coventry City Council to expand provision at Siskin Drive, where the boundary runs through the existing employment areas.


5. Proposals for Employment Land

5.1 In August 2012 we responded to WDC's Preferred Options raising issues including the amount and location of employment land proposed in the emerging plan. Our conclusion on employment land in 2012 was that "no new development of employment land in the Green Belt is justified". The Revised Development Strategy increases our concerns that WDC's emerging plan is unsound.

5.2 Section 3.5 of the Revised Development Strategy (May 2013) summarises sustainable development principles including "avoiding coalescence". But WDC's proposals fail to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The proposals are not sustainable.

5.3 There is in fact an excess of employment land already available in Warwick District. The issue of the amount of employment land is mainly caused by WDC's approach to the assessment of Employment Land Requirements. This approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in the proposed policy RDS6 which specifies that 22.5 hectares of new employment land should be allocated between 2011 and 2029, mostly in the Green Belt.

5.4 Table 4 shows the detail behind the claimed deficit; this is reproduced below.

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 16.5
C. Potential redevelopment of existing employment areas 13.5
D. Total gross employment requirement (demand) 66

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Balance to be allocated 17.5
(15 to 25)


5.5 Section 4.5.8 then takes the bottom line (Row H 'Balance to be allocated') figure of 17.5ha and increases this figure to 22.5ha in order "to allow for flexibility and the assumptions used in modelling and forecasting". The latter 'buffer' of 5ha overlaps with the Item B 'Margin to provide flexibility of supply' of 16.5ha. This is double counting. Error in modelling/ forecasting can go either way (plus or minus), not just one direction. The claim that "it is reasonable to provide an additional 22.5 hectares of employment land" is entirely unreasonable.

5.6 The established requirement (Item A) is 36ha; against this, 16.5ha 'Margin to provide flexibility of supply' is itself excessive: almost 50% extra on top of the established demand of 36ha in order to provide 'choice'; this seems to be an unjustified excessive amount of flexibility. The environment cannot afford such generous luxury of flexibility. A 10% contingency should be sufficient 3.6ha rather than 16.5ha.

5.7 The final component in the demand side of the table above is Item C 'Potential redevelopment of existing employment areas', amounting to 13.5ha. Although this seems at first sight to be supply rather than demand, more employment land is claimed to be needed because of the unjustified change of use of existing employment land, removing it all from the employment portfolio and allocating it to housing. Sections 4.5.19-4.5.20 (and 4.2.4) describe the proposal to remove 19.5ha of existing employment land and replace it with 13.5ha of new employment land.

5.8 The proposal to take all of this land out of the employment portfolio conflicts with other sections of the consultation document. Section 4.3.9 makes quite clear that some of the 'tired' employment land could be released for housing development. No justification is provided for taking all of the land out of employment use; there seems to be no reason why such employment land should not be redeveloped for continuing employment purposes (if demand is really there). It is extreme to assume that all of this land will be 'lost' to employment uses. It is not acceptable to take brownfield land in urban areas out of the employment portfolio and replace it with greenfield land outside urban areas, much in the Green Belt. The strategy should be to improve effective use of the 19.5ha for continuing employment use.

5.9 Established numbers in the above table show the base demand as 36ha (Item A) and the base supply as 48ha (Item F). The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample flexibility and margin for error. A corrected version of Table 4 is provided below:

Table 4 Revised

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 3.6
C. Increased effectiveness of use of existing employment areas 0
D. Total gross employment requirement (demand) 39.6

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Excess providing even more contingency and flexibility 8.9



5.10 Through double counting, unreasonable buffers and unjustified changes of use, WDC has transformed an excess of employment land of 8.9ha into a misleading claimed deficit of 22.5ha. This cannot be justified. The misleading claimed deficit is then used to try to justify development of new employment land in the Green Belt (section 4.6):
* Thickthorn (8ha) between Kenilworth and the A46;
* Part of the Coventry Gateway site (6.5ha) around Baginton and Coventry Airport.

5.11 By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

5.12 The Revised Development Strategy goes on to allocate a "Sub-Regional Employment Site" (Policy RDS8). Section 5.5 is based on an extant planning application, presenting claims from the planning application as though they were sufficient justification for the District's development strategy.

5.13 The first issue with Section 5.5 is evident in its title: the meaning of 'sub-regional' is not defined. The Regional Spatial Strategy has been abolished but the justification in section 5.5 still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with the the abolition of the RSS and makes the proposed strategy unsound. The long- established economic partnership in the area is CSW - Coventry, Solihull and Warwickshire - but the Revised Development Strategy focuses on the Coventry & Warwickshire City Deal and the CWLEP. In practice, the 'sub-region' is an artificial construct with no proven need.

5.14 While Section 5.5 purports to be describing a generic employment site for predominantly B1, B2 and B8 uses, it depends on the justification for the specific uses proposed in the Coventry Gateway application even though this focuses on the Gateway's proposed B1(b) (research and development) sub-class, for example. Policy RDS8 as described when the consultation document was written (before the planning committee considered the Coventry Gateway application in June 2013) is little more than pre-determination of the Coventry Gateway application.

5.15 Even if a 'sub-regional' need were justified, no justification is provided for siting it entirely in Warwick District and in the Green Belt. Considering that any 'sub-region' contains at least Coventry, North Warwickshire, Nuneaton & Bedworth, Rugby, Stratford upon Avon and Warwick, what is the justification for locating the 'sub-regional employment site' within Warwick District? Policy RDS8 would either take jobs from areas with greater need (unemployment is considerably higher in Coventry and Rugby, for example) or add further to the excess of employment land in Warwick District. The proposed site location undermines the well-established principle of urban regeneration, fails to recognise the brownfield-first policy (e.g. NPPF section 111) and would be inappropriate development in the Green Belt. Locating a major employment site in a rural area would increase the need to travel, particularly by car. The proposed criteria claimed to justify such a development in the Green Belt depend on policies of the abolished RSS (e.g. Coventry & Nuneaton Regeneration Zone) and vague concepts such as 'sub-regional need'.

5.16 The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". Policy RDS8 fails to meet this requirement. The proposed policy is not justified, it would damage the environment and it should be removed.

1.1 We strongly oppose the scale of housing growth that the Development Strategy proposes. The The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

1.2 The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and unless much of this is by windfall development within the urban areas.

1.3 The proposals to impose 100-150 houses on each of five villages, and 70-90 on five others, would in most cases damage their rural character and unbalance their structure.


2. Principles of the Development Strategy

2.1 A main aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years. There is no demand from the residents of the area for this aim and it has not been subject to public participation as to whether it should be the principle underlying the Plan.

2.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

2.3 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

2.4 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.

2.5 The justification for the scale of housing proposed is not made. The ONS and SHMA figures include a large element of in-migration of population into the area. It is this assumption of in-migration that leads to the high household numbers forecast and the claim that 12,300 houses are required between 2011 and 2028. The Development Strategy fails to show the actual household increase that would result from accurate application of the 2011 Census and trends in migration in most recent years.

2.6 Other representations set out the reasons for a lower housing requirement, 5,300 over the period 2011-2028 or 250 new dwellings per year. This is an achievable and acceptable level of housing provision and should be adopted by the Council. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The annual housebuilding rate proposed in the Development Strategy has not been achieved in the past and is unrealistic.

2.7 The justification for the high housing numbers is expressed by the Council as being to 'achieve economic growth rates in line with national forecasts' (para 4.1.6). Para 4.1.10 claims that economic growth in the District is linked to providing additional houses. The aim therefore appears to be to encourage in-migration by providing more housing so that more employment is provided in the area to create more 'GVA' (growth).

Not only has this aim of the Development Strategy not been subject to public consultation; it is is wholly contrary to the interests of Warwick District. It is the attractiveness of the District's towns, villages and countryside and the strict control on development that makes it economically successful. The employment growth (much in small businesses and people working from home) has not required new employment land and there has been relatively little rebuilding of existing office accommodation. There is in fact a surplus of employment land and some is not used (see paras 4.5.18-20) while the District already 'has a good range of land within its employment portfolio'. No case has been made for releasing any greenfield land for employment over what is already available.



3. Proposed Locations for Housing Development

3.1 The previous consultation (Preferred Options) proposed 'growth across the District' including on Green Belt, and in villages. The large-scale development of Green Belt north of Leamington has been withdrawn, but Green Belt development at Thickthorn, Kenilworth, at Cubbington, and adjacent to certain villages now 'washed over' by Green Belt is still proposed. The proposals for development in Green Belt at Hampton Magna, Lapworth (Kingswood), Burton Green, and Baginton are strongly opposed.

3.2 The scale of development between Warwick, Warwick Castle Park, Leamington, Whitnash and Bishops Tachbook is unacceptably large. A rural landscape which is not 'urban fringe' but valuable agricultural land would be urbanised. The eastern side of Warwick Castle Park, which past policy has kept rural, would be partly built-up. Harbury Lane should remain the southern boundary of the built-up area of Warwick & Leamington, a function it has performed effectively since the Warwick Technology Park and the housing location known as 'Warwick Gates' were developed under past Plans.

3.3 This major location would not only develop valuable open countryside. It would be car-served development since it would be too far from the town centres for walking, cycling facilities are limited, the railway stations are not near it and bus services in the District have low useage and are not generally attractive. The traffic impact of the development proposed would be so great that Warwick's historic town centre would be heavily congested and polluted by the additional traffic. Routes in and out of central Leamington area already congested at peak hours and condiktions would worsen.

3.4 The proposals for 100-150 houses at each of the non-Green Belt villages - Radford Semele, Bishops Tachbook and Barford - would overwhelm these villages. Smaller numbers may be acceptable over a long period but not development on that scale.

3.5 These housing proposals are not sustainable development, in contrast to the three brownfield site proposals within Leamington Spa which meet sustainability prlnciples.


4. Gypsies and Travellers

4.1 CPRE has commented separately on the Gypsy and Traveller Sites consultation document. We would emphasise the opportunity to co-operate with Coventry City Council to expand provision at Siskin Drive, where the boundary runs through the existing employment areas.


5. Proposals for Employment Land

5.1 In August 2012 we responded to WDC's Preferred Options raising issues including the amount and location of employment land proposed in the emerging plan. Our conclusion on employment land in 2012 was that "no new development of employment land in the Green Belt is justified". The Revised Development Strategy increases our concerns that WDC's emerging plan is unsound.

5.2 Section 3.5 of the Revised Development Strategy (May 2013) summarises sustainable development principles including "avoiding coalescence". But WDC's proposals fail to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The proposals are not sustainable.

5.3 There is in fact an excess of employment land already available in Warwick District. The issue of the amount of employment land is mainly caused by WDC's approach to the assessment of Employment Land Requirements. This approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in the proposed policy RDS6 which specifies that 22.5 hectares of new employment land should be allocated between 2011 and 2029, mostly in the Green Belt.

5.4 Table 4 shows the detail behind the claimed deficit; this is reproduced below.

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 16.5
C. Potential redevelopment of existing employment areas 13.5
D. Total gross employment requirement (demand) 66

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Balance to be allocated 17.5
(15 to 25)


5.5 Section 4.5.8 then takes the bottom line (Row H 'Balance to be allocated') figure of 17.5ha and increases this figure to 22.5ha in order "to allow for flexibility and the assumptions used in modelling and forecasting". The latter 'buffer' of 5ha overlaps with the Item B 'Margin to provide flexibility of supply' of 16.5ha. This is double counting. Error in modelling/ forecasting can go either way (plus or minus), not just one direction. The claim that "it is reasonable to provide an additional 22.5 hectares of employment land" is entirely unreasonable.

5.6 The established requirement (Item A) is 36ha; against this, 16.5ha 'Margin to provide flexibility of supply' is itself excessive: almost 50% extra on top of the established demand of 36ha in order to provide 'choice'; this seems to be an unjustified excessive amount of flexibility. The environment cannot afford such generous luxury of flexibility. A 10% contingency should be sufficient 3.6ha rather than 16.5ha.

5.7 The final component in the demand side of the table above is Item C 'Potential redevelopment of existing employment areas', amounting to 13.5ha. Although this seems at first sight to be supply rather than demand, more employment land is claimed to be needed because of the unjustified change of use of existing employment land, removing it all from the employment portfolio and allocating it to housing. Sections 4.5.19-4.5.20 (and 4.2.4) describe the proposal to remove 19.5ha of existing employment land and replace it with 13.5ha of new employment land.

5.8 The proposal to take all of this land out of the employment portfolio conflicts with other sections of the consultation document. Section 4.3.9 makes quite clear that some of the 'tired' employment land could be released for housing development. No justification is provided for taking all of the land out of employment use; there seems to be no reason why such employment land should not be redeveloped for continuing employment purposes (if demand is really there). It is extreme to assume that all of this land will be 'lost' to employment uses. It is not acceptable to take brownfield land in urban areas out of the employment portfolio and replace it with greenfield land outside urban areas, much in the Green Belt. The strategy should be to improve effective use of the 19.5ha for continuing employment use.

5.9 Established numbers in the above table show the base demand as 36ha (Item A) and the base supply as 48ha (Item F). The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample flexibility and margin for error. A corrected version of Table 4 is provided below:

Table 4 Revised

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 3.6
C. Increased effectiveness of use of existing employment areas 0
D. Total gross employment requirement (demand) 39.6

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Excess providing even more contingency and flexibility 8.9



5.10 Through double counting, unreasonable buffers and unjustified changes of use, WDC has transformed an excess of employment land of 8.9ha into a misleading claimed deficit of 22.5ha. This cannot be justified. The misleading claimed deficit is then used to try to justify development of new employment land in the Green Belt (section 4.6):
* Thickthorn (8ha) between Kenilworth and the A46;
* Part of the Coventry Gateway site (6.5ha) around Baginton and Coventry Airport.

5.11 By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

5.12 The Revised Development Strategy goes on to allocate a "Sub-Regional Employment Site" (Policy RDS8). Section 5.5 is based on an extant planning application, presenting claims from the planning application as though they were sufficient justification for the District's development strategy.

5.13 The first issue with Section 5.5 is evident in its title: the meaning of 'sub-regional' is not defined. The Regional Spatial Strategy has been abolished but the justification in section 5.5 still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with the the abolition of the RSS and makes the proposed strategy unsound. The long- established economic partnership in the area is CSW - Coventry, Solihull and Warwickshire - but the Revised Development Strategy focuses on the Coventry & Warwickshire City Deal and the CWLEP. In practice, the 'sub-region' is an artificial construct with no proven need.

5.14 While Section 5.5 purports to be describing a generic employment site for predominantly B1, B2 and B8 uses, it depends on the justification for the specific uses proposed in the Coventry Gateway application even though this focuses on the Gateway's proposed B1(b) (research and development) sub-class, for example. Policy RDS8 as described when the consultation document was written (before the planning committee considered the Coventry Gateway application in June 2013) is little more than pre-determination of the Coventry Gateway application.

5.15 Even if a 'sub-regional' need were justified, no justification is provided for siting it entirely in Warwick District and in the Green Belt. Considering that any 'sub-region' contains at least Coventry, North Warwickshire, Nuneaton & Bedworth, Rugby, Stratford upon Avon and Warwick, what is the justification for locating the 'sub-regional employment site' within Warwick District? Policy RDS8 would either take jobs from areas with greater need (unemployment is considerably higher in Coventry and Rugby, for example) or add further to the excess of employment land in Warwick District. The proposed site location undermines the well-established principle of urban regeneration, fails to recognise the brownfield-first policy (e.g. NPPF section 111) and would be inappropriate development in the Green Belt. Locating a major employment site in a rural area would increase the need to travel, particularly by car. The proposed criteria claimed to justify such a development in the Green Belt depend on policies of the abolished RSS (e.g. Coventry & Nuneaton Regeneration Zone) and vague concepts such as 'sub-regional need'.

5.16 The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". Policy RDS8 fails to meet this requirement. The proposed policy is not justified, it would damage the environment and it should be removed.

1.1 We strongly oppose the scale of housing growth that the Development Strategy proposes. The The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

1.2 The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and unless much of this is by windfall development within the urban areas.

1.3 The proposals to impose 100-150 houses on each of five villages, and 70-90 on five others, would in most cases damage their rural character and unbalance their structure.


2. Principles of the Development Strategy

2.1 A main aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years. There is no demand from the residents of the area for this aim and it has not been subject to public participation as to whether it should be the principle underlying the Plan.

2.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

2.3 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

2.4 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.

2.5 The justification for the scale of housing proposed is not made. The ONS and SHMA figures include a large element of in-migration of population into the area. It is this assumption of in-migration that leads to the high household numbers forecast and the claim that 12,300 houses are required between 2011 and 2028. The Development Strategy fails to show the actual household increase that would result from accurate application of the 2011 Census and trends in migration in most recent years.

2.6 Other representations set out the reasons for a lower housing requirement, 5,300 over the period 2011-2028 or 250 new dwellings per year. This is an achievable and acceptable level of housing provision and should be adopted by the Council. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The annual housebuilding rate proposed in the Development Strategy has not been achieved in the past and is unrealistic.

2.7 The justification for the high housing numbers is expressed by the Council as being to 'achieve economic growth rates in line with national forecasts' (para 4.1.6). Para 4.1.10 claims that economic growth in the District is linked to providing additional houses. The aim therefore appears to be to encourage in-migration by providing more housing so that more employment is provided in the area to create more 'GVA' (growth).

Not only has this aim of the Development Strategy not been subject to public consultation; it is is wholly contrary to the interests of Warwick District. It is the attractiveness of the District's towns, villages and countryside and the strict control on development that makes it economically successful. The employment growth (much in small businesses and people working from home) has not required new employment land and there has been relatively little rebuilding of existing office accommodation. There is in fact a surplus of employment land and some is not used (see paras 4.5.18-20) while the District already 'has a good range of land within its employment portfolio'. No case has been made for releasing any greenfield land for employment over what is already available.



3. Proposed Locations for Housing Development

3.1 The previous consultation (Preferred Options) proposed 'growth across the District' including on Green Belt, and in villages. The large-scale development of Green Belt north of Leamington has been withdrawn, but Green Belt development at Thickthorn, Kenilworth, at Cubbington, and adjacent to certain villages now 'washed over' by Green Belt is still proposed. The proposals for development in Green Belt at Hampton Magna, Lapworth (Kingswood), Burton Green, and Baginton are strongly opposed.

3.2 The scale of development between Warwick, Warwick Castle Park, Leamington, Whitnash and Bishops Tachbook is unacceptably large. A rural landscape which is not 'urban fringe' but valuable agricultural land would be urbanised. The eastern side of Warwick Castle Park, which past policy has kept rural, would be partly built-up. Harbury Lane should remain the southern boundary of the built-up area of Warwick & Leamington, a function it has performed effectively since the Warwick Technology Park and the housing location known as 'Warwick Gates' were developed under past Plans.

3.3 This major location would not only develop valuable open countryside. It would be car-served development since it would be too far from the town centres for walking, cycling facilities are limited, the railway stations are not near it and bus services in the District have low useage and are not generally attractive. The traffic impact of the development proposed would be so great that Warwick's historic town centre would be heavily congested and polluted by the additional traffic. Routes in and out of central Leamington area already congested at peak hours and condiktions would worsen.

3.4 The proposals for 100-150 houses at each of the non-Green Belt villages - Radford Semele, Bishops Tachbook and Barford - would overwhelm these villages. Smaller numbers may be acceptable over a long period but not development on that scale.

3.5 These housing proposals are not sustainable development, in contrast to the three brownfield site proposals within Leamington Spa which meet sustainability prlnciples.


4. Gypsies and Travellers

4.1 CPRE has commented separately on the Gypsy and Traveller Sites consultation document. We would emphasise the opportunity to co-operate with Coventry City Council to expand provision at Siskin Drive, where the boundary runs through the existing employment areas.


5. Proposals for Employment Land

5.1 In August 2012 we responded to WDC's Preferred Options raising issues including the amount and location of employment land proposed in the emerging plan. Our conclusion on employment land in 2012 was that "no new development of employment land in the Green Belt is justified". The Revised Development Strategy increases our concerns that WDC's emerging plan is unsound.

5.2 Section 3.5 of the Revised Development Strategy (May 2013) summarises sustainable development principles including "avoiding coalescence". But WDC's proposals fail to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The proposals are not sustainable.

5.3 There is in fact an excess of employment land already available in Warwick District. The issue of the amount of employment land is mainly caused by WDC's approach to the assessment of Employment Land Requirements. This approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in the proposed policy RDS6 which specifies that 22.5 hectares of new employment land should be allocated between 2011 and 2029, mostly in the Green Belt.

5.4 Table 4 shows the detail behind the claimed deficit; this is reproduced below.

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 16.5
C. Potential redevelopment of existing employment areas 13.5
D. Total gross employment requirement (demand) 66

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Balance to be allocated 17.5
(15 to 25)


5.5 Section 4.5.8 then takes the bottom line (Row H 'Balance to be allocated') figure of 17.5ha and increases this figure to 22.5ha in order "to allow for flexibility and the assumptions used in modelling and forecasting". The latter 'buffer' of 5ha overlaps with the Item B 'Margin to provide flexibility of supply' of 16.5ha. This is double counting. Error in modelling/ forecasting can go either way (plus or minus), not just one direction. The claim that "it is reasonable to provide an additional 22.5 hectares of employment land" is entirely unreasonable.

5.6 The established requirement (Item A) is 36ha; against this, 16.5ha 'Margin to provide flexibility of supply' is itself excessive: almost 50% extra on top of the established demand of 36ha in order to provide 'choice'; this seems to be an unjustified excessive amount of flexibility. The environment cannot afford such generous luxury of flexibility. A 10% contingency should be sufficient 3.6ha rather than 16.5ha.

5.7 The final component in the demand side of the table above is Item C 'Potential redevelopment of existing employment areas', amounting to 13.5ha. Although this seems at first sight to be supply rather than demand, more employment land is claimed to be needed because of the unjustified change of use of existing employment land, removing it all from the employment portfolio and allocating it to housing. Sections 4.5.19-4.5.20 (and 4.2.4) describe the proposal to remove 19.5ha of existing employment land and replace it with 13.5ha of new employment land.

5.8 The proposal to take all of this land out of the employment portfolio conflicts with other sections of the consultation document. Section 4.3.9 makes quite clear that some of the 'tired' employment land could be released for housing development. No justification is provided for taking all of the land out of employment use; there seems to be no reason why such employment land should not be redeveloped for continuing employment purposes (if demand is really there). It is extreme to assume that all of this land will be 'lost' to employment uses. It is not acceptable to take brownfield land in urban areas out of the employment portfolio and replace it with greenfield land outside urban areas, much in the Green Belt. The strategy should be to improve effective use of the 19.5ha for continuing employment use.

5.9 Established numbers in the above table show the base demand as 36ha (Item A) and the base supply as 48ha (Item F). The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample flexibility and margin for error. A corrected version of Table 4 is provided below:

Table 4 Revised

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 3.6
C. Increased effectiveness of use of existing employment areas 0
D. Total gross employment requirement (demand) 39.6

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Excess providing even more contingency and flexibility 8.9



5.10 Through double counting, unreasonable buffers and unjustified changes of use, WDC has transformed an excess of employment land of 8.9ha into a misleading claimed deficit of 22.5ha. This cannot be justified. The misleading claimed deficit is then used to try to justify development of new employment land in the Green Belt (section 4.6):
* Thickthorn (8ha) between Kenilworth and the A46;
* Part of the Coventry Gateway site (6.5ha) around Baginton and Coventry Airport.

5.11 By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

5.12 The Revised Development Strategy goes on to allocate a "Sub-Regional Employment Site" (Policy RDS8). Section 5.5 is based on an extant planning application, presenting claims from the planning application as though they were sufficient justification for the District's development strategy.

5.13 The first issue with Section 5.5 is evident in its title: the meaning of 'sub-regional' is not defined. The Regional Spatial Strategy has been abolished but the justification in section 5.5 still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with the the abolition of the RSS and makes the proposed strategy unsound. The long- established economic partnership in the area is CSW - Coventry, Solihull and Warwickshire - but the Revised Development Strategy focuses on the Coventry & Warwickshire City Deal and the CWLEP. In practice, the 'sub-region' is an artificial construct with no proven need.

5.14 While Section 5.5 purports to be describing a generic employment site for predominantly B1, B2 and B8 uses, it depends on the justification for the specific uses proposed in the Coventry Gateway application even though this focuses on the Gateway's proposed B1(b) (research and development) sub-class, for example. Policy RDS8 as described when the consultation document was written (before the planning committee considered the Coventry Gateway application in June 2013) is little more than pre-determination of the Coventry Gateway application.

5.15 Even if a 'sub-regional' need were justified, no justification is provided for siting it entirely in Warwick District and in the Green Belt. Considering that any 'sub-region' contains at least Coventry, North Warwickshire, Nuneaton & Bedworth, Rugby, Stratford upon Avon and Warwick, what is the justification for locating the 'sub-regional employment site' within Warwick District? Policy RDS8 would either take jobs from areas with greater need (unemployment is considerably higher in Coventry and Rugby, for example) or add further to the excess of employment land in Warwick District. The proposed site location undermines the well-established principle of urban regeneration, fails to recognise the brownfield-first policy (e.g. NPPF section 111) and would be inappropriate development in the Green Belt. Locating a major employment site in a rural area would increase the need to travel, particularly by car. The proposed criteria claimed to justify such a development in the Green Belt depend on policies of the abolished RSS (e.g. Coventry & Nuneaton Regeneration Zone) and vague concepts such as 'sub-regional need'.

5.16 The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". Policy RDS8 fails to meet this requirement. The proposed policy is not justified, it would damage the environment and it should be removed.