Revised Development Strategy

1 & 2 Introduction / Consultation Process
Right now the District is in an uncomfortable position, with limited powers to exercise priorities, before a new Local Plan is in place. Progress towards that Plan is crucial but the Plan will be of little benefit unless it sets clear and specific criteria for shaping the District's development. This statement of the obvious is made because we seek firmer guidelines for development within the Plan period.
The Leamington Society has previously made strong representations about PO10: Built Environment and we note that in the current Strategic Vision text there is more than one reference to "Garden towns, suburbs and villages". We therefore include this theme in our response (and did indeed 'phone to consult one of your officers on this point).
3 Strategic Vision

3.5 SOCIAL
Of the four bullet points, we particularly endorse point 2 :-
"Providing for diversity, including affordable homes, homes for the elderly and vulnerable and other specialised needs"
But the context of "diversity" should include specific reference to a wide range of dwellings to meet varied lifetime circumstances - beyond the limited special categories identified here.
We pick up this theme below, detailing our concern about the character of the suburban housing developments currently anticipated.
4 Housing
Formulating a core strategy in relation to housing provision is proving controversial. The headline feature of the revised strategy is to plan for very large suburban extensions to the south of Leamington and Warwick. It is evident that this has the potential seriously to aggravate existing traffic problems and will require considerable road works. Such works will be expensive and highly intrusive: they may mitigate the immediate local problem but will not prevent an increase in congestion and pollution around and within the adjoining towns.
There are three elements to this large increase in housing allocation: the total numbers, the proposed locations, and the character and density of the new developments.
THE NUMBERS
We note that half of the potential growth derives from predictions of inward migration to the District. These projections are fraught with uncertainty, as the ONS (Office of National Statistics) warns :-
"The projections are not forecasts and do not take any account of future government policies, changing economic circumstances or the capacity of an area to accommodate the change in population. They provide an indication of the future size and age structures of the population if recent demographic trends are continued. Population projections become increasingly uncertain the further they are carried forward, and particularly so for smaller geographic areas."
We have underlined the ONS phrase about capacity. There is a danger that the Local Plan confuses supply and demand. Building a lot of extra houses will attract immigrants to occupy them. This might appear to be meeting demand, but the demand is a response to supply and not the other way round.
ONS provide separate figures, for "natural" growth and for migration, only as far ahead as 2021. Beyond that there is simply an aggregrate projection, for the years 2021 - 2031. The latest projections are for just over 1000 extra people per year in the District. But the ONS systems round their figures to the nearest 1000, which could include any number between 501-1499. There is therefore a huge potential variation in the total as the annual figures accumulate over the Plan period for Warwick District.
This Society ventures no guesstimate on the projected District numbers, but we do not believe they can honestly be laid down as a certain evidence base for a plan to be set in concrete & brick over the next 15 years and more. Granted that there needs to be a working assumption, the NPPF also demands realism in plan making. In the longer run it is much more likely than not that the outcomes will depart from current projections. Good, realistic planning would provide flexibility to track progress during the plan period and criteria to respond appropriately.
Rather than simply being reactive to individual applications, the Plan should set a hierarchy of priorities towards achieving the District's housing needs, with sequential choice assigned to key objectives.
LOCATION
Warwick District has had difficulty in allocating housing locations for the large numbers anticipated. But even if an overall allocation of sites is set out as in this strategy document, there remains the question of how developers will respond. Understandably they will seek to cherry pick, in search of convenience and maximum profit. Any Plan worth the name will need to prioritise and hence respond to applications on a firm basis.
The mechanisms for setting and achieving effective priorities are no doubt technical. Various carrots and sticks are available but these will surely need to be driven by criteria set out in the Plan.
4.2 We are glad to note significant numbers allocated to urban sites, along with some consolidation from employment areas and a large allowance for windfall sites.
4.3 This starts with WDC preferred options on broad location, but lacks any emphasis on"Brownfield" sites.
We believe the plan needs a stated priority to re-use such land, driven by beneficial conditions as necessary. (See also NPPF para 17 Core Planning Principles, bullet point 8)
This group of POs ends with a bullet point on rural areas, focussing on larger villages We believe this is an appropriate allocation, to concentrate on villages which can best sustain local schools, shops and other services. This should encourage a younger rural population to stay. Also inevitably some migrants into Warwick District will choose a village location and they can best be accommodated in this way.
CHARACTER of new HOUSING DEVELOPMENTS
Given the total numbers, a key element of their location is the land requirement. In arriving at this far too little attention is given to the character of the proposed developments. If Warwick and Leamington had been built at the low, suburban densities envisaged under the plan strategy, they would sprawl over a far greater area of the Warwickshire countryside.
But this is not simply a matter of the amount of land needed. It also relates to diversity of housing need, to affordability, and to the viability of public transport.
Affordability
This is almost certainly the most challenging problem in shaping housing policy. The figures in terms of house prices and of market rents are stark. We supported the PO5 for 40% affordable housing in new developments. This is easier said than achieved : the District has to cope with market forces and is a small local cog driven by the machinery of national government.
5.1.4 "Provide 40% . . The nature of this affordable housing should be agreed with the Council as part of any planning applications"
This vague aspirational statement offers no guidance for negotiating such an agreement, no hint of the means to this end. Can this be a robust or reliable basis on which WDC will resist developer pressure to dilute or claim grounds for avoiding the 40% requirement ?
Affordability at 40 % will surely be dependent on design (not merely on financial engineering) and we doubt very much that this policy can be sustained without firmer guidance, perhaps through Design Codes (NPPF para 59).
Diversity
There is brief reference to size & number of bedrooms related to the SHMA and also mention of older people, (plus students and HIMOs,which are not required). But this seriously fails to address the diversity of varying accommodation requirements over modern lifetimes & social choices; it also entirely ignores the potential for an imaginative range of layout and architecture in addition to rows of houses and lawns.
This is not to denigrate a traditional house and a garden as a common choice of family property but it is simply unrealistic to assume that throughout our typically long and varied lives we are all or mostly living in unchanging families of parents with young children. Moreover that choice / assumption carries with it serious environmental and cost consequences. It appears that developers are most comfortable with this traditional layout. But the function of a local Plan is not simply to align with the "low hanging fruit" most attractive to developers: otherwise there would be no point in a Plan, just leave it all to the market.
We say that the District Plan should give a much stronger lead in challenging developers to come up with more ambitious and diverse designs for varied needs, including affordability.
Transport & Sustainability
The effectiveness of the WCC traffic mitigation proposals, as well as their potential to degrade the local environment, is a matter of argument. But the prime question should be : what is it about these housing proposals that causes such serious traffic consequences ?
It is inevitable that large additional developments - of housing along with employment and community needs - will give rise to a substantial increase in traffic. It is also true that those living in these new developments will own and use motor cars for much personal travel. But it is not inevitable that all of them will do so or that they should have no other options. Some may not be able to drive, some may not have individual use of a car. If housing is to include 40% affordable, then for many household budgets the cost of motoring and especially of multiple car ownership will present hard choices. That is without considering the sheer hassle of daily congestion, parking at destinations, and other considerations in making a personal choice to walk, cycle or use public transport.
3.4 Says that the strategy seeks :-
"Low carbon environmental sustainability" & "Provide for the appropriate & necessary transport "
NPPF para 7 sets out the three dimensions of sustainability, including the third, environmental role
para 17 lists Core planning principles including :-
* "Contribute to conserving . . the natural environment and reducing pollution"
* "Actively manage patterns of growth to make the fullest possible use of public transport , walking and cycling . . ."
5.1.3 Densities
WDC refers to the Garden Towns, Villages & Suburbs Prospectus with Densities of 30-35 dph (dwellings per hectare) or 25-30 dph at the edge.
An undeniable outcome of such densities is to bias transport options overwhelmingly towards use of the car for the vast majority of journeys. It is this feature of your southern housing strategy which aggravates the potential traffic congestion in and around Warwick & Leamington.
This feature is directly in conflict with your own stated Strategic Vision at 3.4
It also is in conflict with the NPPF : Environmental dimension of Sustainable Development
It does not require technical analysis to understand the general point that low density suburban layout is inimical to efficient and economic public transport links. But professional analysis provides good evidence that densities of the order 50 dph and more are the benchmark for viable public transport within 10 minutes walk of each home.
While cycle ways and footpaths may be provided, the very intensity of motor traffic allied to big highway formations (mitigation) will seriously deter cyclists and pedestrians. That, along with the paucity of public transport, makes for a vicious circle against the sustainable choice. It will also increase pollution.
Garden Space

We do not suggest there should be no private gardens in the new developments, but neither is
it useful to insist on gardens throughout. It is perfectly possible to incorporate garden space at up to 50 dph, alongside a smaller proportion at the lower density. Were a choice of some flats and maisonettes included in a mixed development, these may well be at 100 dph. Altogether, a brief for a more diverse range of accommodation within varied layouts could provide a much less sprawling development. This would take less road space, meet varied housing needs, offer more sustainable transport options, and could more realistically provide the crucial element of affordability. It can be set alongside green wedges, allotments, etc as well as leaving more real countryside.

Finally, regarding the WDC "Garden Suburbs" prospectus I attach our response from last year. We indicated a series of points on which we say this is inadequate as a policy document and in parts misleading. It often confuses green pictures with genuinely sustainable solutions to the District's housing needs.

In this connection, we have looked at the WDC website commentary on 2012 responses to the POs. In relation to low density sprawl it states :-

"A balance needs to be struck between land-take and the quality of design"

We are surprised at this suggestion of a false conflict: quality of design resides in meeting the needs of a situation with skilled, well tailored solutions.

1 & 2 Introduction / Consultation Process
Right now the District is in an uncomfortable position, with limited powers to exercise priorities, before a new Local Plan is in place. Progress towards that Plan is crucial but the Plan will be of little benefit unless it sets clear and specific criteria for shaping the District's development. This statement of the obvious is made because we seek firmer guidelines for development within the Plan period.
The Leamington Society has previously made strong representations about PO10: Built Environment and we note that in the current Strategic Vision text there is more than one reference to "Garden towns, suburbs and villages". We therefore include this theme in our response (and did indeed 'phone to consult one of your officers on this point).
3 Strategic Vision

3.5 SOCIAL
Of the four bullet points, we particularly endorse point 2 :-
"Providing for diversity, including affordable homes, homes for the elderly and vulnerable and other specialised needs"
But the context of "diversity" should include specific reference to a wide range of dwellings to meet varied lifetime circumstances - beyond the limited special categories identified here.
We pick up this theme below, detailing our concern about the character of the suburban housing developments currently anticipated.
4 Housing
Formulating a core strategy in relation to housing provision is proving controversial. The headline feature of the revised strategy is to plan for very large suburban extensions to the south of Leamington and Warwick. It is evident that this has the potential seriously to aggravate existing traffic problems and will require considerable road works. Such works will be expensive and highly intrusive: they may mitigate the immediate local problem but will not prevent an increase in congestion and pollution around and within the adjoining towns.
There are three elements to this large increase in housing allocation: the total numbers, the proposed locations, and the character and density of the new developments.
THE NUMBERS
We note that half of the potential growth derives from predictions of inward migration to the District. These projections are fraught with uncertainty, as the ONS (Office of National Statistics) warns :-
"The projections are not forecasts and do not take any account of future government policies, changing economic circumstances or the capacity of an area to accommodate the change in population. They provide an indication of the future size and age structures of the population if recent demographic trends are continued. Population projections become increasingly uncertain the further they are carried forward, and particularly so for smaller geographic areas."
We have underlined the ONS phrase about capacity. There is a danger that the Local Plan confuses supply and demand. Building a lot of extra houses will attract immigrants to occupy them. This might appear to be meeting demand, but the demand is a response to supply and not the other way round.
ONS provide separate figures, for "natural" growth and for migration, only as far ahead as 2021. Beyond that there is simply an aggregrate projection, for the years 2021 - 2031. The latest projections are for just over 1000 extra people per year in the District. But the ONS systems round their figures to the nearest 1000, which could include any number between 501-1499. There is therefore a huge potential variation in the total as the annual figures accumulate over the Plan period for Warwick District.
This Society ventures no guesstimate on the projected District numbers, but we do not believe they can honestly be laid down as a certain evidence base for a plan to be set in concrete & brick over the next 15 years and more. Granted that there needs to be a working assumption, the NPPF also demands realism in plan making. In the longer run it is much more likely than not that the outcomes will depart from current projections. Good, realistic planning would provide flexibility to track progress during the plan period and criteria to respond appropriately.
Rather than simply being reactive to individual applications, the Plan should set a hierarchy of priorities towards achieving the District's housing needs, with sequential choice assigned to key objectives.
LOCATION
Warwick District has had difficulty in allocating housing locations for the large numbers anticipated. But even if an overall allocation of sites is set out as in this strategy document, there remains the question of how developers will respond. Understandably they will seek to cherry pick, in search of convenience and maximum profit. Any Plan worth the name will need to prioritise and hence respond to applications on a firm basis.
The mechanisms for setting and achieving effective priorities are no doubt technical. Various carrots and sticks are available but these will surely need to be driven by criteria set out in the Plan.
4.2 We are glad to note significant numbers allocated to urban sites, along with some consolidation from employment areas and a large allowance for windfall sites.
4.3 This starts with WDC preferred options on broad location, but lacks any emphasis on"Brownfield" sites.
We believe the plan needs a stated priority to re-use such land, driven by beneficial conditions as necessary. (See also NPPF para 17 Core Planning Principles, bullet point 8)
This group of POs ends with a bullet point on rural areas, focussing on larger villages We believe this is an appropriate allocation, to concentrate on villages which can best sustain local schools, shops and other services. This should encourage a younger rural population to stay. Also inevitably some migrants into Warwick District will choose a village location and they can best be accommodated in this way.
CHARACTER of new HOUSING DEVELOPMENTS
Given the total numbers, a key element of their location is the land requirement. In arriving at this far too little attention is given to the character of the proposed developments. If Warwick and Leamington had been built at the low, suburban densities envisaged under the plan strategy, they would sprawl over a far greater area of the Warwickshire countryside.
But this is not simply a matter of the amount of land needed. It also relates to diversity of housing need, to affordability, and to the viability of public transport.
Affordability
This is almost certainly the most challenging problem in shaping housing policy. The figures in terms of house prices and of market rents are stark. We supported the PO5 for 40% affordable housing in new developments. This is easier said than achieved : the District has to cope with market forces and is a small local cog driven by the machinery of national government.
5.1.4 "Provide 40% . . The nature of this affordable housing should be agreed with the Council as part of any planning applications"
This vague aspirational statement offers no guidance for negotiating such an agreement, no hint of the means to this end. Can this be a robust or reliable basis on which WDC will resist developer pressure to dilute or claim grounds for avoiding the 40% requirement ?
Affordability at 40 % will surely be dependent on design (not merely on financial engineering) and we doubt very much that this policy can be sustained without firmer guidance, perhaps through Design Codes (NPPF para 59).
Diversity
There is brief reference to size & number of bedrooms related to the SHMA and also mention of older people, (plus students and HIMOs,which are not required). But this seriously fails to address the diversity of varying accommodation requirements over modern lifetimes & social choices; it also entirely ignores the potential for an imaginative range of layout and architecture in addition to rows of houses and lawns.
This is not to denigrate a traditional house and a garden as a common choice of family property but it is simply unrealistic to assume that throughout our typically long and varied lives we are all or mostly living in unchanging families of parents with young children. Moreover that choice / assumption carries with it serious environmental and cost consequences. It appears that developers are most comfortable with this traditional layout. But the function of a local Plan is not simply to align with the "low hanging fruit" most attractive to developers: otherwise there would be no point in a Plan, just leave it all to the market.
We say that the District Plan should give a much stronger lead in challenging developers to come up with more ambitious and diverse designs for varied needs, including affordability.
Transport & Sustainability
The effectiveness of the WCC traffic mitigation proposals, as well as their potential to degrade the local environment, is a matter of argument. But the prime question should be : what is it about these housing proposals that causes such serious traffic consequences ?
It is inevitable that large additional developments - of housing along with employment and community needs - will give rise to a substantial increase in traffic. It is also true that those living in these new developments will own and use motor cars for much personal travel. But it is not inevitable that all of them will do so or that they should have no other options. Some may not be able to drive, some may not have individual use of a car. If housing is to include 40% affordable, then for many household budgets the cost of motoring and especially of multiple car ownership will present hard choices. That is without considering the sheer hassle of daily congestion, parking at destinations, and other considerations in making a personal choice to walk, cycle or use public transport.
3.4 Says that the strategy seeks :-
"Low carbon environmental sustainability" & "Provide for the appropriate & necessary transport "
NPPF para 7 sets out the three dimensions of sustainability, including the third, environmental role
para 17 lists Core planning principles including :-
* "Contribute to conserving . . the natural environment and reducing pollution"
* "Actively manage patterns of growth to make the fullest possible use of public transport , walking and cycling . . ."
5.1.3 Densities
WDC refers to the Garden Towns, Villages & Suburbs Prospectus with Densities of 30-35 dph (dwellings per hectare) or 25-30 dph at the edge.
An undeniable outcome of such densities is to bias transport options overwhelmingly towards use of the car for the vast majority of journeys. It is this feature of your southern housing strategy which aggravates the potential traffic congestion in and around Warwick & Leamington.
This feature is directly in conflict with your own stated Strategic Vision at 3.4
It also is in conflict with the NPPF : Environmental dimension of Sustainable Development
It does not require technical analysis to understand the general point that low density suburban layout is inimical to efficient and economic public transport links. But professional analysis provides good evidence that densities of the order 50 dph and more are the benchmark for viable public transport within 10 minutes walk of each home.
While cycle ways and footpaths may be provided, the very intensity of motor traffic allied to big highway formations (mitigation) will seriously deter cyclists and pedestrians. That, along with the paucity of public transport, makes for a vicious circle against the sustainable choice. It will also increase pollution.
Garden Space

We do not suggest there should be no private gardens in the new developments, but neither is
it useful to insist on gardens throughout. It is perfectly possible to incorporate garden space at up to 50 dph, alongside a smaller proportion at the lower density. Were a choice of some flats and maisonettes included in a mixed development, these may well be at 100 dph. Altogether, a brief for a more diverse range of accommodation within varied layouts could provide a much less sprawling development. This would take less road space, meet varied housing needs, offer more sustainable transport options, and could more realistically provide the crucial element of affordability. It can be set alongside green wedges, allotments, etc as well as leaving more real countryside.

Finally, regarding the WDC "Garden Suburbs" prospectus I attach our response from last year. We indicated a series of points on which we say this is inadequate as a policy document and in parts misleading. It often confuses green pictures with genuinely sustainable solutions to the District's housing needs.

In this connection, we have looked at the WDC website commentary on 2012 responses to the POs. In relation to low density sprawl it states :-

"A balance needs to be struck between land-take and the quality of design"

We are surprised at this suggestion of a false conflict: quality of design resides in meeting the needs of a situation with skilled, well tailored solutions.

1 & 2 Introduction / Consultation Process
Right now the District is in an uncomfortable position, with limited powers to exercise priorities, before a new Local Plan is in place. Progress towards that Plan is crucial but the Plan will be of little benefit unless it sets clear and specific criteria for shaping the District's development. This statement of the obvious is made because we seek firmer guidelines for development within the Plan period.
The Leamington Society has previously made strong representations about PO10: Built Environment and we note that in the current Strategic Vision text there is more than one reference to "Garden towns, suburbs and villages". We therefore include this theme in our response (and did indeed 'phone to consult one of your officers on this point).
3 Strategic Vision

3.5 SOCIAL
Of the four bullet points, we particularly endorse point 2 :-
"Providing for diversity, including affordable homes, homes for the elderly and vulnerable and other specialised needs"
But the context of "diversity" should include specific reference to a wide range of dwellings to meet varied lifetime circumstances - beyond the limited special categories identified here.
We pick up this theme below, detailing our concern about the character of the suburban housing developments currently anticipated.
4 Housing
Formulating a core strategy in relation to housing provision is proving controversial. The headline feature of the revised strategy is to plan for very large suburban extensions to the south of Leamington and Warwick. It is evident that this has the potential seriously to aggravate existing traffic problems and will require considerable road works. Such works will be expensive and highly intrusive: they may mitigate the immediate local problem but will not prevent an increase in congestion and pollution around and within the adjoining towns.
There are three elements to this large increase in housing allocation: the total numbers, the proposed locations, and the character and density of the new developments.
THE NUMBERS
We note that half of the potential growth derives from predictions of inward migration to the District. These projections are fraught with uncertainty, as the ONS (Office of National Statistics) warns :-
"The projections are not forecasts and do not take any account of future government policies, changing economic circumstances or the capacity of an area to accommodate the change in population. They provide an indication of the future size and age structures of the population if recent demographic trends are continued. Population projections become increasingly uncertain the further they are carried forward, and particularly so for smaller geographic areas."
We have underlined the ONS phrase about capacity. There is a danger that the Local Plan confuses supply and demand. Building a lot of extra houses will attract immigrants to occupy them. This might appear to be meeting demand, but the demand is a response to supply and not the other way round.
ONS provide separate figures, for "natural" growth and for migration, only as far ahead as 2021. Beyond that there is simply an aggregrate projection, for the years 2021 - 2031. The latest projections are for just over 1000 extra people per year in the District. But the ONS systems round their figures to the nearest 1000, which could include any number between 501-1499. There is therefore a huge potential variation in the total as the annual figures accumulate over the Plan period for Warwick District.
This Society ventures no guesstimate on the projected District numbers, but we do not believe they can honestly be laid down as a certain evidence base for a plan to be set in concrete & brick over the next 15 years and more. Granted that there needs to be a working assumption, the NPPF also demands realism in plan making. In the longer run it is much more likely than not that the outcomes will depart from current projections. Good, realistic planning would provide flexibility to track progress during the plan period and criteria to respond appropriately.
Rather than simply being reactive to individual applications, the Plan should set a hierarchy of priorities towards achieving the District's housing needs, with sequential choice assigned to key objectives.
LOCATION
Warwick District has had difficulty in allocating housing locations for the large numbers anticipated. But even if an overall allocation of sites is set out as in this strategy document, there remains the question of how developers will respond. Understandably they will seek to cherry pick, in search of convenience and maximum profit. Any Plan worth the name will need to prioritise and hence respond to applications on a firm basis.
The mechanisms for setting and achieving effective priorities are no doubt technical. Various carrots and sticks are available but these will surely need to be driven by criteria set out in the Plan.
4.2 We are glad to note significant numbers allocated to urban sites, along with some consolidation from employment areas and a large allowance for windfall sites.
4.3 This starts with WDC preferred options on broad location, but lacks any emphasis on"Brownfield" sites.
We believe the plan needs a stated priority to re-use such land, driven by beneficial conditions as necessary. (See also NPPF para 17 Core Planning Principles, bullet point 8)
This group of POs ends with a bullet point on rural areas, focussing on larger villages We believe this is an appropriate allocation, to concentrate on villages which can best sustain local schools, shops and other services. This should encourage a younger rural population to stay. Also inevitably some migrants into Warwick District will choose a village location and they can best be accommodated in this way.
CHARACTER of new HOUSING DEVELOPMENTS
Given the total numbers, a key element of their location is the land requirement. In arriving at this far too little attention is given to the character of the proposed developments. If Warwick and Leamington had been built at the low, suburban densities envisaged under the plan strategy, they would sprawl over a far greater area of the Warwickshire countryside.
But this is not simply a matter of the amount of land needed. It also relates to diversity of housing need, to affordability, and to the viability of public transport.
Affordability
This is almost certainly the most challenging problem in shaping housing policy. The figures in terms of house prices and of market rents are stark. We supported the PO5 for 40% affordable housing in new developments. This is easier said than achieved : the District has to cope with market forces and is a small local cog driven by the machinery of national government.
5.1.4 "Provide 40% . . The nature of this affordable housing should be agreed with the Council as part of any planning applications"
This vague aspirational statement offers no guidance for negotiating such an agreement, no hint of the means to this end. Can this be a robust or reliable basis on which WDC will resist developer pressure to dilute or claim grounds for avoiding the 40% requirement ?
Affordability at 40 % will surely be dependent on design (not merely on financial engineering) and we doubt very much that this policy can be sustained without firmer guidance, perhaps through Design Codes (NPPF para 59).
Diversity
There is brief reference to size & number of bedrooms related to the SHMA and also mention of older people, (plus students and HIMOs,which are not required). But this seriously fails to address the diversity of varying accommodation requirements over modern lifetimes & social choices; it also entirely ignores the potential for an imaginative range of layout and architecture in addition to rows of houses and lawns.
This is not to denigrate a traditional house and a garden as a common choice of family property but it is simply unrealistic to assume that throughout our typically long and varied lives we are all or mostly living in unchanging families of parents with young children. Moreover that choice / assumption carries with it serious environmental and cost consequences. It appears that developers are most comfortable with this traditional layout. But the function of a local Plan is not simply to align with the "low hanging fruit" most attractive to developers: otherwise there would be no point in a Plan, just leave it all to the market.
We say that the District Plan should give a much stronger lead in challenging developers to come up with more ambitious and diverse designs for varied needs, including affordability.
Transport & Sustainability
The effectiveness of the WCC traffic mitigation proposals, as well as their potential to degrade the local environment, is a matter of argument. But the prime question should be : what is it about these housing proposals that causes such serious traffic consequences ?
It is inevitable that large additional developments - of housing along with employment and community needs - will give rise to a substantial increase in traffic. It is also true that those living in these new developments will own and use motor cars for much personal travel. But it is not inevitable that all of them will do so or that they should have no other options. Some may not be able to drive, some may not have individual use of a car. If housing is to include 40% affordable, then for many household budgets the cost of motoring and especially of multiple car ownership will present hard choices. That is without considering the sheer hassle of daily congestion, parking at destinations, and other considerations in making a personal choice to walk, cycle or use public transport.
3.4 Says that the strategy seeks :-
"Low carbon environmental sustainability" & "Provide for the appropriate & necessary transport "
NPPF para 7 sets out the three dimensions of sustainability, including the third, environmental role
para 17 lists Core planning principles including :-
* "Contribute to conserving . . the natural environment and reducing pollution"
* "Actively manage patterns of growth to make the fullest possible use of public transport , walking and cycling . . ."
5.1.3 Densities
WDC refers to the Garden Towns, Villages & Suburbs Prospectus with Densities of 30-35 dph (dwellings per hectare) or 25-30 dph at the edge.
An undeniable outcome of such densities is to bias transport options overwhelmingly towards use of the car for the vast majority of journeys. It is this feature of your southern housing strategy which aggravates the potential traffic congestion in and around Warwick & Leamington.
This feature is directly in conflict with your own stated Strategic Vision at 3.4
It also is in conflict with the NPPF : Environmental dimension of Sustainable Development
It does not require technical analysis to understand the general point that low density suburban layout is inimical to efficient and economic public transport links. But professional analysis provides good evidence that densities of the order 50 dph and more are the benchmark for viable public transport within 10 minutes walk of each home.
While cycle ways and footpaths may be provided, the very intensity of motor traffic allied to big highway formations (mitigation) will seriously deter cyclists and pedestrians. That, along with the paucity of public transport, makes for a vicious circle against the sustainable choice. It will also increase pollution.
Garden Space

We do not suggest there should be no private gardens in the new developments, but neither is
it useful to insist on gardens throughout. It is perfectly possible to incorporate garden space at up to 50 dph, alongside a smaller proportion at the lower density. Were a choice of some flats and maisonettes included in a mixed development, these may well be at 100 dph. Altogether, a brief for a more diverse range of accommodation within varied layouts could provide a much less sprawling development. This would take less road space, meet varied housing needs, offer more sustainable transport options, and could more realistically provide the crucial element of affordability. It can be set alongside green wedges, allotments, etc as well as leaving more real countryside.

Finally, regarding the WDC "Garden Suburbs" prospectus I attach our response from last year. We indicated a series of points on which we say this is inadequate as a policy document and in parts misleading. It often confuses green pictures with genuinely sustainable solutions to the District's housing needs.

In this connection, we have looked at the WDC website commentary on 2012 responses to the POs. In relation to low density sprawl it states :-

"A balance needs to be struck between land-take and the quality of design"

We are surprised at this suggestion of a false conflict: quality of design resides in meeting the needs of a situation with skilled, well tailored solutions.

1 & 2 Introduction / Consultation Process
Right now the District is in an uncomfortable position, with limited powers to exercise priorities, before a new Local Plan is in place. Progress towards that Plan is crucial but the Plan will be of little benefit unless it sets clear and specific criteria for shaping the District's development. This statement of the obvious is made because we seek firmer guidelines for development within the Plan period.
The Leamington Society has previously made strong representations about PO10: Built Environment and we note that in the current Strategic Vision text there is more than one reference to "Garden towns, suburbs and villages". We therefore include this theme in our response (and did indeed 'phone to consult one of your officers on this point).
3 Strategic Vision

3.5 SOCIAL
Of the four bullet points, we particularly endorse point 2 :-
"Providing for diversity, including affordable homes, homes for the elderly and vulnerable and other specialised needs"
But the context of "diversity" should include specific reference to a wide range of dwellings to meet varied lifetime circumstances - beyond the limited special categories identified here.
We pick up this theme below, detailing our concern about the character of the suburban housing developments currently anticipated.
4 Housing
Formulating a core strategy in relation to housing provision is proving controversial. The headline feature of the revised strategy is to plan for very large suburban extensions to the south of Leamington and Warwick. It is evident that this has the potential seriously to aggravate existing traffic problems and will require considerable road works. Such works will be expensive and highly intrusive: they may mitigate the immediate local problem but will not prevent an increase in congestion and pollution around and within the adjoining towns.
There are three elements to this large increase in housing allocation: the total numbers, the proposed locations, and the character and density of the new developments.
THE NUMBERS
We note that half of the potential growth derives from predictions of inward migration to the District. These projections are fraught with uncertainty, as the ONS (Office of National Statistics) warns :-
"The projections are not forecasts and do not take any account of future government policies, changing economic circumstances or the capacity of an area to accommodate the change in population. They provide an indication of the future size and age structures of the population if recent demographic trends are continued. Population projections become increasingly uncertain the further they are carried forward, and particularly so for smaller geographic areas."
We have underlined the ONS phrase about capacity. There is a danger that the Local Plan confuses supply and demand. Building a lot of extra houses will attract immigrants to occupy them. This might appear to be meeting demand, but the demand is a response to supply and not the other way round.
ONS provide separate figures, for "natural" growth and for migration, only as far ahead as 2021. Beyond that there is simply an aggregrate projection, for the years 2021 - 2031. The latest projections are for just over 1000 extra people per year in the District. But the ONS systems round their figures to the nearest 1000, which could include any number between 501-1499. There is therefore a huge potential variation in the total as the annual figures accumulate over the Plan period for Warwick District.
This Society ventures no guesstimate on the projected District numbers, but we do not believe they can honestly be laid down as a certain evidence base for a plan to be set in concrete & brick over the next 15 years and more. Granted that there needs to be a working assumption, the NPPF also demands realism in plan making. In the longer run it is much more likely than not that the outcomes will depart from current projections. Good, realistic planning would provide flexibility to track progress during the plan period and criteria to respond appropriately.
Rather than simply being reactive to individual applications, the Plan should set a hierarchy of priorities towards achieving the District's housing needs, with sequential choice assigned to key objectives.
LOCATION
Warwick District has had difficulty in allocating housing locations for the large numbers anticipated. But even if an overall allocation of sites is set out as in this strategy document, there remains the question of how developers will respond. Understandably they will seek to cherry pick, in search of convenience and maximum profit. Any Plan worth the name will need to prioritise and hence respond to applications on a firm basis.
The mechanisms for setting and achieving effective priorities are no doubt technical. Various carrots and sticks are available but these will surely need to be driven by criteria set out in the Plan.
4.2 We are glad to note significant numbers allocated to urban sites, along with some consolidation from employment areas and a large allowance for windfall sites.
4.3 This starts with WDC preferred options on broad location, but lacks any emphasis on"Brownfield" sites.
We believe the plan needs a stated priority to re-use such land, driven by beneficial conditions as necessary. (See also NPPF para 17 Core Planning Principles, bullet point 8)
This group of POs ends with a bullet point on rural areas, focussing on larger villages We believe this is an appropriate allocation, to concentrate on villages which can best sustain local schools, shops and other services. This should encourage a younger rural population to stay. Also inevitably some migrants into Warwick District will choose a village location and they can best be accommodated in this way.
CHARACTER of new HOUSING DEVELOPMENTS
Given the total numbers, a key element of their location is the land requirement. In arriving at this far too little attention is given to the character of the proposed developments. If Warwick and Leamington had been built at the low, suburban densities envisaged under the plan strategy, they would sprawl over a far greater area of the Warwickshire countryside.
But this is not simply a matter of the amount of land needed. It also relates to diversity of housing need, to affordability, and to the viability of public transport.
Affordability
This is almost certainly the most challenging problem in shaping housing policy. The figures in terms of house prices and of market rents are stark. We supported the PO5 for 40% affordable housing in new developments. This is easier said than achieved : the District has to cope with market forces and is a small local cog driven by the machinery of national government.
5.1.4 "Provide 40% . . The nature of this affordable housing should be agreed with the Council as part of any planning applications"
This vague aspirational statement offers no guidance for negotiating such an agreement, no hint of the means to this end. Can this be a robust or reliable basis on which WDC will resist developer pressure to dilute or claim grounds for avoiding the 40% requirement ?
Affordability at 40 % will surely be dependent on design (not merely on financial engineering) and we doubt very much that this policy can be sustained without firmer guidance, perhaps through Design Codes (NPPF para 59).
Diversity
There is brief reference to size & number of bedrooms related to the SHMA and also mention of older people, (plus students and HIMOs,which are not required). But this seriously fails to address the diversity of varying accommodation requirements over modern lifetimes & social choices; it also entirely ignores the potential for an imaginative range of layout and architecture in addition to rows of houses and lawns.
This is not to denigrate a traditional house and a garden as a common choice of family property but it is simply unrealistic to assume that throughout our typically long and varied lives we are all or mostly living in unchanging families of parents with young children. Moreover that choice / assumption carries with it serious environmental and cost consequences. It appears that developers are most comfortable with this traditional layout. But the function of a local Plan is not simply to align with the "low hanging fruit" most attractive to developers: otherwise there would be no point in a Plan, just leave it all to the market.
We say that the District Plan should give a much stronger lead in challenging developers to come up with more ambitious and diverse designs for varied needs, including affordability.
Transport & Sustainability
The effectiveness of the WCC traffic mitigation proposals, as well as their potential to degrade the local environment, is a matter of argument. But the prime question should be : what is it about these housing proposals that causes such serious traffic consequences ?
It is inevitable that large additional developments - of housing along with employment and community needs - will give rise to a substantial increase in traffic. It is also true that those living in these new developments will own and use motor cars for much personal travel. But it is not inevitable that all of them will do so or that they should have no other options. Some may not be able to drive, some may not have individual use of a car. If housing is to include 40% affordable, then for many household budgets the cost of motoring and especially of multiple car ownership will present hard choices. That is without considering the sheer hassle of daily congestion, parking at destinations, and other considerations in making a personal choice to walk, cycle or use public transport.
3.4 Says that the strategy seeks :-
"Low carbon environmental sustainability" & "Provide for the appropriate & necessary transport "
NPPF para 7 sets out the three dimensions of sustainability, including the third, environmental role
para 17 lists Core planning principles including :-
* "Contribute to conserving . . the natural environment and reducing pollution"
* "Actively manage patterns of growth to make the fullest possible use of public transport , walking and cycling . . ."
5.1.3 Densities
WDC refers to the Garden Towns, Villages & Suburbs Prospectus with Densities of 30-35 dph (dwellings per hectare) or 25-30 dph at the edge.
An undeniable outcome of such densities is to bias transport options overwhelmingly towards use of the car for the vast majority of journeys. It is this feature of your southern housing strategy which aggravates the potential traffic congestion in and around Warwick & Leamington.
This feature is directly in conflict with your own stated Strategic Vision at 3.4
It also is in conflict with the NPPF : Environmental dimension of Sustainable Development
It does not require technical analysis to understand the general point that low density suburban layout is inimical to efficient and economic public transport links. But professional analysis provides good evidence that densities of the order 50 dph and more are the benchmark for viable public transport within 10 minutes walk of each home.
While cycle ways and footpaths may be provided, the very intensity of motor traffic allied to big highway formations (mitigation) will seriously deter cyclists and pedestrians. That, along with the paucity of public transport, makes for a vicious circle against the sustainable choice. It will also increase pollution.
Garden Space

We do not suggest there should be no private gardens in the new developments, but neither is
it useful to insist on gardens throughout. It is perfectly possible to incorporate garden space at up to 50 dph, alongside a smaller proportion at the lower density. Were a choice of some flats and maisonettes included in a mixed development, these may well be at 100 dph. Altogether, a brief for a more diverse range of accommodation within varied layouts could provide a much less sprawling development. This would take less road space, meet varied housing needs, offer more sustainable transport options, and could more realistically provide the crucial element of affordability. It can be set alongside green wedges, allotments, etc as well as leaving more real countryside.

Finally, regarding the WDC "Garden Suburbs" prospectus I attach our response from last year. We indicated a series of points on which we say this is inadequate as a policy document and in parts misleading. It often confuses green pictures with genuinely sustainable solutions to the District's housing needs.

In this connection, we have looked at the WDC website commentary on 2012 responses to the POs. In relation to low density sprawl it states :-

"A balance needs to be struck between land-take and the quality of design"

We are surprised at this suggestion of a false conflict: quality of design resides in meeting the needs of a situation with skilled, well tailored solutions.

1 & 2 Introduction / Consultation Process
Right now the District is in an uncomfortable position, with limited powers to exercise priorities, before a new Local Plan is in place. Progress towards that Plan is crucial but the Plan will be of little benefit unless it sets clear and specific criteria for shaping the District's development. This statement of the obvious is made because we seek firmer guidelines for development within the Plan period.
The Leamington Society has previously made strong representations about PO10: Built Environment and we note that in the current Strategic Vision text there is more than one reference to "Garden towns, suburbs and villages". We therefore include this theme in our response (and did indeed 'phone to consult one of your officers on this point).
3 Strategic Vision

3.5 SOCIAL
Of the four bullet points, we particularly endorse point 2 :-
"Providing for diversity, including affordable homes, homes for the elderly and vulnerable and other specialised needs"
But the context of "diversity" should include specific reference to a wide range of dwellings to meet varied lifetime circumstances - beyond the limited special categories identified here.
We pick up this theme below, detailing our concern about the character of the suburban housing developments currently anticipated.
4 Housing
Formulating a core strategy in relation to housing provision is proving controversial. The headline feature of the revised strategy is to plan for very large suburban extensions to the south of Leamington and Warwick. It is evident that this has the potential seriously to aggravate existing traffic problems and will require considerable road works. Such works will be expensive and highly intrusive: they may mitigate the immediate local problem but will not prevent an increase in congestion and pollution around and within the adjoining towns.
There are three elements to this large increase in housing allocation: the total numbers, the proposed locations, and the character and density of the new developments.
THE NUMBERS
We note that half of the potential growth derives from predictions of inward migration to the District. These projections are fraught with uncertainty, as the ONS (Office of National Statistics) warns :-
"The projections are not forecasts and do not take any account of future government policies, changing economic circumstances or the capacity of an area to accommodate the change in population. They provide an indication of the future size and age structures of the population if recent demographic trends are continued. Population projections become increasingly uncertain the further they are carried forward, and particularly so for smaller geographic areas."
We have underlined the ONS phrase about capacity. There is a danger that the Local Plan confuses supply and demand. Building a lot of extra houses will attract immigrants to occupy them. This might appear to be meeting demand, but the demand is a response to supply and not the other way round.
ONS provide separate figures, for "natural" growth and for migration, only as far ahead as 2021. Beyond that there is simply an aggregrate projection, for the years 2021 - 2031. The latest projections are for just over 1000 extra people per year in the District. But the ONS systems round their figures to the nearest 1000, which could include any number between 501-1499. There is therefore a huge potential variation in the total as the annual figures accumulate over the Plan period for Warwick District.
This Society ventures no guesstimate on the projected District numbers, but we do not believe they can honestly be laid down as a certain evidence base for a plan to be set in concrete & brick over the next 15 years and more. Granted that there needs to be a working assumption, the NPPF also demands realism in plan making. In the longer run it is much more likely than not that the outcomes will depart from current projections. Good, realistic planning would provide flexibility to track progress during the plan period and criteria to respond appropriately.
Rather than simply being reactive to individual applications, the Plan should set a hierarchy of priorities towards achieving the District's housing needs, with sequential choice assigned to key objectives.
LOCATION
Warwick District has had difficulty in allocating housing locations for the large numbers anticipated. But even if an overall allocation of sites is set out as in this strategy document, there remains the question of how developers will respond. Understandably they will seek to cherry pick, in search of convenience and maximum profit. Any Plan worth the name will need to prioritise and hence respond to applications on a firm basis.
The mechanisms for setting and achieving effective priorities are no doubt technical. Various carrots and sticks are available but these will surely need to be driven by criteria set out in the Plan.
4.2 We are glad to note significant numbers allocated to urban sites, along with some consolidation from employment areas and a large allowance for windfall sites.
4.3 This starts with WDC preferred options on broad location, but lacks any emphasis on"Brownfield" sites.
We believe the plan needs a stated priority to re-use such land, driven by beneficial conditions as necessary. (See also NPPF para 17 Core Planning Principles, bullet point 8)
This group of POs ends with a bullet point on rural areas, focussing on larger villages We believe this is an appropriate allocation, to concentrate on villages which can best sustain local schools, shops and other services. This should encourage a younger rural population to stay. Also inevitably some migrants into Warwick District will choose a village location and they can best be accommodated in this way.
CHARACTER of new HOUSING DEVELOPMENTS
Given the total numbers, a key element of their location is the land requirement. In arriving at this far too little attention is given to the character of the proposed developments. If Warwick and Leamington had been built at the low, suburban densities envisaged under the plan strategy, they would sprawl over a far greater area of the Warwickshire countryside.
But this is not simply a matter of the amount of land needed. It also relates to diversity of housing need, to affordability, and to the viability of public transport.
Affordability
This is almost certainly the most challenging problem in shaping housing policy. The figures in terms of house prices and of market rents are stark. We supported the PO5 for 40% affordable housing in new developments. This is easier said than achieved : the District has to cope with market forces and is a small local cog driven by the machinery of national government.
5.1.4 "Provide 40% . . The nature of this affordable housing should be agreed with the Council as part of any planning applications"
This vague aspirational statement offers no guidance for negotiating such an agreement, no hint of the means to this end. Can this be a robust or reliable basis on which WDC will resist developer pressure to dilute or claim grounds for avoiding the 40% requirement ?
Affordability at 40 % will surely be dependent on design (not merely on financial engineering) and we doubt very much that this policy can be sustained without firmer guidance, perhaps through Design Codes (NPPF para 59).
Diversity
There is brief reference to size & number of bedrooms related to the SHMA and also mention of older people, (plus students and HIMOs,which are not required). But this seriously fails to address the diversity of varying accommodation requirements over modern lifetimes & social choices; it also entirely ignores the potential for an imaginative range of layout and architecture in addition to rows of houses and lawns.
This is not to denigrate a traditional house and a garden as a common choice of family property but it is simply unrealistic to assume that throughout our typically long and varied lives we are all or mostly living in unchanging families of parents with young children. Moreover that choice / assumption carries with it serious environmental and cost consequences. It appears that developers are most comfortable with this traditional layout. But the function of a local Plan is not simply to align with the "low hanging fruit" most attractive to developers: otherwise there would be no point in a Plan, just leave it all to the market.
We say that the District Plan should give a much stronger lead in challenging developers to come up with more ambitious and diverse designs for varied needs, including affordability.
Transport & Sustainability
The effectiveness of the WCC traffic mitigation proposals, as well as their potential to degrade the local environment, is a matter of argument. But the prime question should be : what is it about these housing proposals that causes such serious traffic consequences ?
It is inevitable that large additional developments - of housing along with employment and community needs - will give rise to a substantial increase in traffic. It is also true that those living in these new developments will own and use motor cars for much personal travel. But it is not inevitable that all of them will do so or that they should have no other options. Some may not be able to drive, some may not have individual use of a car. If housing is to include 40% affordable, then for many household budgets the cost of motoring and especially of multiple car ownership will present hard choices. That is without considering the sheer hassle of daily congestion, parking at destinations, and other considerations in making a personal choice to walk, cycle or use public transport.
3.4 Says that the strategy seeks :-
"Low carbon environmental sustainability" & "Provide for the appropriate & necessary transport "
NPPF para 7 sets out the three dimensions of sustainability, including the third, environmental role
para 17 lists Core planning principles including :-
* "Contribute to conserving . . the natural environment and reducing pollution"
* "Actively manage patterns of growth to make the fullest possible use of public transport , walking and cycling . . ."
5.1.3 Densities
WDC refers to the Garden Towns, Villages & Suburbs Prospectus with Densities of 30-35 dph (dwellings per hectare) or 25-30 dph at the edge.
An undeniable outcome of such densities is to bias transport options overwhelmingly towards use of the car for the vast majority of journeys. It is this feature of your southern housing strategy which aggravates the potential traffic congestion in and around Warwick & Leamington.
This feature is directly in conflict with your own stated Strategic Vision at 3.4
It also is in conflict with the NPPF : Environmental dimension of Sustainable Development
It does not require technical analysis to understand the general point that low density suburban layout is inimical to efficient and economic public transport links. But professional analysis provides good evidence that densities of the order 50 dph and more are the benchmark for viable public transport within 10 minutes walk of each home.
While cycle ways and footpaths may be provided, the very intensity of motor traffic allied to big highway formations (mitigation) will seriously deter cyclists and pedestrians. That, along with the paucity of public transport, makes for a vicious circle against the sustainable choice. It will also increase pollution.
Garden Space

We do not suggest there should be no private gardens in the new developments, but neither is
it useful to insist on gardens throughout. It is perfectly possible to incorporate garden space at up to 50 dph, alongside a smaller proportion at the lower density. Were a choice of some flats and maisonettes included in a mixed development, these may well be at 100 dph. Altogether, a brief for a more diverse range of accommodation within varied layouts could provide a much less sprawling development. This would take less road space, meet varied housing needs, offer more sustainable transport options, and could more realistically provide the crucial element of affordability. It can be set alongside green wedges, allotments, etc as well as leaving more real countryside.

Finally, regarding the WDC "Garden Suburbs" prospectus I attach our response from last year. We indicated a series of points on which we say this is inadequate as a policy document and in parts misleading. It often confuses green pictures with genuinely sustainable solutions to the District's housing needs.

In this connection, we have looked at the WDC website commentary on 2012 responses to the POs. In relation to low density sprawl it states :-

"A balance needs to be struck between land-take and the quality of design"

We are surprised at this suggestion of a false conflict: quality of design resides in meeting the needs of a situation with skilled, well tailored solutions.

1 & 2 Introduction / Consultation Process
Right now the District is in an uncomfortable position, with limited powers to exercise priorities, before a new Local Plan is in place. Progress towards that Plan is crucial but the Plan will be of little benefit unless it sets clear and specific criteria for shaping the District's development. This statement of the obvious is made because we seek firmer guidelines for development within the Plan period.
The Leamington Society has previously made strong representations about PO10: Built Environment and we note that in the current Strategic Vision text there is more than one reference to "Garden towns, suburbs and villages". We therefore include this theme in our response (and did indeed 'phone to consult one of your officers on this point).
3 Strategic Vision

3.5 SOCIAL
Of the four bullet points, we particularly endorse point 2 :-
"Providing for diversity, including affordable homes, homes for the elderly and vulnerable and other specialised needs"
But the context of "diversity" should include specific reference to a wide range of dwellings to meet varied lifetime circumstances - beyond the limited special categories identified here.
We pick up this theme below, detailing our concern about the character of the suburban housing developments currently anticipated.
4 Housing
Formulating a core strategy in relation to housing provision is proving controversial. The headline feature of the revised strategy is to plan for very large suburban extensions to the south of Leamington and Warwick. It is evident that this has the potential seriously to aggravate existing traffic problems and will require considerable road works. Such works will be expensive and highly intrusive: they may mitigate the immediate local problem but will not prevent an increase in congestion and pollution around and within the adjoining towns.
There are three elements to this large increase in housing allocation: the total numbers, the proposed locations, and the character and density of the new developments.
THE NUMBERS
We note that half of the potential growth derives from predictions of inward migration to the District. These projections are fraught with uncertainty, as the ONS (Office of National Statistics) warns :-
"The projections are not forecasts and do not take any account of future government policies, changing economic circumstances or the capacity of an area to accommodate the change in population. They provide an indication of the future size and age structures of the population if recent demographic trends are continued. Population projections become increasingly uncertain the further they are carried forward, and particularly so for smaller geographic areas."
We have underlined the ONS phrase about capacity. There is a danger that the Local Plan confuses supply and demand. Building a lot of extra houses will attract immigrants to occupy them. This might appear to be meeting demand, but the demand is a response to supply and not the other way round.
ONS provide separate figures, for "natural" growth and for migration, only as far ahead as 2021. Beyond that there is simply an aggregrate projection, for the years 2021 - 2031. The latest projections are for just over 1000 extra people per year in the District. But the ONS systems round their figures to the nearest 1000, which could include any number between 501-1499. There is therefore a huge potential variation in the total as the annual figures accumulate over the Plan period for Warwick District.
This Society ventures no guesstimate on the projected District numbers, but we do not believe they can honestly be laid down as a certain evidence base for a plan to be set in concrete & brick over the next 15 years and more. Granted that there needs to be a working assumption, the NPPF also demands realism in plan making. In the longer run it is much more likely than not that the outcomes will depart from current projections. Good, realistic planning would provide flexibility to track progress during the plan period and criteria to respond appropriately.
Rather than simply being reactive to individual applications, the Plan should set a hierarchy of priorities towards achieving the District's housing needs, with sequential choice assigned to key objectives.
LOCATION
Warwick District has had difficulty in allocating housing locations for the large numbers anticipated. But even if an overall allocation of sites is set out as in this strategy document, there remains the question of how developers will respond. Understandably they will seek to cherry pick, in search of convenience and maximum profit. Any Plan worth the name will need to prioritise and hence respond to applications on a firm basis.
The mechanisms for setting and achieving effective priorities are no doubt technical. Various carrots and sticks are available but these will surely need to be driven by criteria set out in the Plan.
4.2 We are glad to note significant numbers allocated to urban sites, along with some consolidation from employment areas and a large allowance for windfall sites.
4.3 This starts with WDC preferred options on broad location, but lacks any emphasis on"Brownfield" sites.
We believe the plan needs a stated priority to re-use such land, driven by beneficial conditions as necessary. (See also NPPF para 17 Core Planning Principles, bullet point 8)
This group of POs ends with a bullet point on rural areas, focussing on larger villages We believe this is an appropriate allocation, to concentrate on villages which can best sustain local schools, shops and other services. This should encourage a younger rural population to stay. Also inevitably some migrants into Warwick District will choose a village location and they can best be accommodated in this way.
CHARACTER of new HOUSING DEVELOPMENTS
Given the total numbers, a key element of their location is the land requirement. In arriving at this far too little attention is given to the character of the proposed developments. If Warwick and Leamington had been built at the low, suburban densities envisaged under the plan strategy, they would sprawl over a far greater area of the Warwickshire countryside.
But this is not simply a matter of the amount of land needed. It also relates to diversity of housing need, to affordability, and to the viability of public transport.
Affordability
This is almost certainly the most challenging problem in shaping housing policy. The figures in terms of house prices and of market rents are stark. We supported the PO5 for 40% affordable housing in new developments. This is easier said than achieved : the District has to cope with market forces and is a small local cog driven by the machinery of national government.
5.1.4 "Provide 40% . . The nature of this affordable housing should be agreed with the Council as part of any planning applications"
This vague aspirational statement offers no guidance for negotiating such an agreement, no hint of the means to this end. Can this be a robust or reliable basis on which WDC will resist developer pressure to dilute or claim grounds for avoiding the 40% requirement ?
Affordability at 40 % will surely be dependent on design (not merely on financial engineering) and we doubt very much that this policy can be sustained without firmer guidance, perhaps through Design Codes (NPPF para 59).
Diversity
There is brief reference to size & number of bedrooms related to the SHMA and also mention of older people, (plus students and HIMOs,which are not required). But this seriously fails to address the diversity of varying accommodation requirements over modern lifetimes & social choices; it also entirely ignores the potential for an imaginative range of layout and architecture in addition to rows of houses and lawns.
This is not to denigrate a traditional house and a garden as a common choice of family property but it is simply unrealistic to assume that throughout our typically long and varied lives we are all or mostly living in unchanging families of parents with young children. Moreover that choice / assumption carries with it serious environmental and cost consequences. It appears that developers are most comfortable with this traditional layout. But the function of a local Plan is not simply to align with the "low hanging fruit" most attractive to developers: otherwise there would be no point in a Plan, just leave it all to the market.
We say that the District Plan should give a much stronger lead in challenging developers to come up with more ambitious and diverse designs for varied needs, including affordability.
Transport & Sustainability
The effectiveness of the WCC traffic mitigation proposals, as well as their potential to degrade the local environment, is a matter of argument. But the prime question should be : what is it about these housing proposals that causes such serious traffic consequences ?
It is inevitable that large additional developments - of housing along with employment and community needs - will give rise to a substantial increase in traffic. It is also true that those living in these new developments will own and use motor cars for much personal travel. But it is not inevitable that all of them will do so or that they should have no other options. Some may not be able to drive, some may not have individual use of a car. If housing is to include 40% affordable, then for many household budgets the cost of motoring and especially of multiple car ownership will present hard choices. That is without considering the sheer hassle of daily congestion, parking at destinations, and other considerations in making a personal choice to walk, cycle or use public transport.
3.4 Says that the strategy seeks :-
"Low carbon environmental sustainability" & "Provide for the appropriate & necessary transport "
NPPF para 7 sets out the three dimensions of sustainability, including the third, environmental role
para 17 lists Core planning principles including :-
* "Contribute to conserving . . the natural environment and reducing pollution"
* "Actively manage patterns of growth to make the fullest possible use of public transport , walking and cycling . . ."
5.1.3 Densities
WDC refers to the Garden Towns, Villages & Suburbs Prospectus with Densities of 30-35 dph (dwellings per hectare) or 25-30 dph at the edge.
An undeniable outcome of such densities is to bias transport options overwhelmingly towards use of the car for the vast majority of journeys. It is this feature of your southern housing strategy which aggravates the potential traffic congestion in and around Warwick & Leamington.
This feature is directly in conflict with your own stated Strategic Vision at 3.4
It also is in conflict with the NPPF : Environmental dimension of Sustainable Development
It does not require technical analysis to understand the general point that low density suburban layout is inimical to efficient and economic public transport links. But professional analysis provides good evidence that densities of the order 50 dph and more are the benchmark for viable public transport within 10 minutes walk of each home.
While cycle ways and footpaths may be provided, the very intensity of motor traffic allied to big highway formations (mitigation) will seriously deter cyclists and pedestrians. That, along with the paucity of public transport, makes for a vicious circle against the sustainable choice. It will also increase pollution.
Garden Space

We do not suggest there should be no private gardens in the new developments, but neither is
it useful to insist on gardens throughout. It is perfectly possible to incorporate garden space at up to 50 dph, alongside a smaller proportion at the lower density. Were a choice of some flats and maisonettes included in a mixed development, these may well be at 100 dph. Altogether, a brief for a more diverse range of accommodation within varied layouts could provide a much less sprawling development. This would take less road space, meet varied housing needs, offer more sustainable transport options, and could more realistically provide the crucial element of affordability. It can be set alongside green wedges, allotments, etc as well as leaving more real countryside.

Finally, regarding the WDC "Garden Suburbs" prospectus I attach our response from last year. We indicated a series of points on which we say this is inadequate as a policy document and in parts misleading. It often confuses green pictures with genuinely sustainable solutions to the District's housing needs.

In this connection, we have looked at the WDC website commentary on 2012 responses to the POs. In relation to low density sprawl it states :-

"A balance needs to be struck between land-take and the quality of design"

We are surprised at this suggestion of a false conflict: quality of design resides in meeting the needs of a situation with skilled, well tailored solutions.