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Publication Draft
DS6 Level of Housing Growth
Representation ID: 66205
Received: 25/06/2014
Respondent: Protect Lillington Green Belt [Petition]
Number of people: 555
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy DS7 provides for 12860 homes this is not in line with ONS statistics that show a population growth of 14000 over the plan period to 2029. In accordance with the ONS occupancy rates only 6008 homes are required, however Warwick District is working on a rate that predicts a population rise of 19,290. If 12860 homes are built and the occupancy rate applied by Warwick DC is applied we will endure a population rise of 29,963 (a 21.5% increase) which is unsustainable.
See attached.
Object
Publication Draft
H04 Red House Farm
Representation ID: 66849
Received: 25/06/2014
Respondent: Protect Lillington Green Belt [Petition]
Number of people: 555
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Red House Farm allocation should be revisited as it is unsound . The following matters are all causes of concern relating to its current inclusion in the Plan.
- Policy DS11 (H04) fails to mention that Red House Farm is actually greenbelt and calls it "green-field". This is highly misleading and would have misled anyone considering this policy in isolation.
- H04 is contrary to NPPF para's 73 and 74 as H04 contains the riding schools grazing fields. The riding school is a valuable recreational asset that also provides employment opportunities. The plan makes no provisions for the replacement of this facility.
- H04 is contrary to the purposes of including land in the green belt as it will not "safeguard the countryside from encroachment". This land is also of valuable agricultural quality and should be preserved for food security reasons.
- H04 is contrary to the NPPF (paragraph 80) as no specific consideration has been given to the use of brownfield sites elsewhere. Sites in Lillington that should be considered include the Old Round Oak school and the URC on the Cubbington Road (both of which are closer to the shops etc. than Red House Farm).
- The Council has not demonstrated the "exceptional circumstances" and does not make a coherent or sound argument for the removal of this land from the green belt. The owners willingness to release the land is not "exceptional".
- The intended re-location of the green belt boundary is flawed as it has no physical features to reinforce this line. Therefore it could not be considered a permanent boundary. There is no indication that if this new boundary were put in place that it would not be subject to change at the end of the next plan period.
- The District Council has not given any consideration or weight to the fact that this proposal will damage the remaining green belt(its openness and permanence would be compromised).
- A portion of the area include in allocation H04 was not included in the green belt study.
-The area at Red House Farm is in an area of tranquillity and should be defended as such . The Local Plan fails in its obligation to identify and defend such areas.
- The consultation on the allocation/ plan has been inadequate, the terminology for the allocation is also mis-leading , it should have been called Campion Hills for local people to recognise it properly.
- The allocation is founded on incomplete studies. Full wildlife assessments have not been conducted . Some 'red-list' species are present and have legal protection.
- It is stated that this allocation will support the regeneration of Lillington. It is suggested that Lillington is not as badly deprived as argued and that to use this as a justification for the allocation of so many houses is wrong/ unsound. Much of Lillington does not require 'regeneration' as it is perfectly acceptable as it already is.
See attached.
Object
Publication Draft
DS18 Regeneration of Lillington
Representation ID: 66850
Received: 25/06/2014
Respondent: Protect Lillington Green Belt [Petition]
Number of people: 555
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
- It is not clear what is meant by Lillington Local Shopping Centre in the policy, does the policy mean Crown Way Shops??.If it means the demolition of existing perfectly good buildings then the policy should say so clearly and then public opinion can be sought properly.
- DS18 contains inaccuracies, it is contended that Lillington is not as deprived as set out in the policy justification.
- The proposed regeneration strategy has not been tested to see if it is economically viable / deliverable.
- If "reviewing the existing services" means demolishing the current public services / facilities this does not represent good use of funds as many of the assets are perfectly good enough as they are.
- policy DS18 may embrace very substantial changes to Lillington that are not justified and have not been tested to ensure that they are viable. This makes the plan uncertain and unsound. To enhance conditions/ opportunities in the area the Council needs to identify and target funding. The demolition and re-building of existing facilities does not represent good value and is unnecessary as most services are already located / represented here.
- The policy seems by default to suggest the re-development of Crown Way shops and / or the use of the Mason Avenue public open space for new development. The policy is difficult for the public to understand / interpret and therefore should be made clearer so that meaningful and proper consultation can take place.
See attached.
Object
Publication Draft
DS19 Green Belt
Representation ID: 66851
Received: 25/06/2014
Respondent: Protect Lillington Green Belt [Petition]
Number of people: 555
Legally compliant? No
Sound? Not specified
Duty to co-operate? Not specified
-DS19 says that changes to Green Belt boundaries within the proposed plan are in accordance with the NPPF , in the case of H04 (Red House Farm ) this is not true.
-H04 is contrary to NPPF para's 73 and 74 as H04 contains the riding schools grazing fields. The riding school is a valuable recreational asset that also provides employment opportunities. The plan makes no provisions for the replacement of this facility.
- H04 is contrary to the purposes of including land in the green belt as it will not "safeguard the countryside from encroachment".
- H04 is contrary to the NPPF (paragraph 80) as no specific consideration has been given to the use of brownfield sites elsewhere. Sites in Lillington that should be considered include the Old Round Oak school and the URC on the Cubbington Road (both of which are closer to the shops etc. than Red House Farm).
- The Council has not demonstrated the "exceptional circumstances" and does not make a coherent or sound argument for the removal of this land from the green belt. The owners willingness to release the land is not "exceptional".
- The intended re-location of the green belt boundary is flawed as it has no physical features to reinforce this line. Therefore it could not be considered a permanent boundary. There is no indication that if this new boundary were put in place that it would not be subject to change at the end of the next plan period.
- The District Council has not given any consideration or weight to the fact that this proposal will damage the remaining green belt(its openness and permanence would be compromised).
- A portion of the area include in allocation H04 was not included in the green belt study.
See attached.