Publication Draft

Object

Representation ID: 66142

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

As described in our response to Policy DS16, the addition of an exception for Sub-Regional Employment needs is not justified. The justification is based on the SEP, but both the SEP and the WDC draft plan depend on a "Joint Employment Land Review, March 2014" but this report has not been made available. The evidence base is incomplete and there has been no opportunity for consultation or engagement of interested parties on this evidence.

There is no evidence to establish the justification for a sub-regional employment site being located within Warwick District. There has been no sustainability appraisal of alternative sites showing why the proposed site should be developed instead of existing or potential alternative sites.

Environmental impacts have not been sufficiently taken in to account. This is not consistent with the NPPF.

There is no evidence of exceptional circumstances for green belt release other than that put forward in the Gateway Inquiry. the Plan is unsound because Policy DS16 is not justified and reasonable alternatives to the Gateway have not been considered.

The Policy also conflicts with the rationale for Policy EC1.

Object

Representation ID: 66414

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

As described in our response to Policy DS16, the addition of an exception for Sub-Regional Employment needs is not justified. The justification is based on the SEP, but both the SEP and the WDC draft plan depend on a "Joint Employment Land Review, March 2014" but this report has not been made available. The evidence base is incomplete and there has been no opportunity for consultation or engagement of interested parties on this evidence.

There is no evidence to establish the justification for a sub-regional employment site being located within Warwick District. There has been no sustainability appraisal of alternative sites showing why the proposed site should be developed instead of existing or potential alternative sites.

Environmental impacts have not been sufficiently taken in to account. This is not consistent with the NPPF.

There is no evidence of exceptional circumstances for green belt release other than that put forward in the Gateway Inquiry. the Plan is unsound because Policy DS16 is not justified and reasonable alternatives to the Gateway have not been considered.

The Policy also conflicts with the rationale for Policy EC1.

Changes to Plan:
Delete the exception relating to sub-regional employment

Object

Representation ID: 66540

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The strategy has changed against the siwhes of local people. The previous plan was conservation-minded, but the proposed approach now if for growth with higher levels of employment, population and housing than needed. The New Local Plan is unsound because it does not contain adequate justification for this fundamental change of approach.

Maintaining and enhancing the environment of the district does not appear in the list of five key priorities in paragraph 1.40, yet this is importnat to the charatcer of the District.

It is not clear from the Plan what provision is currently made to meet the housing needs of neighbouring areas. It seems to us that because the Plan assumes substantial continuing in-migration, there is already in effect significant provision for meeting needs originating elsewhere. However Policy DS20 of the Plan is ominous because it envisages even higher housing provision.

Object

Representation ID: 66542

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The strategy has changed against the siwhes of local people. The previous plan was conservation-minded, but the proposed approach now if for growth with higher levels of employment, population and housing than needed. The New Local Plan is unsound because it does not contain adequate justification for this fundamental change of approach.

Maintaining and enhancing the environment of the district does not appear in the list of five key priorities in paragraph 1.40, yet this is importnat to the charatcer of the District.

It is not clear from the Plan what provision is currently made to meet the housing needs of neighbouring areas. It seems to us that because the Plan assumes substantial continuing in-migration, there is already in effect significant provision for meeting needs originating elsewhere. However Policy DS20 of the Plan is ominous because it envisages even higher housing provision.

Object

Representation ID: 66551

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The removal of the land in the vicinity of Coventry airport from the green belt was not included in previous versions of the emerging WDC plan, some of which explicitly argued against such a course of action. There has therefore been no prior (or proper) consultation on this proposed GB change. This makes the proposed policy unsound and unjustified because the consultation process has not allowed effective engagement of interested parties. Lack of adequate consultation renders the plan legally non-compliant.

GB boundaries should only be altered in 'exceptional circumstances'. There is no evidence of exceptional circumstances for the proposed change, making the Plan unsound. WDC proposes that it would review its proposed policy on sub-regional employment site if the SoS rejects the Gateway application. However, if the site has been taken out of the GB meanwhile, this approach would be futile. This could be extremely damaging, leaving the area around Coventry Airport open to piecemeal development and urban sprawl.

Aside from the land at Coventry airport, Removal of land from the Green Belt has not been shown to be justified by 'exceptional circumstances'.
CPRE objects to the removal from the Green Belt of the following locations / sites shown on the proposals map and listed in Policy DS19:
* Red House Farm, Leamington Spa (SE of Cubbington)
* Castle Sixth Form, Rouncil Lane, Kenilworth
* Thickthorn and Southcrest Farm, Kenilworth;
* Land in the vicinity of Coventry Airport (sub-regional employment site)
* University of Warwick; (southern part of area shown)
* Baginton;
* Burton Green;
* Cubbington (H26);
* Hampton Magna (SE of settlement);
* Leek Wootton (whole village proposed for insetting)
* Kingswood (Lapworth).
CPRE also strongly submits that ribbon-development locations which are currently washed-over by Green Belt should not be removed from the Green Belt and 'inset' -Burton Geen and Lapworth. Such areas grew up during the 1920s and 1930s and generally have long gardens and are a single street frontage. If removed from the Green Belt, they would be subject to applications for redevelopment at greater density and the conversion.

Object

Representation ID: 66556

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The 'areas of search for Park & Ride' should be deleted from TR5 and from the Proposals Map. The P&R proposal is not justified and would not be effective. The safeguarding of large areas around Blackdown and Greys Mallory roundabouts, and west of Europa Way, would blight countryside at sensitive locations.

The justification offered is weak. The proposal to safeguard land around Grays Mallory roundabout was included in the previous Local Plan. This was for the then 'SPRINT' park & ride proposal of Warwickshire County Council, which was not found to be justified, and was abandoned. If the land is safeguarded, the area shown should exclude land east of Europa Way.

TR5 should have added to it safeguarding of a northern, town-centre side access to Leamington Spa Railway Station. The area shown on the Proposals Map east of housing allocation H10 (former Avenue Road station and current bus garage site) is not shown as safeguarded for this direct foot access from the town centre. That new access is shown in the Supplementary Planning Guidance adopted for the station area, but there has been no implementation.

Object

Representation ID: 66558

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We welcome the efforts of the District Council in Policy DS4 to prioritise housing development on brownfield sites / Completions and sites with planning permission account for 3,629 dwellings. Small urban sites, consolidation of existing employment sites and the allowance for windfall sites account for a further 3,147 dwellings.

Despite the above, the District Council are proposing to provide almost half the total provision in the form of sites newly allocated in the Plan.

850 would be on the southeast side of Kenilworth in the Green Belt. As noted in other responses, we do not consider that the Plan demonstrates the exceptional circumstances required to remove land from the Green Belt for new allocated housing sites.

Sites on the edge of villages and in the rural area account for a further 763 dwellings. Some of the proposals involve substantial expansion of relatively small settlements and we are particularly concerned about those for Leek Wootton, Kingswood (Lapworth), Bishops Tachbrook, Cubbington, Hampton Magna and Radford Semele.

Object

Representation ID: 66561

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

OAN is not a sound or justified figure. See reps relating to DS6.

Object

Representation ID: 66564

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy H11 as written is sound and is established Policy for Green Belt, as earlier set out in PPG2. It allows new houses in washed-over settlements under very strict controls. These are well set-out in the Policy.

Paragraphs 4.77-4.79 are also sound and in accordance with national Green Belt policy.

The policy makes no reference to the village boundaries identified on the policy map. The boundaries do nothing to assist the implementation of Policy H11 and would be likely to harm it by increasing applications which then need to be refused under the terms of the Policy itself.

The NPPF gives no support to showing 'village infill boundaries' for washed-over settlements in the Green Belt.

Village infill boundaries are shown for some small villages outside the Green Belt. These should also be deleted.

Object

Representation ID: 66574

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Net in-migration fell from a figure of over 2,000 per annum in the years immediately following the millennium to 400 in 2008-9 and net out-migration of 700 in 2009-10. In view of this dramatic change it is not acceptable, as the 2012 SHMAA did, to take the 460 average and simply project it forward over the plan period. There is a real possibility that there will be net out-migration from rather than in-migration to the district over the plan period. The past rate of growth of population and in-migration is unsustainable. the District Council should be planning for a very much lower level of growth in which housing and employment are balanced against environmental objectives.

The SHMAs cannot claim to have been an objective assessment of housing need. The work was commissioned by local authorities and the steering committees were dominated by development interests who have a vested interest in talking up the housing needs figures. Wider interests such as residents' groups and environmental bodies were excluded from the process. WDC have assumed population growth of 17% between 2011 and 2029. This rate of growth would be above that for almost all the SHMA Projection Scenarios, despite the plan period being two years shorter than that of the SHMA. No justification is provided in the Plan for the choice of this figure. Employment forecasts are subject to great uncertainty and cannot be reliably used.

The proposal for 12860 houses is not justified in the text. The Plan is therefore unsound in its provision for housing.

The Plan does jot take account of the latest ONS population projections, which shows a much lower rate of population growth than assumed in the JSHMA. This could suggest a reduction in the housing requirement of about 3700 homes. Further average household has recently stablilised, but the plan assumes continued reductions.

Taking all these factors into account, we consider that the Plan is unsound because its housing provision is based on out-of-date information and on an over-optimistic, inflated view of both employment and population growth prospects.