Proposed Modifications January 2016

Object

Representation ID: 68986

Received: 22/04/2016

Respondent: CPRE WARWICKSHIRE

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The updated SHMA has a large number of defects which make its conclusions seriously flawed. At best the resultant Objectively Assessed Need is subject to great uncertainty; at worst it is not credible at all. yet the Local Authorities in the HMA have not done any critical analysis of the report and have accepted its findings in their MOU. inflexible approach is certain to be found wanting as the implementation of the plan unfolds. Meanwhile a great deal of damage will have been done. The position is even more serious because the modification to policy DS20 opens the door for even further housing development in future to meet unspecified housing needs in other areas.
Coventry's inability to meet it housing need results in proposed housing provision of 18,640 over the full twenty year period to 2031, which is over 55% higher than its own OAN. yet the plan does not explain why Coventry can't meet their OAN; how the redistribution has been arrived at. Nor does it take account of GB and other constraints or the wider effects of transferring need.

The Warwick Local Plan is therefore fundamentally unsound, quite apart from its unquestioning reliance on a deeply flawed Strategic Housing Market Assessment. The approach taken is, quite simply, indefensible.

The level of housing proposed (932dpa) is unrealistic.

the over provision will have a range unintended consequences:
-green field sites will be developed rather the brownfield sites
-vacancy rates will accelerate
-increased longer-distance commuting and lead to greater car dependency
-higher service and infrastructure costs
-destructive of the housing opportunities available to newer, younger and less well-off households
-Very substantial areas of Green Belt will be lost
-inhibits necessary adaptations to new problems and unforeseen opportunities

The plan fails to give sufficient weight to national policy in that:
-the presumption in favour of sustainable development does not apply in the Green Belt
-need for housing will rarely be sufficient to constitute the very special circumstances required for inappropriate development in the Green Belt

Object

Representation ID: 70047

Received: 22/04/2016

Respondent: CPRE WARWICKSHIRE

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The plan gives little consideration to the density of new housing development or whether intensification of use of the existing housing stock could be achieved without loss of quality in the urban environment. On most development sites, a density of 35 dwellings per hectare has been uncritically adopted, ignoring the variability between sites and their settings and the potential for higher density. By leaving this vital issue unconsidered, it fails to provide adequate justification for the link between the vast quantum of new housing development proposed and the huge land area involved.

Object

Representation ID: 70052

Received: 22/04/2016

Respondent: CPRE WARWICKSHIRE

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

In order to comply with the key characteristics and purposes of the Green Belt, the additional housing proposals on land designated as Green Belt should be the proposed location of housing should be deleted. In particular, the addition of greenfield sites on the southern edge of Coventry would conflict with the purposes of the Green Belt south of Coventry and would cause great harm. Harm would be magnified when cumulative change is properly assessed: the combination of the unjustified sub-regional employment site (Policy DS16) and the excessive housing proposals would devastate the Green Belt south of Coventry, extending the sprawl of Coventry around Baginton towards the villages of Stoneleigh and Bubbenhall which are of historic importance, demonstrated by their being Conservation Areas

The cumulative impact on roads in the area would also be unacceptable. There is no evidence that mooted (Ref Mod 20) road improvements are viable and would resolve the issues.

Object

Representation ID: 70053

Received: 22/04/2016

Respondent: CPRE WARWICKSHIRE

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The changes now proposed to the Green Belt represent a very substantial departure from previous plan proposals. This adds greatly to our concerns, as previously submitted, about the impact on the Green Belt. The proposed new and amended housing applications amount to an additional 500 hectares of Green Belt land to be taken in addition to earlier proposed removals such as the proposed removal of 124 hectares of Green Belt for the proposed Sub-Regional Employment Site (Policy DS16). Even more land is proposed for removal through policies DS NEW1, DS NEW2 and DS NEW4. The cumulative impact of this excessive development in the Green Belt would be immense and is not justified.
The evidence from the JGBS 2015 are ignored. The Joint Green Belt Study assessed parcels of land for their performance in terms of the national policy, specifically rating them against the five purposes defined in the NPPF. These parcels were also grouped into broad areas which were assessed for their strategic Green Belt designation. The proposed sub-regional employment site covers parcel C10 and the proposed King's Hill housing site covers parcel C14, all within Broad Area 3. Broad Area 3 is assessed as making a considerable contribution to all the purposes of the Green Belt . C10 and C14 are both rated as important in green belt terms fulfilling several of the purposes. The JGBS notes "there remain some significant areas of previously used land in the urban areas". Development in the Green Belt is excessive and is not justified, particularly when the chosen sites are some of the most sensitive. . There is no evidence that these sites, driven in part by excessive demands arising outside Warwick District, have been selected as the best available after a top-down sustainability assessment for the whole Coventry and Warwickshire Local Enterprise Partnership area and Strategic Housing Market area. Brownfield sites and other sites outside the Green Belt are suitable alternatives.

Public consultation on these proposals has been constrained solely to the issues of soundness. There has been no adequate public consultation on these key proposals at a stage when the Council was open to considering changes to its proposals. The consultation process has not allowed effective engagement of interested parties. This process is seriously flawed and does not comply with the necessary procedures for preparation of a Local Plan. Lack of adequate consultation renders the plan legally non-compliant.

Object

Representation ID: 70054

Received: 22/04/2016

Respondent: CPRE WARWICKSHIRE

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The National Planning Policy Framework ('NPPF') requires plans to take into account broader policies and explicitly excludes Green Belt from its presumption in favour of sustainable development. Unmet needs from neighbouring authorities should be met 'where it is reasonable to do so and consistent with achieving sustainable development' (NPPF paragraph 182). Green Belt is explicitly cited as a policy indicating that there can be exception from the need for plans to meet objectively assessed needs. National policy is clear that unmet demand is unlikely to outweigh harm to the Green Belt to constitute the very special circumstances needed to justify inappropriate development in the Green Belt. The cumulative impact of meeting in full sub-regional needs for both housing (Policy DS NEW1) and employment (DS16 Sub-Regional Employment Site) would be very harmful. These demands are excessive and not justified. Coventry living beyond its means is not sustainable and Warwick District should not have to pay the consequent price of Coventry's excessive demands to the sever detriment and amenity loss of its own residents and businesses. The proposed plans are unsound and unsustainable.

Object

Representation ID: 70055

Received: 22/04/2016

Respondent: CPRE WARWICKSHIRE

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The proposed policy on Spatial Strategy (Ref Mod 3) claims to provide a clear strategic basis for proposed site allocations. Proposing Green Belt locations for development on the edge of built-up areas is contrary to established Green Belt policies. A key purpose of the Green Belt is to curb urban sprawl but the proposed policies include 'urban extension' which is another way of saying urban sprawl. The Sustainability Appraisal Addendum recognises that proposed urban extensions south of Coventry would have cumulative and potentially major negative effects on landscape, visual amenity and openness through loss of Green Belt and that these would remain even after so-called mitigation. The proposed policy must be modified to apply only to areas outside the Green Belt.

Object

Representation ID: 70056

Received: 22/04/2016

Respondent: CPRE WARWICKSHIRE

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Green belt release in this location is not justified. Need for housing will rarely be sufficient to constitute the very special circumstances required for inappropriate development in the Green Belt. The DCLG Policy Statement of October 2014 states, 'The local planning authority should prepare a strategic housing land availability assessment to establish realistic assumptions about the availability....of land...and take account of any constraints such as green belt which indicate that development should be restricted and which may restrain the ability of an authority to meet its need'. Development in this location would be a long swathe of urban development which would close the Green Belt gap which currently exists between the built-up area of the town and the A46. On rising ground, the development would be very visible from countryside to the east near Ashow and the National Agricultural Centre. It would undermine the rural character of the Avon Valley and the setting of the Gade I Stoneleigh Abbey and its eighteenth-century landscaped park (registered by English Heritage) by extending Kenilworth's urban area up to the A46, which is near to the western boundary of the parkland. This would halve the distance between the urban area and the parkland to no more than 250 metres.

Object

Representation ID: 70057

Received: 22/04/2016

Respondent: CPRE WARWICKSHIRE

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

These proposals would remove land from the Green Belt without justification, for future housing. . Need for housing will rarely be sufficient to constitute the very special circumstances required for inappropriate development in the Green Belt. The exceptional circumstances for removing both these areas of open agricultural land from the Green Belt have not been demonstrated. To develop these areas would undermine the purposes of the Green belt. DS NEW2 (S2) at Old Milverton would reduce the separation between Leamington Spa and Kenilworth by up to 0.7 km and destroy the setting of Milverton village, a rare rural settlement in the gape between the two towns

Object

Representation ID: 70058

Received: 22/04/2016

Respondent: CPRE WARWICKSHIRE

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Need for housing will rarely be sufficient to constitute the very special circumstances required for inappropriate development in the Green Belt.
North of Milverton (H44) would constitute a substantial northward extension of Leamington Spa into the Green Belt, bringing it significantly closer to coalescence with Kenilworth. The Kenilworth Road is an important entry to the historic town and the Conservation Area extends to the built-up area boundary here. The safeguarding of a large area of additional land to the west for future development (DS New 2) makes the present proposal just the thin end of the wedge. The dualling of the A452 is not feasible and may not be affordable. The proposed H44 Milverton housing area is about 21 hectares in extent. (No area measurement is given in the Plan Modifications.) The land south of Edgehill Drive and west of the Stratford Road is very similar in extent, about 20 ha. However after more than a decade Tournament Fields remains largely undeveloped. The reason for the lack of developer interest is that the price required for the Tournament Fields land to achieve a return for the current land-holder is higher than could be justified by a developer of the land for employment uses. Other less expensive locations are available in the sub-region for buildings for employment use. The only way that Tournament Fields can be developed viably is for housing.

Object

Representation ID: 70059

Received: 22/04/2016

Respondent: CPRE WARWICKSHIRE

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

This location is for housing in the Green Belt. This is not justified and not in accordance with national planning policy. Need for housing will rarely be sufficient to constitute the very special circumstances required for inappropriate development in the Green Belt. The H50 proposals at Cubbington would be a substantial projection of development into pleasant open countryside east of the village.