BASE HEADER

This is a more complex area but the key factors to be considered relate partly to the above points concerning the inadequacies of the SAF i.e. how can we confident about the overall strategy if the link between individual choice of sites and the overall approach is not transparent? Consequently an objection is made to Policy P03: Broad Locations for Growth and the justification for this set out in paragraphs 7.8 to 7.22.

It is noted that paragraph 7.8 does not refer to the SAF. Does this mean that the individual sites have been tested within a Strategic Environmental Assessment that has informed their selection?

It is also noted that paragraph 7.8 does not make reference to the Landscape Character Assessment (LCA) for land south of Warwick and Leamington (February 2009) commissioned by WDC and prepared by Richard Morrish Associates Ltd. This report is referred to as being part of the Council's evidence base for the consideration of Landscape and Green Belt matters in Local Plan on the Council's website. It is included alongside the 2009 Green Belt Review.
The background section to the LCA states:
1.1 ........... The (Green Belt) study sought to identify land that contributed the least towards the Green Belt and was the least constrained in environmental and physical terms. The data gathered will inform each Council's emerging Core Strategy. Richard Morrish Associates Ltd (Chartered Landscape Architects, and a registered practice of the Landscape Institute) worked with Smith Stuart Reynolds to provide a preliminary landscape assessment of the study areas and to provide an evaluation of the extent to which they contributed towards the planning purposes of Green Belt as set out in PPG2 1.2 The West Midlands Green Belt only extends to areas located north and west of Warwick and Leamington and therefore land south of Warwick and Leamington was not considered in the joint authority Green Belt study.1.3 In December 2008 Richard Morrish Associates (RMA), were appointed to provide a preliminary landscape assessment of land to the south of Warwick and Leamington Spa. The objective was to assess the contribution that these study areas presently make to the existing urban structure of Warwick and Leamington and to evaluate which areas might be considered most important in preserving the character and appearance of the towns in the longer term.


It should be the case therefore that the choice of development locations in Warwick and Leamington has been influenced by the Joint Green Belt Study (January 2009) and the LCA for the Area south of Warwick and Leamington (February 2009), in addition to the other matters set out in paragraphs 7.8 and 7.24. If this is the case specific reference to the LCA should be included within paragraphs 7.8 and 7.24. It is noted that the sole reference to the LCA is at paragraph 10.18 in the context of built environment. If the LCA, has not been utilised for the purposes of identifying preferred locations for development - and hence has been purposefully excluded from paragraphs 7.8 and 7.24 of the Local Plan, then the Council should clarify this, and if necessary correct this oversight.

In terms of specific points in respect of P03: Broad Locations for Growth:

* Objection is made to paragraphs 7.8 to 7.22 for the reason outlined above. * Objection is made to the proposed phasing provision identified in paragraph 7.20. There is no evidence provided by the Council to justify a phasing policy. Indeed, on the one hand the Council express concerns about the ability of strategic sites to deliver with the plan period (paragraph 5.23) and then propose in paragraph 7.20 a phasing policy that is likely to artificially constrain strategic sites from being brought forward in a timely manner. Strategic sites require a significant lead-in time. Major infrastructure works are required involving substantial up-front costs to create developable plots. Schools, community centre, district centre facilities etc may also need to be built at an early stage of the development process. It is not appropriate to impose an arbitrary phasing restriction on their delivery which may simply serve to undermine the viability of a development. Reference to phasing should be deleted from the Local Plan.

* Objection is made to paragraph 7.15. It is considered that the Green Belt Study 2009, by itself, does not provide a sufficiently robust evidence base to demonstrate the very special circumstances that justify the scale of land proposed to be released from the Green Belt to the north of Warwick and Leamington. This objection is related in part to the lack of reference to the LCA in the draft Local Plan assessment of the broad locations for growth in Warwick and Leamington.