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I write to register my strong objection to the preferred Options Plan currently in Community Consultation.
There are in my opinion six areas of major planning weakness in the Preferred Options Plan, resulting in it being a meagre and insufficient document which does not propose any thoroughly supported substance.
1. The fundamental aim of Greenbelt policy in the Government's National Planning Policy Framework is to keep land permanently open to prevent urban sprawl. The 'very special circumstances' required by the NPPF to use Greenbelt land have not been stated in WDC's Preferred Options Plan. The NPPF requires the benefit of development to outweigh the harm caused to the Greenbelt. Where is this case? The previous Plan (2009 Core Strategy) is direct evidence that there are alternative areas for development, this proving the special circumstances put forward by WDC are wrong. WDC's argument that the land previously identified to the south of Leamington is less profitable to developers is not a 'very special circumstance' to permit unnecessary development in the Greenbelt.
2. The WDC study assigns high Greenbelt value to the land at Old Milverton and Blackdown, but this is ignored in the Preferred Options plan. These areas have high Amenity and Recreation use as green lungs for the population of Leamington, Warwick, Kenilworth and further afield in Warwick District and should not be sacrificed for the poorly defined 'green wedge' approach. Managed parkland is a very poor substitute for access to find agricultural countryside.
3. The Northern Relief Road is not required (budget c £28m) since traffic flows tend to be north to south. It is proposed across a flood plain with the associated high cost, violates the Avon nature corridor, and will if permitted provide a natural barrier to encourage further encroachment of the Greenbelt., coalescence of towns, and detract from the picturesque northern entry to Leamington and the southern entry to Kenilworth.. If built it will provide the residents of 3000 houses a quick route to get away form the jobs, shopping and econonic well being of Leamington and Kenilworth. The existing road network in south Leamington could be upgraded at considerably lower cost to meet the needs of development on the identified land there.
4. The out of town retail operations proposed are an inappropriate blow to the independent retailers in Leamington, Kenilworth and Warwick who make the area attractive to live in.
5. The use of a significant quantity of high quality agricultural land which is currently Greenbelt, is inappropriate in the world of rising food prices and a requirement to increase the green credentials of the economy.
6. There is a lack of clarity, a paucity of evidence and self inconsistency in the housing, jobs and homes model used for the Preferred Options Plan. The 1400 homes added as a buffer by WDC on top of the modelling are not evidence based. If they are removed, there is no need to include the land at Old Milverton and Blackdown. I would expect that a properly drawn plan should be numerically consistent, and not include a quantity of homes which appears to relate to a similar population increase i.e. about one person per home.
In summary, the Preferred Options lan is a very poor plan. It neither has the support of the community, nor has it adequate compliance to the National Planning Policy Framework. I commend the rapid creation of a suitably sound plan which has significant community support, to provide a relevant guide for the next decades of Warwick District.
To do this well, the current consultative process must be seen to be working, both in the actions of WDC at the conclusion of the process, and in the revised Plan which should emerge.