Testun llawn:
Submission made on behalf of the Hatton Parish Plan Steering Group.
Overall Strategy
The overriding principle of the National Planning Policy Framework (NPPF) is Sustainable Development. When the previous Core Strategy was being prepared, three sites at Hatton Green, which landowners had put forward for development, were dismissed because the general location was considered to be unsustainable. If the area was considered unsustainable then, how does it suddenly become sustainable and where is the evidence to support this change? Indeed, where is the evidence to suggest that housing spread across the district is the most sustainable form of development?
Table 7.2 show approximately 10% of new housing will be in villages, roughly half of which will be concentrated in five villages along the A4177/B4439 corridor - most of which lack the facilities to support sustainable development. Moreover, this will create a corridor of development that will seriously threaten the integrity of the Green Belt. The A4177 and B4439 are also dangerous roads with bad accident records. Potentially another 400 houses will obviously increase the danger, yet the Plan contains no infrastructure improvements to reduce the risks.
We therefore have serious misgivings about the strategic approach to rural areas.
Local Plan Policy PO4: Distribution of Sites for Housing
We object to the inclusion of Hatton as a Category 2 village. In a recent survey for the Parish Plan, 60% of respondents said they are opposed to more housing. We expect the natural reaction will be to dismiss this as NIMBYism, but there are several sound reasons why residents consider this designation to be inappropriate:
1. Hatton has already contributed more than its fair share of housing to the District, with numbers having increased six-fold in the last 20 years, from 140 to 845 units.
2. The 700 new houses at Hatton Park mean the parish now has two distinct settlements, plus a significant scatter of other houses. We now need time to assimilate the massive impact this change has had and develop a cohesive community.
3. Neither Hatton Park nor Hatton Green has the basic facilities needed to support sustainable growth. Hatton Park has a village hall, small general stores and a reasonable bus service, but all children have to travel to school by bus and there is no bus service to the nearest post office or doctors. Hatton Green has a primary school, but this is already over-subscribed and further expansion would only exacerbate the current traffic problems in the village. Otherwise there is a village hall, but only a skeleton bus service with timings that preclude travelling to work by bus. We do not consider these modest, dispersed facilities sufficient to justify designation as a Category 2 village. They certainly don't measure up to the statement in paragraph 7.34 that "a limited amount of development is directed to those villages with a good range of services and public transport to the towns".
4. If the 700 homes at Hatton Park, with their wide range of types and tenures, cannot meet local needs through natural turnover, then it is highly unlikely that 30-80 extra homes, spread over 15 years, will make any difference. Nor is it likely "to encourage new services" as envisaged in paragraph 7.35.
Notwithstanding the above, we recognise that communities cannot stand still and that further development will be required at some stage to sustain the two existing settlements. Indeed, responses to the Parish Questionnaire show that just over a quarter of residents would favour more starter homes, shared ownership or rented homes. Very few, however, would favour more of the larger homes. The issue is how best to satisfy the residents' views.
We do not believe designation as a Category 2 village, with its subsequent implications for the Green Belt, is the best solution.
Local Plan Policy PO16: Green Belt
The Parish Questionnaire shows virtually 80% of residents to be in favour of retaining the Green Belt as it is, though a quarter consider there could be some review of boundaries.
Paragraph 79 of the NPPF says "the essential characteristics of Green Belts are their openness and their permanence". Paragraph 83 goes on to say "Once established, Green Belt boundaries should only be altered in exceptional circumstances" and that authorities "should have regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period".
Taking these statements together, our interpretation is that Green Belts should be essentially permanent; their boundaries, once established (which is the case in Warwickshire), should only be reviewed in exceptional circumstances; and if boundaries are reviewed they should endure beyond the fifteen years of the Local Plan. We question whether the levels of housing being an proposed for Category 2 villages - an average of two to five a year spread over fifteen years - is sufficient to amount to 'exceptional circumstances'. (If all or most were to be built at once however, e.g. very close to our parish at Haseley Manor, then this might constitute exceptional circumstances, but this would almost certainly lead to pressures to release more land.) Because of this we are very concerned that, if village 'envelopes' are created within the Green Belt, the NPPF requires boundaries to be drawn to accommodate expansion beyond the fifteen year period of the current Plan. Notwithstanding the safeguarding provisions in paragraph 85 of the NPPF, we believe this would expose areas to the threat of premature development, which we know from past experience would be extremely difficult to resist.
We certainly believe that creating 'envelopes' for each of the five proposed Category 1 and 2 villages along the A4177/B4439 corridor would fundamentally threaten the integrity of the Green Belt.
In the case of Hatton, with its two very compact settlements, we believe the interests of its residents would best be served by leaving both villages 'washed over' by the Green Belt, leaving any future development to be dealt with as 'limited infilling' or 'limited affordable housing for community needs' in accordance with the NPPF paragraph 89.
Infrastructure
We are surprised that the Plan contains no proposals for improvements to the A4177 and B4439. Both of these roads are extremely dangerous, with the severity of accidents along the stretches at Hatton almost twice the county average (Warwickshire County Council Traffic Accident Statistics pers comm.). Both roads also carry traffic diverted from the M40 and M42 at times when there are incidents on either motorway.
With potentially up to 400 more houses proposed for the five Category 1 and 2 villages along this corridor, the accident risk can only increase and we believe the Local Plan should make provision for infrastructure improvements to minimise the risks.