BASE HEADER

My objections are on three main grounds. Firstly, that the preferred options are based on fallacious reasoning and hypothetical statistical models. Secondly, that they will result in irreversible damage to the Green belt. Thirdly that they are grossly undemocratic and not in keeping with the spirit of the Government`s National Policy Planning Framework.
Fallacious reasoning
1. They use a statistical model prepared by a commercial company, Cambridge Econometrics in conjunction with IER at Warwick University, which uses data given by the District Council, although the company themselves admit there are few official figures for measuring the factors they input. The public has not seen that data, and it is hard to see why the District Council expects there to be so many jobs suddenly appearing in this area. Is their reasoning that if you build houses, the jobs will follow?
2. In PO1they claim their preferred level of growth between 2011 and 2029 is 10,000 dwellings ie an average of 600 p/a. Even if we were to accept this figure then they would have an overprovision of houses by 3,710 if they develop all the sites they have proposed. (ref 5.18 the SHLAA "identifies potentially suitable sites within and on the edge of built up areas. Taken together, these sites would be able to accommodate an estimated 11,410 new homes. In addition, it is estimated that further windfall sites could accommodate around 2,300 new homes.")
3. There is a sudden jump from the scenarios which were presented to the public to an ad hoc rejection of the first scenario on the grounds that "This level of housing would lead to an overall reduction in the number of jobs in the district (or increases in out-commuting)" (ref 5.14) and Projection 3 Employment growth with continued commuting is rejected because it doesn`t allow for a balancing new homes and jobs. You cannot insist that employers only take on staff who live locally any more than you can insist that people only take the jobs that are available in their area! They make the same mistake when providing employment land among the Blackdown development on the grounds that there is a `deficit` there.
4. The lowest projection in Table 5.2 is trend based, but there is no particular reason to believe that the increase in net migration of recent years will continue. In fact if these proposals go ahead it is likely that the area will no longer be attractive to newcomers and many established residents will move away. The other projections are based on the hypothetical model -the West Midlands Integrated Policy Model already mentioned. Paragraph 5.22 admits that the model`s projection "is likely to be optimistic since it was carried out in 2010 and forecast an increase in employment from 2011. Bank of England GDP projections in August 2010 anticipated continued, albeit slow, growth from a low point in February 2009. However, ONS data has since revealed that the rate of increase of GDP has been falling since mid-2010 and has yet to show signs of recovery."
5. Point 5.23 says "housing would need to be met largely on strategic Greenfield sites on the edge of the built up areas. This would be necessary in order to deliver the required infrastructure." This seems an instance of lifting themselves up by their own bootstraps- such massive infrastructure changes would not be necessary with lower levels of growth.
Irreversible Damage to the Greenbelt
The NFPP in `Protecting the Green Belt` states (ref para 8.8) "When considering any planning application, Local Authorities should ensure that substantial weight is given to any harm to the Green Belt. `Very special circumstances` will not exist unless the potential harm to the Green Belt is clearly outweighed by other considerations."
Of the five purposes served by Green Belt outlined in the NFPP, the proposals to alter Green Belt boundaries will cover the first two, but not the last three.
1. The third principle - to assist in safeguarding the countryside from encroachment- will not be addressed. The Council claims there are clear boundaries but in the case of the Blackdown development, for instance, the boundaries would include the Westhill Rd and the Stoneleigh Rd. At the moment there is a clearer boundary- ie the A445, a major road from the M1 and Rugby into Leamington, yet if the building goes ahead this boundary will have proved insufficient to prevent encroachment onto the Green Belt, so it is unlikely that the minor roads will fare any better. That District Council have their eye on further encroachments of the Green Belt is also revealed in 8.33 in a discussion of Coventry Gateway, where they quibble about the proposed location and want to `explore the case for releasing land in the Green Belt.` The Coventry Gateway would be a huge industrial complex, yet they want to destroy Green Belt for it, presumably because they are competing with Coventry City council.

2. The changes also will not address the fourth principle- to preserve the setting and special character of the historic towns of Kenilworth, Leamington and Warwick. The new developments described as `garden suburbs` will be clones of those in other overdeveloped towns. How can they `ensure viability and deliverablity` (para 173 NPPF) and expect to provide 40% affordable housing but architecturally innovative buildings (as recommended in the NPPF) and at the same time `provide competitive returns to a willing landowner and willing developer`? In his ministerial foreword to the NPPF, Greg Clark says, "Our standards of design can be so much higher. We are a nation renowned worldwide for creative excellence, yet, at home, confidence in development itself has been eroded by the too frequent experience of mediocrity." The District Council`s plans for the Green Belt are set to repeat the experience of mediocrity again.

3. Nor will they address the fifth principle-to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Although the Council mentions brown field sites it does not mention any sites arising from Para 51 "local Authorities should identify and bring back into residential use empty housing and buildings and where appropriate acquire properties under compulsory purchase orders". Surely this should be adhered to in an island as small and densely populated as ours?

4. The Council`s justification for using Green Belt land 7.15 claims "the Joint Green Belt Study carried out an assessment of the Green Belt around the towns and on the edge of Coventry. The findings showed that there were variations in the quality of land in the Green Belt and therefore some areas around the towns may be considered for development and therefore, removed from the Green Belt". This is extremely misleading. The remit of the Joint Green Belt Study was to rank the areas, any ranking involves some areas ranking at the bottom, but this does not mean they are not good quality areas and it does not imply they are more suitable for development than areas outside the Green Belt. The NPPF states "Plans should allocate land with the least environmental or amenity value" not least value in competition with other areas in the Green Belt.

5. The Council`s rejection of other proposals (ref 7.18- dispersing development on small/medium sites) claims it `would be impractical in terms of the number of sites that would have to be identified` `Further, this pattern of development would make it difficult to make fullest use of public transport, walking and cycling`. These are allegations with no evidence to back them up.

6. Similarly 7.19, while admitting that `the sustainability appraisal of the options showed that the option for focusing development outside the Green Belt had clear advantages associated with the provision of sustainable transport and reducing the need to travel. However, there would be significant impacts on the historic and natural environment due to such a high concentration of development to the south of the towns due to increased cross-town traffic.` What is the evidence?

7. On the other hand the proposal to develop the North Leamington Relief Road from the A46 to the Sandy Lane A445 roundabout will funnel yet more traffic onto the Lillington Rd into town- a road which is very congested already. The `virtual P&R carpark` and non-bespoke 2- stage buses pay lip-service to looking for a solution, but looking at it realistically, most motorists are not going to get out of their comfortable cars, wait in the rain for buses that don`t go exactly where they work, at times that don`t suit them. There is already a very good bus service from the Blackdown area but the buses are virtually always empty.

8. Point 112 of the NPPF states that "Local Planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land." The fields proposed for development in Blackdown and Old Milverton are extremely fertile and yield excellent harvests year after year. The NPPF says that councils must also look at the bigger picture and future food shortages are one of the biggest.

9. Although the District Council have copied sections from the NPPF about the Green Infrastructure into their Local Plan, they show little environmental vision. For instance, there is no mention of developing renewable energy (para 17 Core Planning Principles NPPF).

Lack of democracy
In his ministerial foreword to the NPPF Greg Clark says,
"Planning must be a creative exercise in finding ways to enhance and improve the places in which we live our lives.
This should be a collective enterprise. Yet, in recent years, planning has tended to exclude, rather than include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them."
This is an apt description of what continues to happen in Warwick District. The consultative period is very brief, and hardly any of the people living in the Blackdown area had even heard about the proposals. It would have been simple to let everyone know, in the same way that we are kept informed about waste collection plans, yet the District Council chose not to do this.
In March 2011The District Council consulted the public in `Helping Shape the District`. They have rejected the growth levels wanted by 90% of those consulted and have set their sights on very much higher growth than the majority voted for. Point 69 of the NPPF says, "The planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Local planning authorities should create a shared vision with communities of the residential environment."
Yet in para7.14 the District Council says `The "Helping Shape the District" consultation exercise carried out last year highlighted much concern about the levels of development which might be required to meet the District's housing needs and the impact this would have on the character and setting of the towns. Many felt that increasing sprawl around the existing towns would damage the rural setting of the towns to the detriment of both their economies and their environment. The Council will require new development to follow the emerging garden suburbs principles in order to overcome this loss of rural characterand facilities they wish to see. ` The Council fails to see that the `garden suburbs` would not in the least overcome the problem.
Again, para 155 of the NPPF says, "Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged so that Local Plans, as far as possible, reflect a collective vision and set of agreed priorities."
It is time that the District Council took these principles onboard.