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I write to register my strong objection to the Preferred Options Plan currently in
Community Consultation.
There are three major areas of required process in which Warwick District Council
and its executive need to offer significant improvement:
1 The Preferred Options Plan includes Greenbelt but offers no "very
speCial circumstances" as required in the National Planning Policy
Framework. WOe's apparent reason of "nowhere else to go" is
insufficient and made invalid by their own recent identification of
development land in the Core Strategy 2009.
2 The Preferred Options Plan has not been produced as an evidence
based planning document, despite repeated statements by WDC and
its officers that it has been. Councillor Doody on 16th July at Old
Milverton Parish Council meeting stated clearly that the housing target
figure was "the minimum we could get away with".
3 The Preferred Options Plan does not offer the community any options.
To date the consultative process has shown little listening by WDC and
its officers, and much pressure by them on the community to accept it
as it is. It is unacceptable in our democracy to have the community
consultation process so poorly executed, run apparently only to
achieve a pre-agreed result and therefore only to a level of "going
through the motions."
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 WOe'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, thus proving the special
circumstances put forward by WDC are wrong. WOe'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 populations 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 fine agricultural countryside.
3 The Northern Relief Road is not required (budget c f28m) 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 from the jobs, shopping and economic 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 ie about one person per home.
In summary, the Preferred Options Plan 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.