Testun llawn:
I wholeheartedly agree with the ambition of making WD "a great place to live, work and visit" but I am not convinced that this Local Plan addresses the issues in such a way as to achieve that vision.
I therefore wish to raise my concerns regarding the new local plan. I am extremely conscious of the position WDC finds itself in but am very worried that this solution is driven by an urgent need for a strategy in the face of developer pressure against the backdrop of the NPPF.
1. Assumptions
I am not convinced by the ONS's forecasts for population. There should be a forecast for 2030 and another for 2050. Most economists agree that UK population will start to fall away mid-century.
There are only 4 options presented and each is exclusive of the other; there are no options presented which are simple or complex hybrids. This is narrowing the choice unnecessarily when a hybrid plan may present the best compromise / optimum mix for all.
The options do not fully consider the needs across district or borough boundaries. The RSS Core strategy in 2007-10 looked at the wider picture and sought to find regional, more balanced solutions. By looking at numbers individually by District or Borough, our choice of options is dramatically reduced and does not consider the impacts on surrounding areas. These artificial political and authority boundaries are not considered by business or residents. As a parallel, in the past Fire Services looked only at the provision of service within a County boundary...clearly this is inappropriate when best planning a reactive service, particularly in rural areas, to avoid duplication eg N Warks / Sth Leics.
I see that there is now a Joint SHMA following the intervention of the Planning Inspectorate. Surely a Local Plan cannot be fully considered through consultation until this has met and made broader, more fully fledged proposals that meet the needs of the wider area and so avoiding duplication and ensuring more joined-up thinking? And what is the "new information" that has come to light?
Finally, when the Plan refers to 'Sustainable Communities', what is is meant by this? Very seriously, a definition is required to know what is being spoken of. Does it mean a community feeding itself, travelling within its own confines, providing its own energy and water needs? Please provide.
2 Housing
The primary determinant for the preferred option seems to be to avoid building on the Green Belt even though elsewhere WDC and Coventry CC will allow industrial development on the Green Belt. This is surely not a principle. Whatever guides the decision-making should be consistent and coherent. If one is permissible, then so should the other.
The notion of the primary employment site being planned at Baginton / Coventry Airport whilst 70% of new housing is proposed south of Warwick and Leamington doesn't seem to make sense
And "The apportionment of housing was guided by the principle of....avoidance of coalescence of settlements". The option proposed for suburban peripheral development to Warwick and Leamington would guarantee that the two in fact would become symbiotic twins with no green buffer separating them.
I would like to have seen a 'HYBRID 5' option being proposed that included elements of options 2, 3 and 4.
I believe in particular that the development of a new town, in the mould of the Eco-Town once proposed near Ettington a few years ago, in South-central Warwickshire would be the best solution to our collective needs. Sites such as the former Royal Engineers depot at Long Marston would have been perfect. I also believe that further expansion of Southam would make sense regionally.
Other villages such as Leek Wootton and Hatton should be expanded more than proposed given a) their size, b) their available land c) their current lack of village services and d) their proximity to the A46 corridor and Warwick and Warwick Parkway train stations. Hatton currently has next to no services and amenities: how was it allowed to be so?
Despite the huge impact on the area, the matter of HMOs and students seems to get little coverage or perhaps I have missed something in the documents. Given the sale of the issue, the Local Plan should address how in future it expects to balance the town between long-term residents and students etc. I would advocate more block development and place a moratorium on the conversion of existing housing stock: there has been a great surge in the number of terraced houses converting to student occupancy which has reduced the availability for young home-makers and families. Surely this is placing an additional burden on the housing shortage being faced in Warwick District. I would urge that WDC considers the conversion of Riverside House and the Fire Station to student blocks with the Council retaining 51% ownership of the sites for future revenue generation.
3. Economic considerations and Employment
I cannot see where in the document it speaks of the additional employment lands other than at the Gateway site.
In fact, worse still, the mention of a Reduction in employment land on industrial estates in Sydenham, Cape Road, Montague and Common Lane would be to the detriment of low skilled work forces throughout the area. Currently such workers are able to walk / cycle to work. this will not be the case in the future as these sites are sold off for housing. By insisting on maintaining the land as industrial, the land value will fall and then become viable for future industrial use; if the land value rises then this will be impossible in future.
The document speaks of " a need to provide new employment land in and around the District's main towns to meet local needs and encourage the creation of new jobs". Completely agree with this but have serious reservations about the viability and robustness of the Gateway project to deliver the number and quality of employment it is promising. In fact, the notion of a business park by the airport would suggest that this is really a giant logistics park by stealth when the former Ryton car plant site is a ready made brownfield location for such business. If I recall, such an application was made some years ago but turned down by Rugby BC. Using Green Field and Greenbelt land to provide such business seems wrong on all counts therefore.
I do not see how the expansion of the Warwick Technology Park is going to help low-skilled workers find jobs. It does not make sense.
Further, the document details the need to "support the rural economy"; this is really important but only touched on. The entire viability of villages is threatened in future with the withdrawal of services from them (the closure of post offices / pubs, small village stores, even primary schools etc..)
4. Infrastructure
The document speaks of an emphasis on infrastructure - "the development of sustainable communities with strong local centres / and or community hubs". As above, the rural economy is very fragile and villages need greater support if they are to remain viable. Rural bus services will become more and more threatened unless the villages served have sufficient mass.
I don't understand how having the major employment site to the north of the district and the housing tithe south will not lead to massive congestion in the town centres of Warwick and Leamington. This does not make sense.
5. Sustainable
See point 1) above. To re-iterate, what is really meant by sustainable communities. It is important to be clear on this point to avoid accusations of 'Greenwash', but it is similarly important to ensure the best, most durable and sustainable communities are created, it just for 2029 but for 50-100 years from now.
The coalescence of Warwick and Leamington does not seem to support a better environment.
The document states that "..ensuring new development is based on principles of sustainable Garden Towns, suburbs and villages" is key however it is not fully explained how this may be achieved. Urban centres have an optimum mass but this is not explored. Likewise, their interdependence is not explained; creating an hierarchy of primary and secondary villages is welcome but this needs to be examined in depth as to implications for the main settlements.
Section 3.4 para 17 talks of contributing to conserving the environment by "....reducing pollution" yet this is not supported with any evidence or data. The development of south Warwick and Leamington would surely have quite the opposite effect.
The document speaks of "caring for our built, cultural and national heritage" which is laudable and right. But the strain on Warwick and Leamington town centres by the addict all 'peripheral residential development would be at odds with this aim.
There is no reference to Building Regulations or the greatest ambition of all, namely, to build 'Passivhaus' dwellings for all new developments between now and 2029. It is possible and should be our goal.
Cycle routes are mentioned only on passing. They should be a key factor in new transport planning to / from town centres and stations / transport hubs.
In summary I have major reservations about this Plan. It appears fundamentally flawed in its assumptions, its siting of housing and its assumptions for employment in the north of the District and not in the south. Foremost, I have grave concerns about the lack of infrastructure, in particular for roads and transport in general to support such number sof homes around the periphery of Warwick and Leamington.
These two towns are very unusual in that they have three barrier to the passage of people and traffic. From north to south and vice versa: a railway, a river and a canal. As such, in Leamington, there are just three narrow single carriageway routes joining the two halves. They will not be able to support any increase in traffic. And in Warwick their is the medieval town and castle to navigate around. What is already a nightmare for pollution will only become worse.
This is not a plan to deliver "Sustainable Communities and Development".
I urge you to reconsider urgently before these towns are forever destroyed by the short-termism forced on WD by developers and the NPPF and the Localism Bill.