BASE HEADER

The Warwick District Council's Local plan, including the 2016 modifications is not sound.

Justification
Whilst the overall number of new dwellings Warwickshire County is required to take may in total be justified, the process for distribution across the neighbouring Districts and Boroughs is flawed. Each of these Councils identified its own criteria on which to base the number of dwellings, the sites identified and subsequent distribution of numbers to sites. This is inconsistent to such an extent that if one district or borough was in error or identified criteria to restrict site suitability, the all subsequent allocations are unjust.
Positively Prepared
Warwick District Council's approach to identifying sites to meet the modified number of dwellings in the new version of the Local Plan is flawed. The Council's approach of identifying sustainable villages has two major flaws:
First, it uses this information to justify the allocation of additional dwellings in villages that it considers are sustainable, but at the same time refuses to accept the fact that additional dwellings in or around villages that are not sustainable, would improve the potential sustainability of these villages. This is particularly the case in respect of public transport where funding is cut or services not provided because there is no demand. The current approach makes these villages less sustainable, and with aging populations, increases the risk of further isolation and disenfranchises rural communities. Additional dwellings would make these sustainable.
Secondly, although Warwick District has a proportion of its area in Green Belt, the creation of a small new town or enlarged village some distance from the main centre of population on green land would obviate the need to use Green Belt and therefore there would be no need for the use of Extra Special Circumstances for building in Green Belt. This situation does not occur in some other Districts or Boroughs because they are largely green land not green belt. It seems that in this instance the mechanisms for identifying the allocations mentioned above as unjustified.
Consistent with National Policy
National Policy is for planners and one would expect the plan to be consistent, however, I have grave concerns about the quality of expert advice provided by the county council and other statutory providers. Bearing in mind that this plan will play a significant for the future and bring in irrevocable changes over its duration, it would be reasonable to expect that Warwick District Council was diligent in its questioning the reasons for any infrastructure modifications or in most cases the reason why no new or modification of infrastructure was needed.
I take the case of Hampton Magna in which an additional 254 dwellings are planned to be built alongside some 650 or so. A primary school is already in place and has a good reputation. Within the general catchment area, taking account parental choice, a further 200 or more dwellings are due in Hatton Green (3 miles) and Hatton Park (2 miles). The Expert Advice on this is that an extra classroom will be needed. However, the School itself has had no input.
A similar position occurs with the network of roads connecting these villages, including the A4177 and the increasing volume of traffic using the popular Warwick Parkway station. The Infrastructure Report only identifies extra slip roads where the A4177, A425 & A46 meet at a roundabout, and traffic lighting. These modifications in the plan are not new. Prior to the Creation of the Local Plan traffic at this junction had already caused concern and the County Council were already planning to do this work. Local people are concerned that the modifications are inadequate, but also that Section 106 or CIL monies may the being redirected to paying for these. In two years the cost of the same modifications has risen from £1.4M to £3.4M.
The creation of a Local Plan is so significant that not to challenge the experts about their comments is negligent.
Sustainable
The question here is 'what does it mean' in this context. We don't know. The planners don't know. It is certain that those villages where there is no development will not be in themselves sustainable. It is clear from other sources that public transport, help for the elderly, Caring, Education, Health Services all of which are seeing a reduction in resourcing in real terms so these, and the populations and new developments using these cannot be sustainable. I have explained that capital infrastructure on roads is not there and most of the other services - gas, electricity, water and sewerage, and high speed broadband - are provided on a suck it and see basis. There is a miniscule chance that sometime after the end of the Local Plan, when more people have complained, the new developments may be sustainable. But it is too late then.

Conclusion
It is my contention that the Local Plan is so unreasonable that it is so unreasonable that no reasonable organisation acting reasonably could have made it: Wednesbury unreasonableness.