BASE HEADER
RDS3: The Council's Preferred Option for the broad location of development is to:
Cefnogi
Revised Development Strategy
ID sylw: 59945
Derbyniwyd: 28/07/2013
Ymatebydd: Mr. Timothy Greasley
Supports the Revised Development Strategy. Supports the absence of development on the North Leamington Green Belt around Milverton and Blackdown as this land meets the 5 key roles of Green Belt and is an excellent and well used cultural and exercise related resource. If the Joint Strategic Housing Needs Analysis identifies an increase in the number of houses above those currently proposed, there is sufficient non-Green Belt land to accommodate this additional development. Proposals represent a fair distribution of housing. Commuting, pollution and infrastructure can be minimised as most of the new development is located close to where employment opportunities already exist and also maximises the opportunity for people to live close to their place of work, improving quality of life. There is ample space to build to the south of Leamington and focussing in one broad area ensures adequate public services can be provided and developed to meet the needs of the new population. The transport assessment clearly shows that development in the North would generate more traffic congestion in the district.
RDS provides for improvement to the road network South of Leamington to relieve the existing congestion and to cater for the new development. It is possible that mitigation methods may need to be employed in the Southern areas to reduce pollution and congestion but the work needed to do this would be less than that needed for the north. Putting the country park in the South next to the existing houses, with new housing beyond it, would make the green-park more accessible, crossed by cycle-ways and acting as a green-lung to reduce air pollution. The exclusion of development in the North Leamington green belt enables the plan to comply with the NPPF, any attempt to reintroduce this area would be opposed as no exceptional circumstances exist.
Supports the Revised Development Strategy. Pleased that the Council has recognised that the exceptional circumstances to develop the Green Belt to the North of Leamington do not exist and that it is vital to preserve the limited green space between Leamington and Kenilworth as there is a risk that the area will merge into the West Midlands conurbation. RDS proposes: new development close to employment opportunities where there is unlimited green space to the south of Leamington; removes the proposal for 2000 houses on the North Leamington Green Belt; proposes better use of brownfield sites and now only 325 further houses are proposed on Greenfield land; improvements to the road network (it is important these are carried out as part of a coordinated plan); the necessary schools and other infra-structure to support the new development; a fair distribution of new housing across the District. Requests the Council keeps the housing requirement to a minimum and if more houses are required following the Joint Strategic Housing Needs Analysis there is sufficient non Green Belt land to accommodate this additional development.
Cefnogi
Revised Development Strategy
ID sylw: 59946
Derbyniwyd: 21/10/2013
Ymatebydd: Mr Nigel Greasley
Supports the Revised Development Strategy. Supports the absence of development on the North Leamington Green Belt around Milverton and Blackdown as this land meets the 5 key roles of Green Belt and is an excellent and well used cultural and exercise related resource. If the Joint Strategic Housing Needs Analysis identifies an increase in the number of houses above those currently proposed, there is sufficient non-Green Belt land to accommodate this additional development. Proposals represent a fair distribution of housing. Commuting, pollution and infrastructure can be minimised as most of the new development is located close to where employment opportunities already exist and also maximises the opportunity for people to live close to their place of work, improving quality of life. There is ample space to build to the south of Leamington and focussing in one broad area ensures adequate public services can be provided and developed to meet the needs of the new population. The transport assessment clearly shows that development in the North would generate more traffic congestion in the district.
RDS provides for improvement to the road network South of Leamington to relieve the existing congestion and to cater for the new development. It is possible that mitigation methods may need to be employed in the Southern areas to reduce pollution and congestion but the work needed to do this would be less than that needed for the north. Putting the country park in the South next to the existing houses, with new housing beyond it, would make the green-park more accessible, crossed by cycle-ways and acting as a green-lung to reduce air pollution. The exclusion of development in the North Leamington green belt enables the plan to comply with the NPPF, any attempt to reintroduce this area would be opposed as no exceptional circumstances exist.
Supports the Revised Development Strategy. Pleased that the Council has recognised that the exceptional circumstances to develop the Green Belt to the North of Leamington do not exist and that it is vital to preserve the limited green space between Leamington and Kenilworth as there is a risk that the area will merge into the West Midlands conurbation. RDS proposes: new development close to employment opportunities where there is unlimited green space to the south of Leamington; removes the proposal for 2000 houses on the North Leamington Green Belt; proposes better use of brownfield sites and now only 325 further houses are proposed on Greenfield land; improvements to the road network (it is important these are carried out as part of a coordinated plan); the necessary schools and other infra-structure to support the new development; a fair distribution of new housing across the District. Requests the Council keeps the housing requirement to a minimum and if more houses are required following the Joint Strategic Housing Needs Analysis there is sufficient non Green Belt land to accommodate this additional development.
Cefnogi
Revised Development Strategy
ID sylw: 59947
Derbyniwyd: 28/07/2013
Ymatebydd: Ms Philippa Greasley
Supports the Revised Development Strategy. Supports the absence of development on the North Leamington Green Belt around Milverton and Blackdown as this land meets the 5 key roles of Green Belt and is an excellent and well used cultural and exercise related resource. If the Joint Strategic Housing Needs Analysis identifies an increase in the number of houses above those currently proposed, there is sufficient non-Green Belt land to accommodate this additional development. Proposals represent a fair distribution of housing. Commuting, pollution and infrastructure can be minimised as most of the new development is located close to where employment opportunities already exist and also maximises the opportunity for people to live close to their place of work, improving quality of life. There is ample space to build to the south of Leamington and focussing in one broad area ensures adequate public services can be provided and developed to meet the needs of the new population. The transport assessment clearly shows that development in the North would generate more traffic congestion in the district.
RDS provides for improvement to the road network South of Leamington to relieve the existing congestion and to cater for the new development. It is possible that mitigation methods may need to be employed in the Southern areas to reduce pollution and congestion but the work needed to do this would be less than that needed for the north. Putting the country park in the South next to the existing houses, with new housing beyond it, would make the green-park more accessible, crossed by cycle-ways and acting as a green-lung to reduce air pollution. The exclusion of development in the North Leamington green belt enables the plan to comply with the NPPF, any attempt to reintroduce this area would be opposed as no exceptional circumstances exist.
Supports the Revised Development Strategy. Pleased that the Council has recognised that the exceptional circumstances to develop the Green Belt to the North of Leamington do not exist and that it is vital to preserve the limited green space between Leamington and Kenilworth as there is a risk that the area will merge into the West Midlands conurbation. RDS proposes: new development close to employment opportunities where there is unlimited green space to the south of Leamington; removes the proposal for 2000 houses on the North Leamington Green Belt; proposes better use of brownfield sites and now only 325 further houses are proposed on Greenfield land; improvements to the road network (it is important these are carried out as part of a coordinated plan); the necessary schools and other infra-structure to support the new development; a fair distribution of new housing across the District. Requests the Council keeps the housing requirement to a minimum and if more houses are required following the Joint Strategic Housing Needs Analysis there is sufficient non Green Belt land to accommodate this additional development.
Gwrthwynebu
Revised Development Strategy
ID sylw: 59981
Derbyniwyd: 29/07/2013
Ymatebydd: Mr & Mrs Graham and Vera Leeke
All communites can benefit fom a measured amount of new development . It is highly unfair to propose 70% of the new growth requirement at one location. The wise approach would be to state that all riral communities (Green Belt or otherwise) should accept growth of up to 5% of their current housing stock.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60009
Derbyniwyd: 29/07/2013
Ymatebydd: Ms Margaret Middleton
The Council should reconsider its strategy and bring all empty properties into use as well as develop infill sites before Green field options are looked at.. If this cannot be made to work there should be consideration of a new settlement in the District (perhaps on the former Peugeot factory site).
Coalescence of current settlements should be avoided at all costs with consideration of a wider dispersal of smaller scale growth options as well as taking on board the wants of local people/ communities.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60158
Derbyniwyd: 29/07/2013
Ymatebydd: Mr Michael Wardle
Is this the time to reorganise the Green Belt as there is a very large area north of Warwick and Leamington that cannot be built on? WDC should consider allocating an area of land to the south of Warwick and Leamington, including the Asps and several of the possible Gypsy sites as green belt to provide a buffer to proposed develpment to the south of Warwick and Leamington or extend the Tachbrook Country park as far as Banbury Road. This would ensure villages in the south of the district retain their identiy and are not swallowed up by Warwick and Leamington over time.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60159
Derbyniwyd: 02/08/2013
Ymatebydd: Bishop's Tachbrook Parish Council
The Balance and Distribution of the Proposed New Housing across the District presents real problems:
Deeply concerned that, because of the unnecessarily high numbers of housing, the focus of new house building has shifted further to the south of Leamington and Warwick, further skewing the balance in the location of new housing:
a. such an imbalance of housing to the south will lead to significant congestion from traffic trying to access the town centres, particularly at the canal, railway and river crossings where there is no practical and economic mitigation option;
b. It places significant pressure on the southern landscape and the historic setting of Warwick in particular; and
c. It adds to the pressure on the coalescence of settlements and in particular threatening the rural identity of Bishop's Tachbrook.
The high housing numbers proposed must be reduced in order to address this in balance and to meet the NPPF, paras 54, 55, 109.
Green Belt Policy Influence:
The principle reason for this shift and the discounting in the RDS of significant housing sites to the north of the towns is because of the large amount of Green Belt (80% of its area) in Warwick District.
The additional status afforded to the Green Belt has the effect that one area of rural Warwickshire to the north is said to be more precious than another area of at least equivalent landscape worth to the south.
This is unreasonable and unfair. Further, it comes as a result of an application of the Green Belt principle that was not intended when green belt was established.
Town & Country Planning legislation used rural area policies to control development in designated rural area locations. These were intended to be strong enough to prevent such arguments arising.
The Parish Council fully supports Green Belt policy but expects that rural areas and landscapes close to urban areas should be controlled by strong rural area policies.
The contrast between town and country is important to the well-being of everyone and provides a high value recreational benefit for all, whether they drive, cycle or walk through it.
The West Midlands Green Belt was established to prevent large urban areas such as Birmingham and Coventry expanding uncontrollably into the surrounding countryside.
The fact that the Green Belt touches the north of Leamington and Warwick is therefore incidental because both at that time and now, the real threat of expansion on landscape and coalescence comes from Coventry.
The New Local Plan proposals have potentially far reaching affects for the district, with the potentially vast numbers of new homes being proposed.
Alternatives:
There are two choices:
1-distribute the housing through all parts of the district including green belt to satisfy large number of in-migrants; or
2-reduce the number of houses to that which the locality needs to meet sustainable objectives and respect the long standing purposes of green belt and rural areas.
If WDC decides to ignore the views of the electorate and to proceed with an overlarge number of new houses, it should undertake a strategic review of the Green Belt to determine whether exceptional circumstances prevail to justify redrawing green belt boundaries to distribute the new housing in a balanced way around the district (In accordance with requirements of NPPF para 83).
The NPPF requires that where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality. (Para 112).
If the Local Plan eventually includes Myton Gardens as a major urban extension, then the Council should establish a new green belt from Castle Park, along the Tach Brook valley south of Harbury Lane and Gallows Hill too provide long term protection of the landscape from urban sprawl as provided for in NPPF para 52.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60160
Derbyniwyd: 02/08/2013
Ymatebydd: Bishop's Tachbrook Parish Council
Rural Area Policies and loss of landscapes and agricultural land.
The previous Local Plan Inquiry in 2006/7 looked particularly at sites both in Areas of Restraint and subject to rural area policies.
Applying NPPF para 55 would extend the current Local plan rural policies " To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. For example, where there are groups of smaller settlements, development in one village may support services in a village nearby."
To do this, the local plan should have specific rural area policies. It may be that neighbourhood plans would customise such policies for particular reasons relevant to that parish.
In relation to proposals to select rural areas for development, NPPF para 109 requires that "The planning system should contribute to and enhance the natural and local environment by:
* protecting and enhancing valued landscapes, geological conservation interests and soils;
* preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and
* remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.
The sites selected for development to the south of Warwick & Leamington do not appear to meet the requirements of the NPPF:
* para 110 (minimising pollution and other adverse effects on local and natural environment);
* Para 111 regarding the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value; and
* NPPF112. Requiring local planning authorities to take into account the economic and other benefits of the best and most versatile agricultural land and using areas of poorer quality land in preference to that of a higher quality.
In particular, the district has not demonstrated that housing at the 12,300 or the 10,800 levels is needed to support the local community.
As housing projections are updated, the amount of housing needed for both objectively assessed natural and migration projections is reducing. 5,400 homes in the plan period is the best projection available.
NPPFpara 156. Requires that Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver: climate change mitigation and adaptation, conservation and enhancement of the natural and historic environment, including landscape.
The council's own Landscape consultant in 2009 has some very strong recommendations that should be taken into account.
The 2012 "Considerations for Sustainable Landscape Planning" concludes, in paragraph 9 that
"The scale and extent of development presently being considered in Warwick District is possibly unprecedented and will undoubtedly have major implications for the character and appearance of the towns and parishes affected for many decades to come. There is presently considerable pressure on local authorities to act quickly and to facilitate development. However, it is essential that good decisions are made for the long term. There is extensive contemporary guidance highlighting the importance of landscapes, ecology, historic fabric and all ecosystem services in creating sustainable development. "
Gwrthwynebu
Revised Development Strategy
ID sylw: 60167
Derbyniwyd: 02/08/2013
Ymatebydd: Bishop's Tachbrook Parish Council
Separation of settlements:
The Council to date has rigorously resisted any development that reduced the gap between Bishops Tachbrook and Whitnash/Warwick.
The NPPF requires the district to continue to implement those policies as part of the social role within sustainable development, supporting strong, vibrant and healthy communities.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60172
Derbyniwyd: 02/08/2013
Ymatebydd: Bishop's Tachbrook Parish Council
The representation sets out the key context to sustainable development as set out in the NPPF:
* The purpose of the planning system is to contribute to sustainable development and the representation sets out the five guiding principles of sustainable development. Also:
* Local planning authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three. Significant adverse impacts on any of these dimensions should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued (para 152).
* Local Plans are the key to delivering sustainable development that reflects the vision and aspirations of local communities (para 150)
Comment:
* So, is the consultation plan sustainable in the terms laid down by the NPPF?
* Is the assessed housing need at 12,300 assessed objectively for the District?
* Are the sites selected for development acceptable in principle and compliant with the NPPF?
* Is the effect on the environment, taken as a whole, of enlarging the population by another 20% in 15 years necessary and acceptable?
* Does the development require associated infrastructure other than provided in the housing development and are the costs of their provision covered by the proposed developments?
* Are there any significant adverse impacts from the development?
* What are the social impacts of the plan?
BTPC consider that none of these requirements pass the test of the NPPF and that the plan is non-compliant.
An additional 30,000 population if they were to arrive as planned would change the District dramatically and reverse the strategic vision promoted by the Council.
Alternatives:
The single most effective way to take all the communities forward together, without splitting north from south, green belters from rural folk and making happy people sad to see the place destroyed, would be to adopt the objectively assessed number of new homes as 5,400 as it would:
* be achievable within the terms of the NPPF and so get an examiners approval rather than rejection;
* use sites that are uncontroversial and fit in from the outset;
* provide all the housing requirements needed by the people in the locality and give a reasonable margin to allow trend based migration to occur;
* Provides a good set of affordable homes more quickly into urban locations with existing services and communities giving organic growth of the towns;
* Reduce car travel miles by using urban locations closer to facilities;
* allow a 5year housing land supply to be established forthwith and remove the impediment of developers usurping the local Plan process
* Be economically viable for all the public bodies that would otherwise be left with having to find the costs of additional infrastructure from the 12,300 plan;
* Retain rural area policies intact into the new local plan, retaining agricultural land and high visual quality landscapes;
* Retain Green Belt which is so valuable in differentiating the character of Warwick district from the surrounding conurbations;
* Retain the attractiveness of the district that is basis of our thriving tourism industry;
* Retain the existing good jobs homes balance, despite the continuing economic situation;
* Be aspirational but also realistic because 5,400 homes still produces 10,000 employees that will need employers, which, short of a miracle will be hard to find;
* Be better to grow more slowly and controllably than rashly and erratically: and
* Regain the trust in our elected representatives
Gwrthwynebu
Revised Development Strategy
ID sylw: 60188
Derbyniwyd: 29/07/2013
Ymatebydd: Lone Star Land LLP
Asiant : Alliance Environment & Planning Ltd
Act on behalf of Lone Star Land LLP in respect of their land interests at Norton Lindsey, Warwickshire.
Settlement Hierarchy:
Whilst generally supporting the proposed strategy for the broad location of development (RDS3) which seeks to focus development within or on the edge or existing urban areas and at primary and secondary villages, consider that the 'limited growth' now proportioned to the smaller Villages (i.e. Norton Lindsey) and hamlets is unjustified and does not fully recognise the importance that such settlements could play in significantly boosting housing land supply in the District.
As drafted consider the policy as it relates to Settlement Hierarchy is unsound, in that it is not positively prepared (i.e. it will not meet the objectively assessed housing need), neither is it sufficiently justified nor effective.
Questions the robustness of the Council's Draft Settlement Hierarchy Report which been used to inform the identification of Primary and Secondary Villages in RDSS.
This report has only assessed villages with regards to their sustainability and has not undertaken a detailed assessment to fully consider the constraints facing each settlement (para 5.3).
This work should have been completed before any specific settlements were identified to accommodate the District's future growth.
In particular, Norton Lindsey was previously identified within the Council's Preferred Options Local Plan as a Category 2 Village which had the potential to deliver between 30-80 new dwellings.
In the RDS the categorisation of Norton Lindsey and its role in delivering new housing growth has been reduced further although it is noted at para 4.4.6 that some growth will be acceptable where it is practical and also avoids compromising the character of the Green Belt, new Village envelopes will be established to accommodate infill or small groups of dwellings, subject to detailed form, scale and character considerations.
Would wish to see any further material with regards to the Council's intentions to introduce capped proportional growth rates at Norton Lindsey and the other smaller Villages identified at Table 3.
Lone Star Land LLP is willing to work in partnership with the Parish Council to deliver new homes to meet the local needs of Norton Lindsey and a development which respects the existing character and setting of the Village.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60190
Derbyniwyd: 13/08/2013
Ymatebydd: Catseby Estates Ltd
Asiant : Framptons
The provision of land to meet possible future development needs beyond the plan period (Safeguarded Land):
In that it is evident the strategy of the emerging Local Plan requires the release of land from the Green Belt to achieve sustainable patterns of development, it is almost inconceivable that a future strategy will not similarly require further releases of land from the Green Belt.
In order to make provision for longer term development needs, this Local Plan should identify 'Safeguarded Land'.
If contrary to the submissions that have been made above, it is concluded that this site is not required to meet housing needs arising from within the plan period, then it is submitted that the site should be excluded from the Green Belt to meet possible future development requirements beyond the Plan period.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60194
Derbyniwyd: 29/07/2013
Ymatebydd: Gladman Developments
Supports the Council's decision to direct development to the main urban areas and the sustainable Primary Service Villages.
However this should not preclude development coming forward in lower order, but still sustainable settlements.
Proposals according with the Council's guidelines for village development should be considered acceptable.
Where suitable, unconstrained sites are available this suggests that a village can support housing growth at the upper end of its allocated dwelling range.
It may also be preferable to focus more growth in villages that are unconstrained by Green Belt designations.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60200
Derbyniwyd: 29/07/2013
Ymatebydd: Gladman Developments
The Council's preferred approach directs development to within and the edge of exiting urban areas. It allows for a higher level of growth in more sustainable villages with a reasonable level of services, and limited growth to smaller villages and hamlets of a scale appropriate to the existing settlement. It recognises that development directed towards villages may need to be located within or adjacent to the existing village envelope, and in some instances within the Green Belt.
In principle support the Council's distribution strategy. It recognises that growth should be directed to key towns and villages with established sustainability credentials, ensuring the creation of sustainable communities that have good access to a range of jobs, housing, community facilities and key services and infrastructure.
However, it should be noted that whilst the main settlements should accommodate a larger proportion of housing growth, this should not prevent development coming forward in lower order, sustainable settlements, which could also help to sustain existing facilities and services.
One of the principles of the Council's development strategy is to avoid development which could potentially result in the coalescence of settlements.
Would welcome further clarification on the decision making criteria that would be used to implement this policy.
In particular it should be recognised that development which results in a physical loss in separation can often be accommodated without eroding the character and identity of individual towns and villages.
Sustainable Urban Extensions and Housing Supply
A significant proportion - 66% - of the of the Council's proposed housing requirement is to be met through the allocation of sustainable urban extensions (SUE).
Whilst recognising the sustainability benefits that can arise from SUEs, placing too much emphasis on these sites could further result in an under-supply of housing in the District.
Large SUEs often require extensive infrastructure and planning prior to housing being delivered. As a result often they fail to come forward as anticipated, or only start to deliver in the medium to longer term.
If the Council cannot demonstrate a five-year housing land supply upon adoption of its Local Plan there's a risk that its housing policies will be out-of-date as soon as the Plan comes into effect.
In light of the above, and to ensure housing comes forward as anticipated, the Council need to allow for the release of additional housing sites, and earlier in the Plan period to meet its housing needs.
In doing so it should consider sites that result in sustainable development and continue to support the Plan's strategy.
Village Development
The Council's 2013 Settlement Hierarchy Strategy allocates an initial range of housing growth to each of the Primary and Secondary Services Villages.
It describes how these initial figures have been based on feedback from Parish Council's and Neighbourhood Plan teams, apportioning housing based on existing settlement size, and an outline assessment of key delivery factors, e.g. services and facilities, environmental impacts and the suitability of sites.
The initial dwelling ranges for the District's Primary Service Villages are set out in Table 3 (as submitted).
With reference to the distribution strategy for the Primary and Secondary Service Villages the Council is reminded that it should not be progressing a political strategy to apportion development to settlements where people do not want to (and will not) live.
Whilst recognising the role of parish council's and local communities in shaping the development of their areas first and foremost growth should be distributed on the basis of meeting housing needs.
There may also be a need to update the village dwelling allocations in light of the Joint SHMA findings.
The Strategy goes on to state that the initial dwelling ranges for each village will be reviewed in light of ongoing work on Green Belt assessment, habitat and landscape impact and identifying the most appropriate sites - that minimise environmental impacts, contribute to the built quality of the village and deliver an appropriate scale of development - which could deliver housing in each village.
This suggests that where suitable, unconstrained sites are available a village can support housing growth at the upper end of its allocated range.
It may also be preferable to focus more growth in villages that are unconstrained by Green Belt designations.
Policy RDS5 provides further guidelines on how housing within the villages should be accommodated. These criteria include:
* Ensuring an appropriate mix of dwelling types and sizes, including affordable housing
* Ensuring acceptable design, layout and scale through a collaborative approach involving Parish Council's, Neighbourhood Plan teams and residents
* Carefully considering the quality of development and how this relates to local vernaculars; and
* Ensuring landscaping will be used positively to contribute to and protect the quality of place
Where a proposal accords with these criteria it should be considered acceptable and sustainable.
However it is noted that two further guidelines for village development set out that housing growth should be located within the village envelope and give priority to the redevelopment of brownfield and previously used sites.
Gladman Object to these guidelines in their current form.
Whilst locating sites within existing village envelopes is desirable, under Policy RDS4 the Strategy recognises that there may be a need to locate further village growth adjacent to existing settlements. This should be emphasised in Policy RDS5.
Further, whilst it is recognised that the development of brownfield sites is important, a priority should not be placed on this which would act to arbitrarily restrict development on sustainable Greenfield sites. It is also worth noting that there are likely to be brownfield sites that are less sustainable than Greenfield land options.
Infrastructure Requirements
The RDS sets out requirements for the provision of infrastructure where it has identified specific site allocations and a range of Borough-wide highway improvements.
The Council are reminded of the guidance on viability set out in p173 of the Framework, which states that "Plans should be deliverable.
Therefore, the sites and scale of development identified in the Plan should not be subject to such a scale of burdens that their ability to be developed viably is threatened".
It is noted note that the Council is yet to publish an Infrastructure Delivery Plan or test the viability of its infrastructure requirements.
The robustness of these requirements in their current form. is therefore questioned.
The requirement to provide new infrastructure should only apply where there is a clear and evidenced deficiency in the provision of existing facilities to accommodate a development.
Cefnogi
Revised Development Strategy
ID sylw: 60219
Derbyniwyd: 28/07/2013
Ymatebydd: Mrs Mary Rypma
With this email I give you my full support for the revised Local Plan.
It is certainly a much better plan that the last one !
Cefnogi
Revised Development Strategy
ID sylw: 60220
Derbyniwyd: 28/07/2013
Ymatebydd: Christine & Ingo Lyle-Goodwin
Nifer y bobl: 2
We are writing to support the revised plan that omits Old Milverton from development with some relief. We are pleased that the village will be preserved and free from overbearing traffic.
Cefnogi
Revised Development Strategy
ID sylw: 60231
Derbyniwyd: 27/07/2013
Ymatebydd: Gallagher Estates
Asiant : Pegasus Group
The distribution strategy put forward by the Authority in RDS3 seeks to focus development within, and on the edges of, the existing urban area. In so doing it seeks to protect the Green Belt where there are non Green Belt options available and seeks to avoid development in areas which would lead to the unacceptable coalescence of settlements.
The approach goes on to suggest a proportionate amount of growth in the rural areas, based on a hierarchical approach to the suitability of rural settlements.
This strategy is consistent with the NPPF in terms of sustainable development paras 151 and 152 refers.
The distribution strategy put forward by the District Council can deliver a considerable number of positive impacts in environmental, social and economic terms. The spatial strategy is therefore supported.
The distribution approach will perform mindful of paragraph 7 of the NPPF, an economic role by providing land of the right type in the right place proposing development that can assist in delivering infrastructure particularly in the proposed strategic urban extension sites to the south of Warwick and encouraging higher skilled economic sectors directing employment growth in the vicinity of the Warwick Technology Park.
The strategy also performs a social role by providing housing in locations that are accessible to services and can support strong, vibrant and healthy communities.
Lastly the strategy provides an environmental role. This includes: maintaining and enhancing landscape and townscape quality and promoting biodiversity by enhancing connectivity and diversity of habitats and wildlife corridors and positively encouraging energy efficiency.
In particular the distribution strategy proposed at RDS3 provides a clear prioritisation that land outside of the Green Belt on the edge of existing urban areas is to be used in preference to locations within the Green Belt which closes the gap between existing settlements and could potentially lead to their coalescence.
This addresses a concern previously raised at Preferred Options stage. The NPPF, at paragraph 85, is clear that Green Belt boundaries should only be altered in exceptional circumstances. It is the case that the updated evidence base provided by the Council (summarised at 4.3.4 to 4.3.12) demonstrates that the previous perception that additional development should be accommodated in the Green Belt to the north west of Leamington as an exceptional circumstance cannot be substantiated.
In reality the evidence base supports the release of further land to the south of Warwick, outside of the Green Belt, as a sustainable approach.
Cefnogi
Revised Development Strategy
ID sylw: 60242
Derbyniwyd: 25/07/2013
Ymatebydd: J.G. Sayell
If this development within the District is essential, considers the Revised Plan to be the best option and supports it. Pleased that the RDS recognises that there are no special circumstances for the use of this green belt and does not include proposals for further development in the Milverton/North Leamington areas. The use of land in the south of Leamington / Warwick to meet the proposed development makes sense because: ease of access to the M40 J14 and J13; all large and recently built supermarkets etc are to the south of the town; local employment opportunities; the Plan allows for road improvements.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60243
Derbyniwyd: 25/07/2013
Ymatebydd: J.G. Sayell
The District has an asset in Leamington Football Club (the 'Brakes'). The Club has risen through the levels of the sport and is only held back due to its present location. Provision for an independent stadium in South Town that would in due course cater for the Club becoming professional should be considered.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60246
Derbyniwyd: 25/08/2013
Ymatebydd: Mr Nigel Hamilton
Every ward should have the same level of housing growth during the plan. 4,000 units adjacent to Warwick will lead to a 40% increase in the town's population: this is unsustainable in quality of life, transport, air quality, employment, schools, and health infrastructure, and will destroy the character of the town totally, and therefore damage the local economy which depends upon it.
Inexplicable lack of housing growth in and around Kenilworth. The greenbelt should in principle be protected, but not where this protection will cause massive detriment to the life and health of the inhabitants of Warwick.
1,000 houses over 15 years in the villages is inadequate to meet their housing needs or the lack of affordable housing. Suggests a minimum 3500 of the 12800 houses in the plan be developed in the village areas spread evenly across the district. This number could be much higher, built on the existing village fringes. Infrastructure is much more likely to be able to cope with 6-10 new houses per rural ward per annum than the huge estates proposed adjacent to Warwick. Would meet some of the need for affordable rural housing projected, at 67 per year if 33% was "affordable".
Suggests three areas which have been overlooked for large scale housing provision are Bagington, Radford Semile and Lapworth. All ripe for large scale "garden suburbs", supported by business parks, supporting existing shops and schools. Suggest at least an additional 1,000 to 1,500 houses are considered for each ward. Opportunity in Lapworth to build a business park to tap into the proximity to Solihull and at Radford Semile to build a business park dedicated to engineering to tap into the expertise and supply chain associated with Ricardos. Warwick Gateway would be supported by new housing and infrastructure, too. this would mean much smaller developments around Warwick would be required.
The land between Warwick, Whitnash and Bishop's Tachbrook is rural and agricultural and present policies respect this. Building on it would merge our built-up areas, making them a single suburban sprawl. The green land is as important as the Green Belt, arguably more so, to the north of Leamington and Warwick, and should be safeguarded just as strongly.
To be sustainable would be better to have more smaller housing developments within walking/ cycle distance of the new job provision; i.e. small estates near small business parks? If not possible, a commitment to provide and subsidise long distance inter nodal commuter bus routes is essential.
Low paid workers will need to be able to commute quickly and cheaply to where the jobs actually are. This can be achieved, by developing inter town express bus routes, integrated with mini bus services which will then serve the local housing areas, funded by the CIL. Lack of effective public commuter transport compounds inequality and creates greater dependency on state subsidies, as those able and willing to work cannot afford the transport to get to the jobs, and the bus services are simply too slow and too infrequent to be a viable alternative. Regular local new commuter train services linking together all the major Warwickshire Towns and Coventry should be a priority, funded by the CIL.
Air Pollution: Parts of WDC already do not meet the Nox emissions EU Directive, including large parts of the centre of Warwick.
40% increase in the town's population, over 15 years will add to the congestion and air pollution.
Historic Distinctiveness and lack of "vision": Believes the plan should do more to promote good design in housing. Should seek to protect the historic buildings in the area and their settings. The Plan needs a clearly articulated "heritage vision". Existing open spaces, sports fields, allotments and parklands should be protected from development, including their settings. An alternative approach could be to build modern squares rather than "garden cities", the higher density and ease of mixed development can lead to more sustainable communities and less urban sprawl.
Affordable Housing: the definition needs broadening. The plan highlights the need for housing for the elderly. One solution to their needs would be to classify "granny flats" or semi separated apartments within houses as the "affordable housing" targets. Multigenerational living should be encouraged as it meets housing need, is sustainable and reflects changing land-use patterns.
Public Space: Existing open space, sports and recreational buildings and land, including playing fields, should not be built on. Any new developments should have additional public space. RDS mentions need for extra public space to accommodate the increase in population but no clear policy to designate all existing public parks as "areas of restraint".
Climate Change: Flooding and SUDS: great care should be given to the siting of all new developments. Consideration should be given to more local flood defences and helping individuals to flood proof their homes.
Fear of Crime: No sex clubs or night clubs should be allowed near housing- they should only be built in non residential areas. No new pubs, bars or hotels should be built or change of use in areas of predominately residential nature, to protect existing residential amenity. Should be the presumption that in residential areas new businesses will not increase the background ambient noise levels. If this cannot be achieved these businesses should be located in designated areas such as retail or business parks.
Good Design: The plan highlights good design and sustainability. All new housing should be built to Parker Morris standards.
Tourism: New visitor accommodation should be examined to see if it would have a negative impact on the existing providers locally as a material planning consideration. Desirable to have a diversity in type and location of accommodation providers
Gwrthwynebu
Revised Development Strategy
ID sylw: 60251
Derbyniwyd: 26/07/2013
Ymatebydd: Mrs Christine Miles
The situation made worse in South Leamington and Whitnash by the `immigration` of students from Warwick University. Many properties suitable for first time buyers have been bought to let and been used to accommodate students. Whitnash also currently takes a higher level of Immigration compared to other areas.
Healthcare and education provision is already virtually to capacity.
Transport - at times the roads in this area are exceedingly busy and hazardous around schools especially.
The plan shows the most significant development focussed on the area south of the river. The `green belt` argument used to limit development to the north of Leamington is artificial. `Green belt` status is man-made, created some years ago to meet the needs of the time, and should be varied when circumstances change. An even and fair distribution of new housing across the district is needed.
There is still much brownfield land in the wider area e.g Baginton and Ryton.
Cefnogi
Revised Development Strategy
ID sylw: 60253
Derbyniwyd: 26/07/2013
Ymatebydd: The Leamington Society
Glad to note significant numbers allocated to urban sites, along with some consolidation from employment areas and a large allowance for windfall sites.
Larger Villages: this is an appropriate allocation, to concentrate on villages which can best sustain local schools, shops and other services. Should encourage a younger rural population to stay.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60254
Derbyniwyd: 26/07/2013
Ymatebydd: The Leamington Society
Formulating a core strategy in relation to housing provision is proving controversial. The headline feature of the revised strategy is to plan for very large suburban extensions to the south of Leamington and Warwick. It is evident that this has the potential seriously to aggravate existing traffic problems and will require considerable road works. Such works will be expensive and highly intrusive: they may mitigate the immediate local problem but will not prevent an increase in congestion and pollution around and within the adjoining towns. There are three elements to this large increase in housing allocation: the total numbers, the proposed locations, and the character and density of the new developments.
Too little attention is given to the character of the proposed developments. It also relates to diversity of housing need, to affordability, and to the viability of public transport.
Affordability is almost certainly the most challenging problem in shaping housing policy. The figures in terms of house prices and of market rents are stark. RDS offers no guidance for negotiating an agreement on affordable housing. Affordability at 40 % will surely be dependent on design and we doubt very much that this policy can be sustained without firmer guidance, perhaps through Design Codes.
There is brief reference to size & number of bedrooms related to the SHMA and also mention of older people. But this seriously fails to address the diversity of varying accommodation requirements over modern lifetimes & social choices; it also entirely ignores the potential for an imaginative range of layout and architecture in addition to rows of houses and lawns. It is unrealistic to assume that throughout our typically long and varied lives we are all or mostly living in unchanging families of parents with young children. Moreover that choice / assumption carries with it serious environmental and cost consequences. It appears that developers are most comfortable with this traditional layout. But the function of a local Plan is not simply to align with the "low hanging fruit" most attractive to developers: otherwise there would be no point in a Plan, just leave it all to the market.
The Plan should give a much stronger lead in challenging developers to come up with more ambitious and diverse designs for varied needs, including affordability.
Regarding the "Garden Suburbs" prospectus we indicated a series of points on which we say this is inadequate as a policy document and in parts misleading. It often confuses green pictures with genuinely sustainable solutions to the District's housing needs. We have looked at the WDC website commentary on 2012 responses to the Pos and in relation to low density sprawl it states 'A balance needs to be struck between land-take and the quality of design'. We are surprised at this suggestion of a false conflict: quality of design resides in meeting the needs of a situation with skilled, well tailored solutions.
Even if an overall allocation of sites is set out as in the RDS there remains the question of how developers will respond. They will seek to cherry pick, in search of convenience and maximum profit. Any Plan will need to prioritise and hence respond to applications on a firm basis. The mechanisms for setting and achieving effective priorities are no doubt technical. Various carrots and sticks are available but these will surely need to be driven by criteria set out in the Plan.
Plan lacks any emphasis on 'Brownfield' sites and needs a stated priority to re-use such land, driven by beneficial conditions as necessary.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60259
Derbyniwyd: 26/07/2013
Ymatebydd: Mr Patrick Reddin
Could we not build on brownfield and infill sites already within each town's infrastructure?
The air quality issue is of great concern. Understands that air quality in Warwick and Leamington is already above the legal limit. The Council is required to improve air quality. The scale of planned houses will make it worse. Notes that Stratford Council have their own plans for even more houses south of Warwick, has this development been taken into consideration?
Believe the strategy is car based and will push even more congestion onto the existing road network. Building a dual carriageway to the river Avon bridge will just bring increased traffic to a halt. Also the current bridge was not built to take the potential amount of traffic. Parking in Warwick is already difficult enough, this plan will make matters far worse. There will be implications for traffic at the Morrisons roundabout on the Myton Road.
There is no doubt that the plans will ruin the visual look of Warwick forever. The increase of traffic and people will drive visitors away. We need to conserve the beauty of Warwick not plan to destroy it.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60266
Derbyniwyd: 26/07/2013
Ymatebydd: Lynn Waters
Why are brownfield sites not being utilised before new greenfield developments - is it "easier" for developers to go for greenfield sites?
It is not a given that all new residents will work in the same area as they live, therefore congestion is inevitable because of the concentration of new houses to the south Warwick.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60276
Derbyniwyd: 05/07/2013
Ymatebydd: Gill and Steve Hawkins
We feel very strongly that the amount of proposed new housing will have a tremendous negative impact on south Leamington - the road system will not cope and nor will local facilities. Also we feel that North Leamington is escaping any of this upset and we feel the housing should be more evenly distributed
Gwrthwynebu
Revised Development Strategy
ID sylw: 60344
Derbyniwyd: 29/07/2013
Ymatebydd: Mr Peter Kerr
Air pollution is already at, or above, the recommended levels. RDS does not address this problem. No mention of the capacity of Warwick Hospital to cope with a massive increase in population. The present hospital is surrounded by housing and cannot expand; can it cope with such an increase as is projected. In addition, serious consideration should be given to giving equal protection to open land to the south of Warwick and Leamington as that given to the "green belt" area located to the north of the towns so that all the open "greenfield" sites can be considered equally and the load spread more equitably throughout the District.
Cefnogi
Revised Development Strategy
ID sylw: 60348
Derbyniwyd: 26/07/2013
Ymatebydd: Warwickshire Wildlife Trust
Pleased to note that the RDS does largely recognise that, for the majority of the sites listed above, wildlife sites are a constraint to development and that the green infrastructure proposals do outline mitigation measures where needed.
Pleased to note the buffering and extension proposals around the Tach and Whitnash Brooks as well as the 50m buffer for the ancient woodland habitats at Thickthorn and Glasshouse Spinney.
These measures must be supported by a robust policy for the protection and enhancement of wildlife sites within the Local Plan.
Cefnogi
Revised Development Strategy
ID sylw: 60352
Derbyniwyd: 26/07/2013
Ymatebydd: Hatton Parish Plan Steering Group
Welcomes the revised proposals which seem to be better balanced and more appropriate to the needs of the District and the wishes of its residents than the original ones. Welcomes the reduction in the number of settlements proposed for development along the A4177/B4439 corridor, which would have threatened the integrity of the Green Belt through pepper-potting.
Gwrthwynebu
Revised Development Strategy
ID sylw: 60399
Derbyniwyd: 09/07/2013
Ymatebydd: Mr Anthony King
The Local Plan needs to locate the new housing both north and south of the river in a fair, and environmentally sustainable plan; make strenuous efforts to reduce illegal levels of air pollution by addressing the traffic problems through Warwick and Leamington (including new bridge and bypass if necessary); and ensure that the fabric of our historic environs are respected.
What has brought about the deletion of all sites that were earmarked for development on the north side of Leamington? The argument would seem to be that the sites are located in the Green Belt and there were objections to this. As a result a major proportion of sites are concentrated on environmentally and visually sensitive sites to the south of Warwick on greenfield sites. The environmental and traffic congestion problems that this will generate seems to have also had a lesser consideration.
The green belt plan to prevent urban coalescence is over 50 years old and in need of changing to ensure a plan for the orderly fair and sustainable development of Warwick and Leamington.
Over the past 10 years Warwick has grown at a rate of 1% per annum, which is double to national and county average. It is time to look elsewhere.
The nitrous dioxide levels in both Warwick and Leamington still remain well above the levels set following the Air Quality Regulations 2000. Further development and traffic will worse an already illegal level leading to further health problems and damage to historic buildings and quality of life.