BASE HEADER
DS10 Broad Location of Allocated Sites for Housing
Gwrthwynebu
Publication Draft
ID sylw: 66357
Derbyniwyd: 27/06/2014
Ymatebydd: Mr & Mrs Peter & Linda Bromley
Nifer y bobl: 2
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The location of so much development in the south of the District will encourage car use. Jobs and schools to support this development do not exist.
The proposals are not consistent with the NPPF and appear to be financially motivated.
The loss of so much greenfield land is unsustainable. The greenfield areas to the south of the District play an important part in separating communities and are limited in extent. The Local could lead to communities being joined together by development. It is not necessary to develop greenfield sites. The proposals will lead to a large funding gap in infrastructure provision, particularly in mitigating traffic movements across the towns. Additional traffic signals have already been required for new developments. The allocations are to the south of the towns, will encourage more movements across the towns including crossing the river, canal and railway. The proposals do not provide for a bypass or other means to avoid the town centre. This additional traffic will make pollution worse and increase health risks.
The result of allowing houses to be built on every single green space between housing is that sites cannot be integrated and cannot deliver the infrastructure required.
The proposals will damage important heritage assets in Whitnash by building on every remaining greenfield space.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66369
Derbyniwyd: 25/06/2014
Ymatebydd: The Leamington Society
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
This policy is based on a housing target that is not justified. Much of the allocation is on land to the south of Warwick and Leamington. The implications for transport and other infrastructure are severe, damaging and expensive. If fewer houses were planned for the a large proportion of the need could be provided for on brownfield sites as required by the NPPF.
see attached
Gwrthwynebu
Publication Draft
ID sylw: 66387
Derbyniwyd: 27/06/2014
Ymatebydd: Warwick Town Council
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
The plan ignores:
The importance of of retaining greenfield sites free from development as recommended by the residents of Bishops Tachbrook, Warwicka nd Whitnash. Dismissed, even though such allocations are unnecessary.
The impact of air quality and the health of residents as development will generate greater number of of vehicles, with more congestiona dn even more dangerous levels of air pollution in Warwick.
The damage to the environment and heritage assets of Warwick and fails to promote Warwick as an attractive place to live in, work or
visit. All of which would have a serious impact on the visitor economy.
The transport strategy upon which the plan is based is flawed.
Gwrthwynebu
Publication Draft
ID sylw: 66392
Derbyniwyd: 27/06/2014
Ymatebydd: Cllr Elizabeth Higgins
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
The enormous impact of so many houses, to the south of Warwick, around Bishops Tachbrook, and Whitnash, as well as SDC's plans to build maybe as many as 3,800 houses in Gaydon/Lighthorne Heath, just to the south of Warwick; is really worrying many Warwick residents.
Loss of Greenfield and agricultural land is unsustainable.
Greenfield allocations, unnecessary, densities, too low.
Transport strategy ineffective and unsustainable.
Air Quality, already at danger levels.
Failed to give enough emphasis to protecting our assets from the onslaught of modern traffic.
The effect of so many houses, to the south of Warwick, BT and Whitnash, Gaydon/L/H and their vehicles will increase traffic in our three town centres to an unacceptable level. These 8000 houses, if built, will bring cars with families seeking schools, doctors, libraries, and medical/dental services.
The independent assessment of STS(4) by WCC has now been formalised and it castigates WCC with its "mitigation" plans which actually means accommodating more vehicular traffic along our narrow streets to the detriment of the built environment and the health of people who live, work or visit our towns.
Save Warwick and Warwick Deserves Better have produced magnificent representation to you on heritage and the effect of traffic, both poor air quality and the effect of vibration on historic buildings.
Gwrthwynebu
Publication Draft
ID sylw: 66405
Derbyniwyd: 30/06/2014
Ymatebydd: The Warwick Society
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The tabulation in policy DS7 shows that 3,600 new homes have been completed since 2011 or had planning permission by 31 December 2013, that a further 3,100 sites will become available as windfalls, as Small Urban sites in the SHLAA and through the consolidation of existing employment areas and canal side regeneration; urban brownfield sites allocated in policy DS10 provide 1,300 new homes. The total without any use of greenfield land provides for 8,000 new homes.
The requirement for substantial expenditure on healthcare and education infrastructure would be very much reduced, and the needs of the growing population met by incremental expansion of existing facilities within the existing built up area.
The transport infrastructure requirement would be heavily reduced. The need to accommodate traffic growth, especially from greenfield developments south of Warwick, would disappear. Development sites within the existing built up areas would create much less demand for transport: local educational, healthcare, retail and leisure facilities would be largely within walking or cycling distance of the new homes.
see attached
Gwrthwynebu
Publication Draft
ID sylw: 66420
Derbyniwyd: 27/06/2014
Ymatebydd: Sharba Homes Group
Asiant : PJPlanning
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The Council appear to have made assumptions and assertions about where they feel it is appropriate to locate housing within the district, as well as the level of housing to be provided, before carrying out the relevant assessments with an open mind to reach such a conclusion. Thus, the process has begun from entirely the wrong premise and is based on evidence that is partial, inaccurate and subjective. It also shows little regard for the evidence base for the new Local Plan. Following the cessation of work on the 2010 Core Strategy the Council did not start the process anew, and instead merely attempted to rehash pre-determined strategies and development patterns.
The green belt allocations are not sufficiently justified as there are suitable sites outside the green belt. Exceptional circumstances pertaining to the 'need' for land are not proven. See reps relatibg to policies DS11 and DS19 as well.
A number of sites proposed in the Plan have previously been refused planning permission and cannot therefore be considered deliverable. Further the significant amount of development in one location on land to the south of Leamington Spa, will mean there is not enough choice to provide the level of competition required. The plan is not considered sufficiently robust to adapt to market conditionsdue to under-allocation of sites and little overall headroom.
Please see the attached representation submitted by PJ Planning on behalf of Sharba Homes Group
Gwrthwynebu
Publication Draft
ID sylw: 66435
Derbyniwyd: 30/06/2014
Ymatebydd: Mrs Luisa Hodge
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The Local Plan after emotive pressure from North Leamington protestors disregards green belt yet does not pursue with sufficient vigour preferable brownfield sites. The area of restraint between Myton Road and Europa Way is a case in point. It is high grade agricultural land full of wildlife, ancient trees and hedgerows. Since 2000 Warwick has undergone a large increase in population (12%) which is approximately twice the rate of Warwickshire and the national average and three times the increase for West Midlands. The plan is not justified as it crams so much of the new development into the already congested south part of the district. This is because of pressure from developers who wish to build in the areas which afford them most profit. Roads and schools in this area are already under pressure.
The plan is creating more car dependant suburbs. Recent development at Warwick Gates has not justified bus services. It will also contribute to the already illegal air quality in central Warwick.
see attached
Gwrthwynebu
Publication Draft
ID sylw: 66448
Derbyniwyd: 14/06/2014
Ymatebydd: Mr C Wood
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
The loss of Greenfield land is unsustainable.
The greenfield land that is planned to be destroyed is important both environmentally and agriculturally.
Impacts on Air Quality and on Health have not been satisfactorily assessed.
Existing poor air quality areas in the town centres will continue to suffer dangerous levels of pollution, and the suggestion that this will in time be eliminated by changes in technology is, as the air quality report itself states, dubious.
I wish to object to the New Local Plan on the grounds that it is (still) unsound.
Specifically the issues that concern me are, and that I have raised previously in one form or another:
1. The overall Housing Need Forecast of 12,900 homes is exaggerated.
It is a forecast based on projections and assumptions, not on evidence. Fewer than 6,000 new homes would meet both natural growth and any likely reduction in household size.
The Plan period of 18 years, 2011-29, is longer than the 15 years required by the NPPF. The Office of National Statistics' itself advises against extrapolating them beyond 2021.
There is no need to provide in full now for what only may happen in the late 2020s, or never, the consequence of which is the allocation now of huge greenfield sites that may never be needed.
2. The loss of Greenfield land is unsustainable.
The greenfield land that is planned to be destroyed is important both environmentally and agriculturally.
3. The Transport Strategy is ineffective and unsustainable
The proposed large-scale use of greenfield sites, outside the urban area and at suburban densities, would make the new housing estates car-dependent. Peak hour congestion would increase from its already unacceptable level, to the detriment of all road users, the urban environment, and town centre economies.
The transport strategy is incomplete and inconclusive. It would be irresponsible to approve the Plan at this stage without understanding its full implications for traffic and transport.
4. Impacts on Air Quality and on Health have not been satisfactorily assessed.
Existing poor air quality areas in the town centres will continue to suffer dangerous levels of pollution, and the suggestion that this will in time be eliminated by changes in technology is, as the air quality report itself states, dubious.
I also support the Warwick Society's representations over the unsoundness of the plan.
Cefnogi
Publication Draft
ID sylw: 66466
Derbyniwyd: 27/06/2014
Ymatebydd: Gladman Developments
Asiant : Stansgate Planning
Policy directs 1,330 dwellings to brownfield sites within the urban areas of the district's settlements, 850 dwellings to greenfield sites on the edge of Kenilworth, 3,245 dwellings to greenfield locations on the edge of Warwick, Leamington and Whitnash, and 763 dwellings to sites within the districts Growth Villages and rural area.
LP explains proposed spatial strategy aims to meet housing needs by allocating sites across towns and in more sustainable villages. Seeks to maximise use of brownfield land by directing allocations to pd sites in urban areas first, bring forward greenfield sites where these are in sustainable locations, and avoid coalescence between settlements. Sets out that Green Belt sites will be limited to locations where exceptional circumstances can be justified.
Policy Analysis
Generally supportive of distribution strategy. Growth should be directed to key towns and villages with established services/facilities, ensuring creation of sustainable communities that have good access to range of jobs, community facilities, key services and infrastructure. However should not overlook need for further development in lower order sustainable settlements that could help to sustain existing services/facilities. Submit that further growth should be directed to identified Growth Villages, particularly in light of need to provide for a higher level of homes than currently proposed through LP.
Support identification of Radford Semele as location for further sustainable growth. As one of the Growth Villages, Radford Semele is one of the larger villages in the authority area with a population of nearly 2,000 and just over 800 dwellings. Village benefits from good range of local services/facilities,and from good public transport links to both Leamington Spa and Southam, where a wider range of employment opportunities and facilities are available.
Whilst supporting the decision to identify Radford Semele as a Rural Service Village, object to level of development proposed to be directed to the settlement. Previous LP Village Housing Options and Settlement Boundaries Consultation identified the village as an appropriate location to receive an allocation of 100-150 dwellings, but this has now been reduced to 50 dwellings consistent with proposed allocation North of Southam Road. Strongly submit there is no robust justification for this change in policy stance. The Council's May 2013 Draft Settlement Hierarchy Report identified Radford Semele as appropriate location to receive 100-150 dwellings. There is no basis for this figure to now be reduced based on the capacity of the North of Southam Road Allocation.
Radford Semele is not washed over by Green Belt or any other landscape designations. Although its development is constrained by an Area of Restraint that seeks to prevent the coalescence of the village with neighbouring urban areas, it is less constrained than other settlements and has ability to support further development. Although aware that further work has been undertaken to assess sensitivity of the landscape around the village to further development, submit that there are no justifiable reasons that would preclude Radford Semele from accommodating further sustainable development that could come forward in the short term to meet the district's housing needs. Submit that development targets for the village should be increased to at least 180 dwellings.
Would be opposed to re-use of previously developed land if this would preclude development from coming forward on sustainable greenfield sites. Whilst §111 of the Framework states that planning policies should encourage effective use of land by re-using land that has previously been developed, it does not state that brownfield development should be prioritised.
Conclusions on Soundness
Generally supportive of proposed distribution strategy, Growth Villages, particularly in light of the need to provide for a higher level of homes in the district. Whilst supporting identification of Radford Semele as a location for further growth, submit that there is no justifiable basis to now reduce level of residential development to be directed to the village.
6.1.9 There is no reason why Radford Semele cannot accommodate further sustainable development that could come forward in the short term. In this regard we submit that the housing targets for the village should now be increased to at least 180 homes.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66502
Derbyniwyd: 27/06/2014
Ymatebydd: Whitnash Town Council
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Majority of the houses (+-4655) are situated south of the River Leam. Not an appropriate distribution, and is unfair.
Population projection out of date, which substantially affects dwelling requirements. Mid 2012 projections show 28.7% reduction
in population expected by 2029 and this is a significant material change.Plan is unsound and does not meet NPPF requirements.
Address issues before submitting for examination
Gwrthwynebu
Publication Draft
ID sylw: 66505
Derbyniwyd: 27/06/2014
Ymatebydd: Friends of the Earth
Nifer y bobl: 4
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
numbers as they are clearly linked to proposed policy DS6.
We still believe that the average housing densities on new development sites can be increased significantly without a reduction in design quality. Paragraph 47 of the NPPF clearly says 'local planning authorities should... set their own approach to housing density to reflect local circumstances'. In our view, Warwick District Council has not yet explained their 'approach to housing density'.
see attached
Gwrthwynebu
Publication Draft
ID sylw: 66609
Derbyniwyd: 27/06/2014
Ymatebydd: Richborough Estates Ltd
Asiant : Strutt & Parker
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
The identification of 850 new homes on Greenfield sites on the edge of Kenilworth within Policy DS10 is not considered sound when considering the need to allocate additional land to ensure sufficient flexibility in housing delivery and the proposed amendments advocated by the representation to Policy DS11 outlined below. Policy DS10 could be made sound by increasing the number of new homes to be provided on the edge of Kenilworth through the allocation of the land controlled by Richborough at Warwick Road.
see attached
Gwrthwynebu
Publication Draft
ID sylw: 66680
Derbyniwyd: 27/06/2014
Ymatebydd: Save Warwick
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
The loss of Greenfield land is unsustainable. As only 8100 houses are needed over the plan period this can be met from permissions already granted together with the brown field sites identified in the plan. Greenfield sites are remote from schools, shops and other services and it has not been demonstrated that proposals for transport are going to be practicable/ effective. Much of this land (south of Warwick and Leamington in particular) is high grade agricultural which we cannot afford to lose.
The Plans Greenfield allocations are excessive and unnecessary as higher densities (using less land) will be attainable on previously developed/ brownfield land. The garden suburbs are extravagant; their low densities mean more land than what is necessary is being allocated for development.
See attached
Cefnogi
Publication Draft
ID sylw: 66694
Derbyniwyd: 27/06/2014
Ymatebydd: Mr Michael Kelsey
Support the retention of green belt to the north of Leamington and the focus on development to the south of the towns thereby supporting business and making best use of existing infrastructure.
see attached
Gwrthwynebu
Publication Draft
ID sylw: 66708
Derbyniwyd: 27/06/2014
Ymatebydd: Barwood Strategic Land II Limited
Asiant : HOW Planning LLP
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
Notwithstanding this support, Barwood reiterate paragraph 17 of the Framework which states that Local Planning Authorities should actively manage patterns of growth and focus significant development in locations which are or can be made sustainable. Additionally, the Framework states the supply of new homes can sometimes be best achieved through planning for larger scale development, such as new settlements or extensions to existing villages, which follow principles of Garden Cities.
Allocation of The Asps site would be consistent with the Council's spatial strategy,
furthermore The Asps offers the potential to deliver a Sustainable Urban
Extension.
See attachment
Gwrthwynebu
Publication Draft
ID sylw: 66724
Derbyniwyd: 27/06/2014
Ymatebydd: Stephen Trinder
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
Vehemently object to a proposal which is not as yet part of the Draft Plan but which has been proposed with just days to spare by Lynnette Kelly, prospective Parliamentary Labour MP for Leamington Spa and Warwick at the next general election.
Not sure that I'm able to object to something that's not yet officially - and I believe deserves never to be - part of the Draft Plan.
Objections to the soundness of Kelly's proposals are summarised below:
Positively Prepared
"This means that the Plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development."
"Objectively Assessed Development"
Any possible amendment from Lynnette Kelly to the WDC Local Plan 2029 i.e.5000 houses on King's Hill on the WDC-Coventry boundary could not, as of June 2014, be positively prepared because:
There appear to be no current objectively assessed development and infrastructure requirement figures behind Kelly's proposals at the time she made them (late June 2014), and nor could there be.
With new ONS figures still under scrutiny, initially appearing to show lower figures for population increase in the WDC area than forecast, then Kelly's housebuilding proposals of 5000 houses for King's Hill could not possibly be based on a sound basis of need.The figures were still in flux.
No figures for infrastructure requirements and how they impact on her proposals appear to have been made.
Kelly's proposals also appear not to meet a neighbouring authority's unmet requirements, i.e. Coventry's. No suggestion that the boundary of Coventry be extended to include the new houses - indeed, Coventry's intervention in the whole affair was to offer to sell the land at King's Hill (currently owned by Coventry) to Warwick.
At no time was Kelly's call to move the 5000 Warwick houses to King's Hill presented as assisting a neighbouring authority. These would be Warwick houses.
WDC Plan, on the other hand, is sound and has been positively prepared, based as it is on has been objectively assessed development and infrastructure requirements. New ONS figures appear to show lower figures for population increase in the WDC area than were initially forecast if anything suggest a need for fewer dwellings needed to be built in the WDC area over the Plan period.
No objective justification whatsoever for a wholesale unloading of 5000 housing units onto the edge of a neighbouring authority.
Achieving Sustainable Development"
The Kelly 5000-house to King's Hill transfer also makes a mockery of sustainable development because:
The proposed site, sits within yards of one of the thinnest greenbelts in the West Midlands and this whole area already faces massive turmoil and destruction from HS2. Construction traffic for King's Hill would, unbelievably, share narrow roads with that for HS2.
Traffic to and from the regionally vital University of Warwick, which injects £222 million-a-year into the local economy, already snarls up the same B-rated Stoneleigh Road that 4000-odd cars would disburse onto from Lynnette's proposed King's Hill mega-estate.
Construction of a new, dedicated A46 access point for the site would entail colossal delays and expense, on top of the Kenilworth Bypass closures already scheduled during HS2 construction.
Over 4000 local people (from 1931 households canvassed) signed a petition against just 3500 houses on this exact location when they were proposed in 2009. Resistance remains extremely strong.
Justified
"The Plan should be the most appropriate strategy when considered against reasonable alternatives, based on proportionate evidence."
The Kelly proposal is not based on proportionate evidence, and is not the most appropriate strategy when considered against reasonable alternatives. She has no up-to-date ONS figures to show a need for Warwick DC houses in King's Hill, there is no sustainable transport plan, takes no account of the turmoil and considerable destruction this area is already scheduled for from HS2 from 2017 onwards, and neglects to consider that many of the roads construction traffic for King's Hill would clog are already HS2 construction-traffic routes.
Not the most appropriate and reasonable strategy, but are a political move.
Effective
"The Plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities."
Consistent with national policy:
The King's Hill site is not a solution which supports reductions in greenhouse gas emissions, reduces congestion, or facilitates the use of sustainable modes of transport. Reservations were made in 2009 about the ability of the site to achieve sustainable modes of transport.
With this route now scheduled for far greater use as part of the Electric Spine electrified railfreight line from Southampton to Nuneaton and thence to the North, it is unlikely that many slow, stopping trains could stop at a halt at the King's Hill development and no suggestions for such a rail line have even been included.Most of the 5000 house-dwellers on King's Hill would thus be expected to be car users, making this a wholly unsustainable transport site.
Most traffic to and from the site would be expected to use the A46, effectively an M road, the lack of opportunities for sustainable transport mode use would increase the pressure for new major transport infrastructure near and around the settlement.
Greatly increased traffic from King's Hill would further snarl up traffic along the B-rated Stoneleigh Road, which is used by very heavy numbers of Warwick University commuters going to and from their work, visits and study to the University.
The lack of sustainable access would greatly increase the need for new and widened traffic infrastructure on and around the site - such as a new southern relief road off the A46.
A Transport Statement or a Transport Assessment" has not yet been advanced.
As Kelly is proposing the King's Hill site as a Warwick settlement in WDC's area, her proposals run foul of NPPF Section 34's recommendations. New Warwick and Leamington Spa housing constructed in the vicinity of these settlements would better satisfy this advice. Warwick and Leamington people moving to King's Hill would need to commute back to these towns to work and burden an already extremely busy A46 Kenilworth Bypass as well as heavily used smaller roads
Most of the traffic from the King's Hill site would need to disburse onto and come off the A46 Kenilworth Bypass. This is, in effect, an M-road and unused by pedestrians, cyclists and bus services. The site would not, and cannot, have pedestrian, cycle, and high quality public transport facilities along its principal means of access and egress, the A46.
Lack of pedestrian footpath along Stoneleigh Road.
As the King's Hill settlement is proposed by Kelly as a Warwick settlement, the movement of largely Warwick people to and from a site eight miles from their normal jobs, friends, places and routines runs completely counter to a planning policy guided by Section 37.
The Kelly proposals of increasing the number of houses proposed from the 3500 under a previous proposal, which incorporated community parks, to 5000, which presumably would have far less area available hardly constitutes an attempt to "evolve designs that take account of the views of the community."
5000 houses on the King's Hill site, rather the 3500 discussed in 2009, would make delivery of shared space and community facilities, most especially parks, that much harder, if not impossible.
Density of the King's Hill site under Kelly's 5000-house suggestion would make NPPF recommendation very hard to achieve.
Building 5000 houses at King's Hill would run a coach and horses through points 1,2,3, and 4 of NPPF Section 80.
The setting and character of Kenilworth would also be damaged by King's Hill as it sits on an elevated position, giving views to and from Kenilworth and Coventry.
Putting 5000 Warwick District overspill houses on King's Hill would not retain or enhance King's Hill's landscape, its visual amenity or its biodiversity.
There are no 'very special circumstances'.
The King's Hill houses satisfy none of the criteria listed as acceptable for greenbelt building.
The landscape is valued by the people who signed a petition against possible construction of houses on this site in 2009. Placing 5000 houses, with little room for community sites or parks on elevated ground like this is not enhancing or protecting a valued landscape.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66740
Derbyniwyd: 27/06/2014
Ymatebydd: Mr Edward Walpole-Brown
Asiant : Brown and Co
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
In site selection this has not been adequately taken into account, in particular the relationship between sites at Hatton Green and Hatton Park
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66743
Derbyniwyd: 27/06/2014
Ymatebydd: Mr Richard Brookes
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
The level of growth is too high. Since the publication of this Draft new ONS projections show that population growth between 2011 and 2029 is 15,300 compared with the joint SHMA figure of 23,800.
This error is compounded by the Joint SHMA using a Household Headship Ratio of 1.66 people per dwelling. If the ratios and sizes of affordable and market homes are taken into account this ratio should be 2.12. If this is applied to the new population projection this gives a housing requirement of 7,700. If the ratio of 1.66 is used this gives a requirement of 9,300.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66745
Derbyniwyd: 27/06/2014
Ymatebydd: Mr Edward Walpole-Brown
Asiant : Brown and Co
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Insufficient regard has been given to the needs of sites within the rural areas to make sure key objectives of the plan can be satisfied in terms of the quantum of growth and ensure sustainable communities can be improved and services provided and retained
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66781
Derbyniwyd: 27/06/2014
Ymatebydd: Bishop's Tachbrook Parish Council
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
This does not take account of previous years oversupply; completions to date; sites under construction; vacant dwellings already returned; permissions not started; further permission between April and December 2013; offices to residences approved; windfall sites for the plan period; small urban sites on SHLAA sites and consolidation of existing employment areas and canal side development. This means that if the housing numbers identified as needed by a revised approach on population numbers and the conversion method to number of dwellings then no further applications need to be granted to meet the plan as there is already a surplus provision.
If the maximum figure for the reduced population projection figure of 9,217 is considered to be necessary, then to this list can be added allocated urban brownfield sites definites only; 2 greenfield sites in urban locations; 4 sites accepted in villages and 6 sites granted since January 2014 can be added giving 9,601 dwelling sites.
The reduced population projection and the related reduction in the number of houses required now means that the use of any further greenfield sites cannot be demonstrated to be necessary and those should be removed from DS11.
Grove Farm at 200 dwellings, future vacant dwellings return and a list of 543 C2 homes for the elderly can also be counted in the supply. With these it would not be necessary to keep the sensitive urban brownfield and sensitive greenfield in DS11.
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029
Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 1.
1. In responding to this consultation, the Parish Council emphasises that its sole interest is to help devise a Local Plan that is positively prepared, justified, effective and consistent with national policy, complying with the National Planning Policy Framework and the Planning Practice Guidelines published in March 2014.
2 It is our belief however that draft Local Plan is not sound in a number of aspects.
But over-riding all the matters is the fact that because the plan is based on the joint SHMA, it was only able to use the mid-2011 ONS Population Projections when it was prepared.
On the 29th May 2014, the ONS published the mid-2012 population projections. As we indicated to you at the Planning Forum before the publication draft was approved by the District Council on April 23rd, the new projections show a very significant reduction in population projection for the plan period up to 2029.
3. National planning policy places Local Plans at the heart of the planning system, so it is essential that they are in place and kept up to date. PPG12-001, NPPF157 * 2.
To start a new Local Plan based on outdated data cannot be seen as a sound plan and an Inspector will have to conclude that procedural requirements have not been met and question whether the Plan is sound.
For Warwick District, the joint SHMA uses for Proj 1A a population growth of 23,858 over 20 years, this being 21,472 over 18 years. The mid-2012 ONS projection for 2029 is 153,049, which is a population growth of 15,313 from mid 2011. This is 28.7% less than the Joint SHMA.
This is a very significant change since, amongst other things, it
* Changes the number of dwellings to meet local need
* The lower population will need commensurately less infrastructure support, optimising the use of capacity in existing infrastructure
* Changes the emphasis on the selection of sites for new housing
* Allows brownfield and regeneration sites to be committed before greenfield sites meeting NPPF112 and PPG8-026 and this also places less pressure on Green Belt.
* Can provide a deliverable plan rather than a plan that is too ambitious and unrealistic in the period of the plan
The new projections indicate that 8,343 persons are due to natural change; movement between Warwick District and the rest of the UK account for 5,971 net inflow and International migration shows a net inflow of 999 persons over the plan period.
Further detail is given in Appendix 1 pages 1 to 7.
Until the population targets are revised to the latest projections, the plan cannot be considered ready for submission to Inspection.
Explanation paragraph 2.7 in relation to DS2 commences by saying "The Council's ambitions align with national policy in recognising that housing needs are met for all. "
The parish council agrees that housing needs identified in the district based on up to date population projections should be met, but that the ambitions of the district must also be realistic. Planning practice Guidance on the definition of need, advises that
PPG: 2a-003 "Assessing development needs should be proportionate and does not require local councils to consider purely hypothetical future scenarios, only future scenarios that could be reasonably expected to occur." Ensuring that there is a supply of sites for new housing is clearly necessary with affordable housing and housing that can be afforded being an important part of the plan.
But it is also important to comply with NPPF 157 Crucially, Local Plans should:
* plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework;
* identify land where development would be inappropriate, for instance because of its environmental or historic significance; and
* contain a clear strategy for enhancing the natural, built and historic environment, and supporting Nature Improvement Areas where they have been identified.
The projected population increase of 15,313 people will clearly require employment opportunities but it is also important to balance the jobs/homes ratio so that the current ratio, generally regarded as good, is maintained.
4.1 The plan has to be prepared in accordance with the Duty to Cooperate with Neighbouring authorities. This has been accomplished through a joint SHMA. The mid-2012 ONS Population projection has had a similar result for the Warwickshire Districts. There is however a possible problem with the Coventry result.
4.2 This table summarises the revised population growth and the number of dwellings resulting from the same dwelling density as the Joint SHMA. The joint SHMA identified a need for 67,536 homes. The revised projections now identify 68,152 homes.
Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 74,796 36,168 +70.4%
TOTAL HMA 123,882 67,536 129,751 68,152 +4.7%
4.3 Coventry's 2011 ONS population was 316,915 and is projected by 2029 to be 391,711. This is an increase of 74,796 over the plan period. This is made up from
* The net effect of natural change which accounts for 50,734 people by 2029.
* The net effect of people moving in and out of Coventry from other parts of the UK is a net outflow of 50,592 over the plan period.
* The net effect of international migration is an inflow of 74,654 over the plan period.
However, analysis of the numbers of people in single age groups for each year from 2002 to 2029 identifies two problems with this projection.
The first is that the 2 universities currently have about 13,500 international students. Most Coventry students and many Warwick University students live in Coventry. Looking at the 17 to 20, 21 to 24, 25 to 29 and 30 to 34 age groups it was found that there was in increase in these cohort numbers of International inflow from 2005 but not a corresponding outflow. Between 2002 and 2004 the net inflow was between 3400 and 3700. From 2005 inflow increased in significant steps to 7700 by 2011. In younger and older age groups the numbers remained fairly constant for the whole period. This reflected a time when universities sought to increase international students.
There was not a corresponding change in international outflow until 2009 to 2011 but the volume of the outflow was less that the volume of the inflow 3 years earlier. This indicates that the increase in inflow may be due to international students on courses that are not yet completed.
The problem for the population projection is that the higher inflow is reflected in the population projections because it takes the 6 year average from 2007 to 2012 with the higher numbers, but a related outflow at the completion of courses has not yet begun except at a lower level. It would be expected that as courses and related academic activities for each student came to an end then the outflow would approach the previous level of inflow. Hence the projection for outflow on the same 6 year average is based on a low level. This represents a temporary student bulge that in the course of time should rectify as student turn over numbers give equating inflows and outflows.
The 2002 to 2004 net inflow was between 1000 and 2000 per year, but by 2011 and 12, this had become over 5,000 per year.
In the meantime this gives an overall increase of 74,654 due to international migration over the 18 year plan period. It does not make sense to plan to build homes for a population that is theoretical and will not be there.
If the student bulge is factored out by relating student age groups to the younger and older age groups to estimate the possible non-student element, this indicates that the total number of 74,654 will fall to between 25,000 and 40,000 depending the averaging method used. Without any other detail data this is the closest estimate that can be given. Take the worst case of 40,000 inflow due to migration, then this is still lower than the migration inflow in the Joint SHMA of 43,884.
Hence, Coventry would still have a reduced requirement over the JointSHMA of almost 9%, which would indicate that Coventry is unlikely to seek to ask neighbouring authorities to meet its housing need.
The table below shows the result.
Population increases JSHMA ONS-2012 projection Population % change
population homes population homes
North Warwickshire 4,074 2,970 3,038 2,218 -25.4%
Nuneaton & Bedworth 16,380 8,892 12,395 6,736 -24.3%
Rugby 23,706 11,844 14,360 7,176 -39.4%
Stratford-on-Avon 14,364 9,684 9,848 6,636 -31.4%
Warwick 21,474 12,924 15,313 9,217 -28.7%
Coventry 43,884 21,222 40,000 19,344 -8.85%
TOTAL HMA 123,882 67,536 94,954 51,327 +4.7%
4.4 Further detail is given in Appendix 1 pages 12 to 16.
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029
Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 2.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS6
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure the Inspector is fully aware of the implications of the method by which the 2012 population projections are converted to the number of dwellings required in the plan and that a fully justified housing need is objectively assessed.
___________________________________________________________________________
DS6 states that the District will provide 12,860 homes over the plan period. This has to relate to the population projection that the up to date assessment of population growth determines.
This number needs to be revised to comply with the reduction in population growth now known.
To convert population to homes, the JointSHMA used an abstract concept of Headship rates, based on information contained in the 2011-based CLG household projections about the relationship between the total population in an age group and the number of household reference persons (HRPs) in that age group. But this is only true at the time the data is taken. HRP's can be any age and are mobile. It can only be a subjective and not an objective assessment.
It is critical because small changes in the average household size can alter homes required significantly. The JointSHMA bases its chosen headship rate on an arbitrary split between 2008 and 2011 headship rates.
It also bases its average household size on the total population. This gives an incorrect result. ONS calculate the population estimates and projections on the total population less those living in communal establishments adding these back into the total population at the end of any calculation. This gives a true average household size which is different to the SHMA household size and varies the relationship between areas as each has a different communal proportion.
If the population less communal residents is added to the Joint SHMA plan,, the 2029 population becomes 156,150 plus communal. The combined dwellings total 71,603 and the resultant household size is 2.181.This is a very low figure compared with the 2011 census.
Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 21,472 = 156,150
dwellings 58,679 + 12,924 = 71,603
Persons/household 2.295 = 2.181
If the population growth is going to be less, then the household size to use needs to be addressed.
The following options could be considered -
a) If the population of 15,313 is substituted in to the table above so that the household size in 2029 remains as 2.181, then 10,100 would be needed.
b) Proportionately, the revised population growth would require 9,217 homes producing an average household size of 2.209.
c) Using census data for 2001, the average household size excluding communal was 2.32. But the 2011 size was 2.295. If the size dropped at the same rate in the next 18 years it would become 2.245. If this is used for the revised population projection, the calculation becomes
Add the existing and new populations together 2011 census including growth to mid-2012 18 year plan 2029 projection
population 134,678 + 15,313 = 149,991
dwellings 58,679 + 8,118 = 66,797
Persons/household 2.295 = 2.245
d) However, there is no evidence that says that any drop in household size will be at the same rate. The closer that the size gets to 1, the slower will be the reducing rate of change. If the 2011 census rate of 2.295 prevails then 6,715 homes would provide for 15,313 people.
e) Because the built home is normally constant, the size and tenure of a house, on average over time, is a better indicator of household size than the variable HRP. Given that we know from the 2011 census the number of people in the number of house of each tenure type, we have an up to date household size for each dwelling type, for example, the average household size for a detached house or bungalow was 2.585.
Further details are given in Appendix 1 pages 8 to 11 where a calculation for a typical development takes the 2011 census data for each dwelling type adds on the densities arising from Affordable homes that will be allocated to match families to the number of bedrooms they need and the market housing developers have selected the type they want to include in their development. From Page 10 in the appendix, in the example given, the average household size calculates at 2.325. So the likelihood is that the household size will rise rather than fall. If it should rise to 2.325 over the whole of the 2029 population, then only 5,785 homes will be required.
Two other factors will also affect future measures of household size. Over time as affordable homes are reallocated to existing occupants, vacant spaces will become occupied. For owner occupiers, as people find house prices unaffordable, rather than move they tend to stay where they are but extend their properties to accommodate extra children etc. So a calculated outcome can be used to provide the capacity in a lower but acceptable number of homes.
As well as being better in terms of providing the right tenure mix, it is also better from a sustainability point of view as it takes less land, avoids loss of agricultural land, is better from a CO2 emissions reduction viewpoint both from energy used in homes and travel from fossil fuel vehicles, reduces costs and makes all homes more affordable and spreads the homes required around the district, reducing the amount of infrastructure needed by the additional population. This is what the NPPF6 means by "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system. 7. There are three dimensions to sustainable development: economic, social and Environmental all of which should be achieved simultaneously."
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029
Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 3.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS4, DS7, DS10, DS11, NE5
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that in the selection of sites for development, compliance with all NPPF matters from provision of housing and infrastructure to protecting Green Belt, conserving the natural and historic environment is achieved.
___________________________________________________________________________
DS7 identifies 13,014 sites for a plan of 12860 homes. This has to relate to the population projection that the up to date assessment of population growth determines, so that this number needs to be revised to comply with the reduction in population growth now known.
DS7 lists sites completed between 2011 and 2013 as 406. This conflicts with a previously published number of 447 in the June 2013 % year housing land supply document.
It makes no provision for the following
1. As PPG3-036 no allowance has been made to deduct oversupply of 687 made in years previous to the start date of Apr 2011 when completions of 5,947 compared with the target was 5,260.
2. Completions of 450 in the 2013/14 financial year, listed in the rough update April 2014 is not shown.
3. No allowance is made for completions since 1st April 2014.
4. An up to date assessment of sites under construction is not included.
5. No allowance has been included for vacant dwellings returned to use since1/4/11 to date, as reported to DCLG and upon which new homes bonus has been received by the District.
6. No allowance for vacant dwellings being returned to use through the remainder of the plan period has been included.
Explanation 2.22 states that the balance of housing outside of DS7 is to be provided on allocated brownfield and greenfield sites across the District. Reference is made to DS4.
Policy NE5 Protection of Natural Resources para d) includes reference to NPPF112 concerning best & most versatile agricultural land. It is a somewhat watered down version of NPPF112 that requires LPA's to take into account the economic and other benefits of the b&mv ag land. Even where significant development of b&mv ag land is identified, it has to be demonstrated that it is necessary and seek to use poorer quality land in preference to it. Explanation clause 5.198 expands NE5d) satisfactorily until it gets to the last few lines where it alters the sense of NPPF112 with a less stringent condition requiring any lower grade land to be excused if it has adverse sustainability impacts such as ...... sustainable patterns of development. This last phrase could mean anything to a developer. It may well explain why NE5 conflicts with DS11 where the Local Plan includes a significant number of sites as a first call for the housing required, before brownfield and urban regeneration sites have been fully examined.
Explanation 2.23 states that the housing strategy shows a timeline for the delivery of housing across the plan period. The housing trajectory is unexplained and shows annual targets that are unlikely to be met. For a trajectory to be achieved, it should be site related so that as sites are approved they can be included in the trajectory correctly and confidently. 2014/15 is supposed to deliver over 1,000 homes but as yet none of the large sites have commenced.
DS4 Spatial Strategy contains statements that are not being observed.
a) in the first instance, allocations will be directed to previously developed land within urban areas. If this is the case why have 5 major sites been approved in advance of any (except for affordable homes on Queensway) previously developed land within the urban areas? Regeneration and enhancement sites remain to be identified in principle let alone activation. The strategy is right, but its needs to be fully implemented.
b) greenfield sites will not need to be identified for housing because the revised population projection shows that the number of homes have either already been built, permission granted, allocated without involving greenfield or green belt for up to 10,100 homes, more than is now known to be required.
DS10 and DS11 sets out a list of allocated housing sites.
Taking these lists and the current programme position, the sites have been listed in appendix 2. This appendix shows that 8,482 sites have been identified as -
1. Previous years oversupply; completions to date; sites under construction; vacant dwellings already returned; permissions not started; further permission between April and December 2013; offices to residences approved; windfall sites for the plan period; small urban sites on SHLAA sites and consolidation of existing employment areas and canal side development.
This means that if the housing numbers identified as needed by a revised approach on population numbers and the conversion method to number of dwellings up to 8482 dwellings for this set of supply categories , then no further applications need to be granted to meet the plan as there is already a surplus provision. This applies to options c), 8,118 d), 6,615 & e) 5,785 in Representation 2 from Bishop's Tachbrook Parish Council.
If the maximum figure for the reduced population projection figure of 9,217 is considered to be necessary, then to this list can be added allocated urban brownfield sites definites only; 2 greenfield sites in urban locations; 4 sites accepted in villages and 6 sites granted since January 2014 can be added giving 9,601 dwelling sites.
The reduced population projection and the related reduction in the number of houses required now means that the use of any further greenfield sites cannot be demonstrated to be necessary and those should be removed from DS11.
2. This applies to the following sites (See also APPENDIX 2)
Land west of Europa Way
East of Whitnash/south of Sydenham
Campion hills
East of Kenilworth (Thickthorn)
Both Kenilworth School sites.
All villages except Bishops Tachbrook, Barford and Radford Semele
Land south of Harbury Lane, including the former sewage works which is wrongly classified under Urban Brownfield sites. In any event this is a valuable green part of the Tachbrook Valley with a significant range of ecological biodiversity implications, a series of deep tanks across the site that would make any development difficult and a slope across the site which at the proximity of the Tach Brook turns into a steep slope. It is well planted and supports a number of mammals. Otters are known in the brook.
The photo below shows the former sewage works. This is not urban brownfield.
3. The list also shows
* Grove Farm at 200 dwellings which is currently subject to appeal after refusal,
* future vacant dwellings return and
* a list of 543 C2 homes for the elderly, all of which can be counted towards the housing supply in accordance with PPG3-037.
037 How should local planning authorities deal with housing for older people?
Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.
With these it would no longer be necessary to keep the sensitive urban brownfield and sensitive greenfield shown at the end of appendix 2 in DS11.
So the 3 Kenilworth sites, land west of Europa Way and East of Whitnash/ south of Sydenham do not need to be included.
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029
Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact. Councillor Ray Bullen
Representation 4.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DS13
5. Do you consider the Local Plan is :
5.1 Legally Compliant? Don't know
5.2 Complies with the Duty to Co-operate? No
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that best and most versatile agricultural land is protected sufficiently to conserve and enhance the Natural Environment
___________________________________________________________________________
DS13 allocates grade 2 and 3a agricultural for the development of a country park as part of the offsetting of the housing development proposed south of Harbury Lane.
Now that the 2012 population projections show that land south of Harbury Lane is not necessary for housing development, this area of land should also remain as agricultural land. This is particularly important as it an essential part of the Tachbrook Valley and can be seen from long distances across the valley.
As part of the duty to cooperate, the District Council should work with the Parish Council, as we prepare our Neighbourhood Plan and in accordance with Policy NP2 stating that the Council will support communities preparing Neighbourhood Plans.
The developing Neighbourhood plan seeks to retain the agricultural economy of the land between Harbury Lane and the Tach Brook but at the same time open the area up in a limited way with a brookstray walk and habitat improvement for wildlife possibly through an extended Defra/ Natural England Stewardship scheme and a Local Greenspace designation over those stewardship areas. This could achieve the objectives in Explanation paras 2.57 but not commit to the expensive country park concept.
We doubt that the £1.5m needed to set up a Country Park, which will require car parks and facilities for the public, becoming urbanised and less friendly to wildlife, will be available nor can we see the expensive continual maintenance being affordable from reducing Council budgets. Hence we cannot see the Country Park will materialise.
Bishop's Tachbrook Parish Council Response to Warwick District Council Publication Draft Local Plan 2011 - 2029
Submitted on behalf of Bishop's Tachbrook Parish Council,
Contact.
Representation 5.
4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?
Policy Numbers DM1
5. Do you consider the Local Plan is :
5.1 Legally Compliant? No
5.2 Complies with the Duty to Co-operate? Yes
5.3 Sound? No
6. If you answered no to question 5.3, do you consider the Local Plan and/or SA unsound because it is not: (please tick that apply):
Positively Prepared: √
Justified: Effective: √
Consistent with National Policy: √
9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? Yes, I wish to participate at the oral examination.
10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To ensure that the Local Plan has been prepared to a realistic level that can be supported by adequate income from developments CIL and other government payments such as new homes bonus to ensure that the additional infrastructure necessary to accommodate the increased population of 15,313 people
___________________________________________________________________________
It is an important part of the local plan that the necessary infrastructure required to support the additional population has been fully identified , addressed in the plan as to where and how it will be delivered and that the costs have been assessed and a financial plan for their delivery determined.
An independent assessment of the plan for 12860 homes has been carried out by professionals concerned that this aspect is not properly covered, since the result of an inadequate financial plan would mean the necessary infrastructure is not provided or that it has to come from other source which the current inhabitants will have to meet the cost of.
DM1 says it will happen but there does not appear to be a plan in place to ensure that it does. If this is the case, then the inspector, who will have to ensure that such a plan is in place, will find that it doesn't and the plan will be found unsound.
However the amount of infrastructure necessary will depend on the population to be planned for, the housing numbers necessary to meet that need and the location of housing.
Across the district currently, much of the infrastructure is fairly fully stretched. Major items such Education, Hospitals and road networks are heavily utilised. But there are parts where there is some spare capacity that new developments can utilise.
If the housing needed is spread around the district, then some of the existing infrastructure can take up the spare capacity and in some ways that can be a good thing. But large amounts of new housing are concentrated in one place then large amounts of new infrastructure cannot be avoided.
For the 12,860 homes plan, our independent assessment indicates that the costs of the infrastructure required will be between £30m to £50m more than the income that will be received from section 106, CIL(when it applies), new homes bonus and other sundry incomes. This is on the assumption that the infrastructure costs are capital costs and that the revenue running costs will be met from income generated from Council tax and similar receipts.
In our assessment we have included the costs of road traffic schemes due to high concentrations of new traffic in underprovided areas, Health and hospitals, Education, sports facilities, recreational facilities , cultural and community , police and emergency services as well as parking provision for the additional users of the towns. All this additional infrastructure will require sites upon which to place the facilities and these had not been selected nor has any land acquisition cost been included.
It will be appreciated that doing this exercise from outside the authority, much of the detail necessary is not available and it is dependent on published information from the District Councils website as to the amounts of payments so far agreed with developers on the early schemes.
Although the plan is for 12860 homes, many of these will not be paying contributions because they have been approved in advance of the programme, are affordable homes so will not be liable for payments and are part of small schemes for which 106 payments are not sought.
We find compared with an expenditure of in the region of £230m income that will be recovered to pay for those costs will be about £190m, leaving £50m unfinanced.
If the reduced population now known is taken into the plan then much of the infrastructure listed will cease to be required, because the sites are already known and are well distributed around the district. Some elements are population number dependent but lower numbers mean a smaller impact on them.
Depending on the housing number decided the assessment will to be reworked. Until thenthe plan does not have a sound infrastructure cost strategy.
Assessing development needs should be proportionate and does not require local councils to consider purely hypothetical future scenarios, only future scenarios that could be reasonably expected to occur.
Paragraph: 037 Reference ID: 3-037-20140306
Cefnogi
Publication Draft
ID sylw: 66829
Derbyniwyd: 27/06/2014
Ymatebydd: Europa Way Consortium
Asiant : AMEC
The Consortium supports the Council's decision to direct most new development to sites within, or to the edge, of main towns within the District, namely Leamington, Warwick, Whitnash and Kenilworth.
see attached
Gwrthwynebu
Publication Draft
ID sylw: 66842
Derbyniwyd: 03/07/2014
Ymatebydd: Patricia Hollis
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
The loss of Greenfield land is unsustainable. As only 8100 houses are needed over the plan period this can be met from permissions already granted together with the brown field sites identified in the plan. Greenfield sites are remote from schools, shops and other services and it has not been demonstrated that proposals for transport are going to be practicable/ effective. Much of this land (south of Warwick and Leamington in particular) is high grade agricultural which we cannot afford to lose.
The Plans Greenfield allocations are excessive and unnecessary as higher densities (using less land) will be attainable on previously developed/ brownfield land. The garden suburbs are extravagant; their low densities mean more land than what is necessary is being allocated for development.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66906
Derbyniwyd: 03/07/2014
Ymatebydd: Colin Sharp
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The loss of Greenfield land is unsustainable. As only 8100 houses are needed over the plan period this can be met from permissions already granted together with the brown field sites identified in the plan. Greenfield sites are remote from schools, shops and other services and it has not been demonstrated that proposals for transport are going to be practicable/ effective. Much of this land (south of Warwick and Leamington in particular) is high grade agricultural which we cannot afford to lose.
The Plans Greenfield allocations are excessive and unnecessary as higher densities (using less land) will be attainable on previously developed/ brownfield land. The garden suburbs are extravagant; their low densities mean more land than what is necessary is being allocated for development.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66914
Derbyniwyd: 03/07/2014
Ymatebydd: Ms Alison Cox
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The loss of Greenfield land is unsustainable. As only 8100 houses are needed over the plan period this can be met from permissions already granted together with the brown field sites identified in the plan. Greenfield sites are remote from schools, shops and other services and it has not been demonstrated that proposals for transport are going to be practicable/ effective. Much of this land (south of Warwick and Leamington in particular) is high grade agricultural which we cannot afford to lose.
The Plans Greenfield allocations are excessive and unnecessary as higher densities (using less land) will be attainable on previously developed/ brownfield land. The garden suburbs are extravagant; their low densities mean more land than what is necessary is being allocated for development.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66922
Derbyniwyd: 03/07/2014
Ymatebydd: Alison Kelly
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The loss of Greenfield land is unsustainable. As only 8100 houses are needed over the plan period this can be met from permissions already granted together with the brown field sites identified in the plan. Greenfield sites are remote from schools, shops and other services and it has not been demonstrated that proposals for transport are going to be practicable/ effective. Much of this land (south of Warwick and Leamington in particular) is high grade agricultural which we cannot afford to lose.
The Plans Greenfield allocations are excessive and unnecessary as higher densities (using less land) will be attainable on previously developed/ brownfield land. The garden suburbs are extravagant; their low densities mean more land than what is necessary is being allocated for development.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66930
Derbyniwyd: 03/07/2014
Ymatebydd: Andrew Cliffe
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The loss of Greenfield land is unsustainable. As only 8100 houses are needed over the plan period this can be met from permissions already granted together with the brown field sites identified in the plan. Greenfield sites are remote from schools, shops and other services and it has not been demonstrated that proposals for transport are going to be practicable/ effective. Much of this land (south of Warwick and Leamington in particular) is high grade agricultural which we cannot afford to lose.
The Plans Greenfield allocations are excessive and unnecessary as higher densities (using less land) will be attainable on previously developed/ brownfield land. The garden suburbs are extravagant; their low densities mean more land than what is necessary is being allocated for development.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66938
Derbyniwyd: 03/07/2014
Ymatebydd: Angelo Cugini
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The loss of Greenfield land is unsustainable. As only 8100 houses are needed over the plan period this can be met from permissions already granted together with the brown field sites identified in the plan. Greenfield sites are remote from schools, shops and other services and it has not been demonstrated that proposals for transport are going to be practicable/ effective. Much of this land (south of Warwick and Leamington in particular) is high grade agricultural which we cannot afford to lose.
The Plans Greenfield allocations are excessive and unnecessary as higher densities (using less land) will be attainable on previously developed/ brownfield land. The garden suburbs are extravagant; their low densities mean more land than what is necessary is being allocated for development.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66946
Derbyniwyd: 03/07/2014
Ymatebydd: Barbara Groves
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The loss of Greenfield land is unsustainable. As only 8100 houses are needed over the plan period this can be met from permissions already granted together with the brown field sites identified in the plan. Greenfield sites are remote from schools, shops and other services and it has not been demonstrated that proposals for transport are going to be practicable/ effective. Much of this land (south of Warwick and Leamington in particular) is high grade agricultural which we cannot afford to lose.
The Plans Greenfield allocations are excessive and unnecessary as higher densities (using less land) will be attainable on previously developed/ brownfield land. The garden suburbs are extravagant; their low densities mean more land than what is necessary is being allocated for development.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66954
Derbyniwyd: 03/07/2014
Ymatebydd: Professor Bob Ireland
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The loss of Greenfield land is unsustainable. As only 8100 houses are needed over the plan period this can be met from permissions already granted together with the brown field sites identified in the plan. Greenfield sites are remote from schools, shops and other services and it has not been demonstrated that proposals for transport are going to be practicable/ effective. Much of this land (south of Warwick and Leamington in particular) is high grade agricultural which we cannot afford to lose.
The Plans Greenfield allocations are excessive and unnecessary as higher densities (using less land) will be attainable on previously developed/ brownfield land. The garden suburbs are extravagant; their low densities mean more land than what is necessary is being allocated for development.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66962
Derbyniwyd: 03/07/2014
Ymatebydd: Christopher Paden
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The loss of Greenfield land is unsustainable. As only 8100 houses are needed over the plan period this can be met from permissions already granted together with the brown field sites identified in the plan. Greenfield sites are remote from schools, shops and other services and it has not been demonstrated that proposals for transport are going to be practicable/ effective. Much of this land (south of Warwick and Leamington in particular) is high grade agricultural which we cannot afford to lose.
The Plans Greenfield allocations are excessive and unnecessary as higher densities (using less land) will be attainable on previously developed/ brownfield land. The garden suburbs are extravagant; their low densities mean more land than what is necessary is being allocated for development.
See attached