The original plan will be challenging to the local infrastructure without the further additional housing

WDC have not, in my opinion, based housing numbers on sound data. Their assumed population growth of 17% between 2011 and 2029 is higher than the Office for National Statistics published (May 2014) 2012-based population projections for England, which suggests population may grow by 15.1% in Warwick District between 2012 and 2037.

It is considered that the modifications still do not provide for sufficient land to meet the unmet need nor provide for adequate flexibility in meeting future need.

Whilst technically in a separate SHMA, Birmingham has substantial unmet need which must be fulfilled by surrounding Authorities.

Apart from the practical point of providing homes from which people can readily commute to their work (Coventry and Warwick being on prime commuter routes into Birmingham) the definition of SHMAs and other relevant Study Areas vary considerably as they try to reflect what actually 'happens on the ground'. It is believed that the Warwick Local Plan area,with Coventry, are inextricably linked to the wider Birmingham area and the provision of new homes should reflect the practical position.

Support the Modification to reduce numbers

Object to size of increase in total housing needs target following liaison with Coventry

Even though it purports to follow government guidance, the Strategic Housing Market Assessment (SHMA) is not independent and is seriously defective. It has considered only one side of the equation and only those with a vested interest in growth have influenced its findings. Population and household projections have been wrongly used as if they were forecasts. The assumption on headship rates is questionable and the study fails to get to grips adequately with economic issues, commuting, international migration, student needs and affordable housing. Above all, the SHMA acknowledges the high degree of uncertainty about the future but then plumps for a single figure of so-called Objectively Assessed Need (OAN) which is poorly justified. This figure is seriously lacking in credibility. [section 3]

The local authorities in their Memorandum of Understanding have misused the SHMA by adopting the so-called OAN uncritically and indeed adding to it. They have failed to consider whether environmental and other policy factors limit the ability of the area to meet its housing needs. The decisions they have reached about the distribution of housing provision within the housing market area are arbitrary, opaque and extreme, making the proposed plan unsound and unsustainable. The proposal that Warwick District should take the largest share of Coventry's overspill is reckless and wholly unjustified given the Green Belt status of a large part of the district. [section 4]

The Council have failed to demonstrate that nearly 17,000 dwellings can be built in the district by 2029. All the evidence suggests otherwise. Their response to the low level of dwelling completions in the first four years of the plan period is to allocate even more housing, without considering what (if anything) can be done to improve building rates within the existing allocation. As a result, the proposed plan would have a range of undesirable consequences for urban regeneration, vacancy rates and dereliction, commuting, service and infrastructure costs, housing opportunities and loss of Green Belt which neither the Council nor the Sustainability Appraisal have adequately considered. Those negative effects which the Sustainability Appraisal does recognise have played no apparent part in the development of the strategy. Almost half the dwellings to be built on allocated sites are in the Green Belt. The proposed plan is unsustainable and is directly at odds with policy in the National Planning Policy Framework. [sections 5 and 6]

The proposed plan and the cumulative impact of its development proposals would exacerbate problems which the district already faces such as loss of character and environmental quality, traffic congestion and inadequate public transport. Many of the individual housing proposals - particularly those involving substantial loss of Green Belt - cannot be justified and will do great damage. Nearly half of housing development on allocated sites would be in the Green Belt and the proposed plan does not comply with government policy on housing development in the Green Belt. Insufficient consideration has been given to the infrastructure implications of development on such a large scale. [section 7]

The plan is unsound, unsustainable and unworkable. It stems from a deluded view of the growth potential of Coventry and Warwickshire and is contrary to government policy. The plan needs to be fundamentally re-thought and housing provision of between 10,000 and 10,500 dwellings would be much more appropriate and potentially achievable. [section 8]

3. Defects in the Strategic Housing Market Assessment (SHMA)
The SHMA prepared by G L Hearn was intended to be an objective assessment of housing need in Coventry and Warwickshire. While it purports to follow government guidance, it has the following serious defects which fatally undermine its credibility:
* As a general rule, only organisations with a vested interest in increasing housing provision from its already very high level have been consulted. Those able to take a more detached and balanced view were conspicuously excluded. The local authorities themselves have a strong incentive to push house building rates higher and higher thanks to the New Homes Bonus.
* While the terms of reference for the study are reasonably objective, a wealth of e-mail correspondence between the local authorities and the consultants (released under the Freedom of Information Act ) suggests that there was a good deal of manipulation behind the scenes.
* The study rightly uses ONS population and household projections as the baseline for its work, but treats them as if they were forecasts. On the contrary, ONS say ''The population projections have limitations. They are not forecasts (my italics) and do not attempt to predict the impact that future government policies, changing economic circumstances or other factors (for example, government policies on immigration or student fees) might have on demographic behaviour...... As a forecast of the future population they would inevitably be proved wrong, to a greater or lesser extent..... Projections become increasingly uncertain the further they are carried forward into the future'. Hearns have fundamentally erred in treating the projections as forecasts and failing to consider how the policies or other factors that underlie them may change in future. They assume (paragraph 3.34) that uncertainty is mainly attributable to inadequacies in base data, but the effects of future changes in societal trends and public policy are likely to be far more influential. The SHMA never faces up to these issues.
* There is an unexplained anomaly in the use of the projections. The difference from the 2011-based to the 2012-based projections for the HMA is a decrease of 127 dwellings per annum. However, in Hearns' work this results in an increase of between 472 and 572 dwellings per annum . The consultants do not adequately explain this apparent conflict.
* The approach is based on the implicit assumption that new dwellings will meet existing and future housing needs, but this is not the case. Almost 90% of the private housing market involves existing, not new, housing stock. With the exception of starter homes, the great majority of new dwellings are bought by existing home owners. Except in the very long term, prices are insensitive to the volume of new house building and the market is not particularly effective in ensuring that newly arising housing needs are met.
* The study rightly explores a very wide range of scenarios in its attempts to quantify Objectively Assessed Need but fails to critique the underlying methodologies of the different models in which it places its faith. The study plumps for single figures within the range of possible outcomes (often towards the upper end of the range) that are arbitrary or poorly justified. The eventual recommendation that 4,272 dwellings per annum should be built in Coventry and Warwickshire seems to be a black-box generated number instead of being backed up by credible analysis at each step in the process.
* The 'part return to trend' on headship rates is poorly explained and justified. It is far from certain yet whether the cessation of the fall in average household size in recent years is just a 'blip' or the 'new normal' . The factors likely to influence this lead in different directions and give different outcomes. The consultants assume that a reduction in average household size will resume, but there is very little evidence for this;
* The economic forecasts used by Hearns give widely divergent results. The fact that they are based on past development trends is a major weakness, particularly as only a short, probably unrepresentative period has been considered. They also lack explicit assumptions about the productivity relationship between GVA and job growth. Yet the Local Enterprise Partnership is trying to attract high tech and high value added jobs, which would result in a lower number of jobs for a given level of GVA;
* The Strategic Employment Land Study is based on very arbitrary assumptions and data and has not been subjected to critical analysis. The 'talking up' of Coventry's employment prospects in section 4 of the study is very speculative, verging on wishful thinking, and the whole OAN is consistent with a rose-tinted view of economic prospects in Coventry and Warwickshire, bearing in mind past lower than national growth rates and skills shortages . Hearns have suggested upward adjustments to OAN in some areas in relation to economic prospects, but do not seem to have considered downward adjustments in other areas so the analysis is all one way. The equation made between jobs and people is over-simplistic;
* The assumptions about commuting are unrealistic. Commuting patterns change over time and it should be one of the objectives of a plan to reduce longer distance commuting in the interests of sustainability. Conversely however this plan is likely to lead to significant increases in commuting (see Section 6 below). The assumption that the commuting rate will remain as in 2011 is therefore naive and lacks any credibility;
* Much of the increase in population in Coventry over the past ten years or so appears to be related to the growth in student numbers in the city. A huge amount of development of student accommodation has taken place. The SHMA never properly addresses this issue. It fails to consider whether and to what extent these trends are likely to continue into the future; or the extent to which students require separate housing provision (as opposed to living in halls of residence or shared accommodation). Why should there not be a 'partial return to trend' on this issue, as on headship rates?
* International migration is mentioned in section 3, but there is no discussion of whether past trends are likely to continue. The Government is under intense political pressure on this issue and has maintained its target of lowering net in-migration by more than half. The outcome of the EU referendum is also likely to have a bearing on international migration. In recent years, Coventry has taken more than its fair share of in-migrants. There is no reason to think that in-migration to the city can or will continue at anything like recent levels. In Warwick District, net migration (including international migration) has varied greatly from year to year since 1995 and is inherently unpredictable. Also, net migration is influenced by housing and employment provision so there is an element of circularity in any forecast which is based on past trends;
* The relationship between affordable housing and overall housing need is never convincingly established by the study. Affordable housing should be a sub-set of overall need, not an 'add-on', so Hearns' upwards adjustment of OAN to take account of affordability appears unjustified. It is also debatable whether 'affordable housing' is affordable in practice to many new households. There is no evidence that Hearns have taken sufficient account of recent changes in government policy.
To sum up, the SHMA is a seriously flawed piece of work that should not have been used without critical analysis. At best the resultant so-called Objectively Assessed Need is subject to great uncertainty; at worst it is not credible at all.
4. Defects in the Way the SHMA Has Been Interpreted and Used
Government guidance is that Objectively Assessed Need should be a starting point for assessing what housing provision should be. The National Planning Policy Framework (NPPF) recognises that there may be circumstances in which development requirements cannot be met because of the demonstrable lack of environmental capacity.
In a letter in December 2014 , the then minister said 'A Strategic Housing Market Assessment is just the first stage in developing a Local Plan and councils can take account of constraints that indicate that development should be restricted.... The outcome of a Strategic Housing Market Assessment is untested and should not automatically be seen as a proxy for a final housing requirement in Local Plans......Councils will need to consider Strategic Housing Market Assessment evidence carefully and take adequate time to consider whether there are environmental and policy constraints, such as Green Belt, which will impact on their overall final housing requirement.' Unmet needs from neighbouring authorities should be met 'where it is reasonable to do so and consistent with achieving sustainable development' .
The Local Plans Expert Group have drawn attention to a common deficiency in local plans. They conclude that 'despite the clear test set by paragraph 14 of the NPPF, few authorities compile an assessment of the environmental capacity of their area' . They go on to propose that a proportionate Assessment of Environmental Capacity should be an important part of plan making. The local plan making authority should consider the extent to which the plan can meet OAN consistent with the policies of the NPPF.
This type of approach is conspicuously absent in Coventry and Warwickshire. The local authorities in their so-called Memorandum of Understanding and Warwick District Council in its plan have taken a lemming-like approach which is directly at odds with Government policy. They have decided without adequate explanation that Hearn's Objectively Assessed Need of 4,272 dwellings per annum (already an artificially high figure) should be increased still further to a housing target of 4,408. They have then failed to consider whether environmental constraints prevent this new figure being met in its entirety. The Hearn approach and its results have not been subjected to any critical analysis whatsoever and the uncertainty that runs right through the study has simply been ignored. It is sheer folly to pick out a single figure and stick to it come what may. Such an inflexible approach is certain to be found wanting as the implementation of the plan unfolds. Meanwhile a great deal of damage will have been done. The position is even more serious in Warwick because the modification to policy DS20 opens the door for even further housing development in future to meet unspecified housing needs in other areas.
The housing proposals for individual authorities are unjustified, to say the least. Coventry is deemed (without supporting evidence or argument) to be able to accept only 1230 (64%) of its OAN of 1930 per annum. The remaining 700 is distributed (without explanation) between three Warwickshire districts - Nuneaton and Bedworth, Rugby and Warwick. In Warwick's case, this results in proposed housing provision of 18,640 over the full twenty year period to 2031, which is over 55% higher than its own OAN. This is a fundamentally unsustainable and unjustified outcome.
The Warwick Plan gives no explanation of -
a. Why Coventry cannot meet more of its OAN;
b. How the allocation of the excess to other authorities has been decided. The 'redistribution methodology' has not been explained or justified;
c. The account taken of Green Belt, environmental and other policy constraints, both in Coventry and in the surrounding Warwickshire districts, in making this judgement;
d. The wider effects of 'transferring' housing need originating in Coventry to Warwick and other authorities.
The plan also fails to consider the density of new housing development or whether intensification of use of the existing housing stock could be achieved without loss of quality in the urban environment. On most development sites, a density of 35 dwellings per hectare has been automatically assumed, ignoring the variability between sites and their settings and the potential for higher density. By leaving this vital issue unconsidered, the plan fails to provide adequate justification for the link between the vast quantum of new housing development proposed and the huge land area involved.
The Warwick Local Plan is therefore fundamentally unsound and unsustainable, quite apart from its unquestioning reliance on a deeply flawed Strategic Housing Market Assessment. The approach taken is, quite simply, indefensible.
5. Implementation Problems
Government guidance requires the Council to demonstrate the deliverability of the plan . The Council do not seem to have asked themselves whether it is realistic to expect 16,776 dwellings to be built in Warwick District between 2011 and 2029.
The Council claim that 1,483 dwellings were completed in the district during the first four years of the plan period - 2011 to 2015: an average of 371 dwellings per annum. The plan requires an average of 932 dwellings per annum to be built over the full plan period, including those first four years. If dwellings built in the first four years are discounted, the average for the remaining fourteen years rises to 1,092 dwellings per annum, nearly three times the rate achieved in the first four years (during which the economy was growing). It simply cannot be done.
The Housing Trajectory in Appendix A shows very clearly the unreality of what the Council are proposing. Average completions per annum between 2018 and 2022 are assumed to be some 1,730 per annum, nearly five times the rate achieved in the first four years of the plan. The beginning of this period is a mere two years away and the assumption seems to ignore the lead time required to assemble skilled workers on a very large scale.
The plan states that at April 2016 there will be sites with planning permission for 5,161dwellings. It is very difficult to believe that all these permissions will actually be implemented during the plan period, though that is apparently what the plan assumes (in contrast, for example, to the Rugby Local Plan which assumes low take-up of existing permissions). In reality, allocating many more sites is likely to reduce the take-up rate on existing permissions still further. Over-allocation on this scale would effectively destroy the planning strategy because the Council would surrender control to house builders over where and when dwellings would be built. Adding an arbitrary 'element of flexibility' to housing provision , taking it up to a grand total of 17,557 , makes matters even worse.
A figure of 16,776 dwelling completions by 2029 therefore belongs in the realms of fantasy. National and regional studies have shown that the main factor limiting the scale of house building has been the sharp decline in public sector house building. Despite some recent policy announcements, there is little prospect of a significant revival in house building by this sector. Private sector building has been stuck at around 90,000 dwellings per annum nationally since 2008 and the latest RICS survey indicates that growth in private sector house building slowed considerably during the first quarter of 2016. Overall, housing permissions have exceeded starts by about 50,000 dwellings per annum nationally in recent years .
A recent study by The Guardian newspaper showed that the nine largest national house building companies were sitting on planning permissions for 615,000 dwellings. Either they were incapable of building more because of shortages of labour, materials and / or finance; or effective demand is so low that they had no confidence that they could sell houses if they were built, or they chose to limit their output in order to keep house prices artificially high. Some house builders may also see investment in land as an end in itself in view of rising land prices. The truth probably lies in some combination of these factors. House builders have recently been criticised for 'land banking' by the Local Government Association.
So the prospects of 16,776 dwellings being built in Warwick by 2029 are negligible. Even so, house builders continue to press for high levels of provision so that they will have even more scope to pick and choose the sites that will bring them the greatest profits. This is understandable from their point of view, but should never form part of a credible planning strategy.
6. Likely Effects of the Housing Policies
As a result of this serious over-provision, the plan's housing proposals will have a wide range of unintended consequences -
a. The sites that provide developers with the greatest potential profit will tend to be green field sites outside urban areas rather than brownfield sites within them. The momentum behind urban regeneration will therefore be weakened still further and it will become much more difficult to redevelop windfall sites becoming available within the urban area. The Local Plan is right to have made an allowance for windfalls, but the more green field sites they allocate for housing development, the more difficult it will become to benefit from windfall sites;
b. Over-provision of housing can be expected to accelerate vacancy rates, dereliction and decay in the existing stock, particularly in the more marginal housing areas;
c. The displacement of housing from Coventry into Warwickshire will increase longer-distance commuting and lead to greater car dependency. No proper analysis has been done of this vital aspect of the proposals, least of all by the Sustainability Appraisal. Can the road and public transport systems cope with the extra traffic and passengers? With many roads, particularly in the towns of Warwick, Leamington Spa and Kenilworth, close to or above capacity already, the strong suspicion must be that the Warwick plan is unsustainable in transport terms. Where new roads or improvements to existing roads are proposed, insufficient information is given to demonstrate their financial viability or effectiveness in dealing with congestion;
d. A more dispersed pattern of development will lead to higher service and infrastructure costs once existing capacity thresholds have been exceeded, and will divert severely limited public sector resources away from renewal of services and infrastructure within existing urban areas . Developer contributions are rarely sufficient to provide necessary supporting services and facilities in their entirety;
e. Provision at a level not supported by effective demand is particularly destructive of the housing opportunities available to newer, younger and less well-off households: those most likely to be in housing need. New housing will overwhelmingly not be purchased by newer households. It is not valid to assume that a glut of new housing will result in lower prices all round, making the existing stock more affordable to those in housing need. In practice new homes are generally such a small proportion of the total housing stock that they do not have a significant lowering effect on prices;
f. Very substantial areas of Green Belt will be lost, compounded by losses for other purposes such as the sub-regional employment site. Proposed housing development in the plan accounts for some 500 hectares of Green Belt land and much of this is in strategically significant areas where the Green Belt performs vital functions, meeting all or most of the five purposes of Green Belt. It is very revealing that the plan does not make clear that meeting housing needs is not sufficient on its own to constitute the very special circumstances needed to justify inappropriate development in the Green Belt (see below) and that it generally ignores the recommendations of the Joint Green Belt Study;
g. Rigid adherence to forecasts gives only the illusion of certainty, inhibiting necessary adaptations to new problems and unforeseen opportunities . Warwick and the other Coventry and Warwickshire authorities have chosen to adopt a particularly rigid and unresponsive interpretation of present government policy and their proposals are therefore doomed to fail in practice.
These potential impacts of the Warwick Plan's housing proposals render the plan unsustainable and therefore not in compliance with government policy in the National Planning Policy Framework.
In particular, the plan fails to give sufficient weight to two key aspects of government policy:
a. That the presumption in favour of sustainable development does not apply in the Green Belt ;
b. That need for housing will rarely be sufficient to constitute the very special circumstances required for inappropriate development in the Green Belt. In July 2013, Local Government Minister Brandon Lewis said that 'The single issue of unmet demand....is unlikely to outweigh harm to the green belt and other harm to constitute the 'very special circumstances' justifying inappropriate development in the green belt' This was followed by a DCLG policy statement in October 2014 - 'the local planning authority should prepare a strategic housing land availability assessment to establish realistic assumptions about the availability....of land...and take account of any constraints such as green belt which indicate that development should be restricted and which may restrain the ability of an authority to meet its need . This was in turn reflected in Planning Practice Guidance . Yet Warwick District Council, along with the other Coventry and Warwickshire authorities, seems to have ignored this very important element of government policy .
The Sustainability Appraisal has been updated to reflect the latest modifications to the plan and specifically the huge uplift in housing numbers. However it suffers from a major weakness: that it treats the Strategic Housing Market Assessment and the local authority Memorandum of Understanding as givens without subjecting them to sustainability appraisal in their own right. In general it does not apply sufficiently rigorous analysis and places exaggerated faith in mitigation measures. It plays down some negative effects because of uncertainty about the exact form development will take. It also makes some very questionable individual assessments - for example that the effect of high growth on public transport and community services and facilities will be positive, when experience suggests that provision of these facilities and services almost invariably lags well behind housing development, particularly when it takes place as rapidly as is envisaged in this plan. A positive assessment of the high growth options against 'reduce need to travel' also seems fundamentally misguided when such a high proportion of the proposed development involves meeting Coventry's housing needs in Warwick District.
Impact on the Green Belt should have featured as one of the sustainability criteria used to appraise the plan and its policies. Green Belt is simply subsumed within the much wider criterion of 'Prudent Use of Land and Natural Resources' and it tends to get lost in the process. The appraisal frequently pulls its punches, talking for example about the potential for the loss of Green Belt when the strategy entails certainty of massive Green Belt loss.
Nevertheless the Sustainability Appraisal finds that the two high growth options (900 and 1,000 houses per annum) would have negative effects in relation to six of the sustainability criteria used to assess options. This conclusion is effectively ignored in the plan itself and there is no evidence that it has played any part in the development of the strategy. The Council have wrongly assumed that they have no alternative but to meet so-called Objectively Assessed Need in full, plus the huge uplift to meet Coventry's excessive housing needs.
7. Comments on Specific Housing Policies and Proposals and their Justification
My calculations suggest that some 4,575 (49%) of the new dwellings on specifically allocated sites would be in the Green Belt. This is a staggering figure which cannot possibly be reconciled with Government policy as described above. It is difficult to imagine why Warwick District Council, given the large amount of its land area subject to Green Belt policy, agreed to accept by far the largest individual proportion of Coventry's overspill (6,640 dwellings). On the basis of conflict with government policy and the need to preserve a strong Green Belt to secure the continued separation of the towns in the district from each other and from Coventry, I object to all the locations for housing development listed in paragraph 2.81 as having been removed from the Green Belt.
My comments on selected proposals are as follows:
* Kings Hill (H43) - This development would be a huge and totally unwarranted projection of the built-up area of Coventry into the Green Belt and open countryside south of the city. It would doubtless be followed soon afterwards by an application for a boundary revision to extend the city's area. This is an area of good quality landscape which makes an important contribution to the role of the Green Belt in separating Coventry from Kenilworth. The proposal relies heavily on a new railway station and roads but given the long delay in securing reopening of Kenilworth station there can be no guarantee that a station at Kings Hill will be open before development takes place.
* East of Kenilworth (H40) - This long swathe of development would close the Green Belt gap which currently exists between the built-up area of the town and the A46. On rising ground, the development would be very visible from countryside to the east near Ashow and the National Agricultural Centre.
* North of Milverton (H44) - This would constitute a substantial northward extension of Leamington Spa into the Green Belt, bringing it significantly closer to coalescence with Kenilworth. The safeguarding of a large area of additional land for future development makes the present proposal just the thin end of the wedge. The explanation talks blithely about dualling the A452 but this is unlikely to be feasible within the existing built-up area of Leamington and may not be affordable in any case.
* Baginton (H19) - The Rosswood Farm site, almost in line with the airport runway, seems particularly ill chosen from the point of view of noise, air pollution and air safety.
* Barford (H48 et al) - The cumulative impact of these developments would be expected to have a substantial impact on the character of the village.
* Bishops Tachbrook (H49 and H23) - Taken together, development of these sites could be expected to have a profound effect on the character of the village and would involve projections into open countryside to the west and south.
* Cubbington (H50) - A substantial projection of development into pleasant open countryside east of the village.
* Hampton Magna (H51 and H27) - Taken together, these developments would represent a huge extension of the village into Green Belt and open countryside to the south and east, changing the character of the village in the process.
* Leek Wootton (DS NEW 3) - Although a minority of the site was already developed, this does not justify the proposal, which forms a very substantial westward extension of the village into open countryside and Green Belt.
* Whitnash (H-03) - Whitnash is already a peculiarly shaped and poorly accessed urban extension. This large development will add an extension to the extension, taking the village across the railway to the east and making it stick out even more like a sore thumb. It is noticeable that there is no proposal for a railway station to serve it.

Policy DS New 1 includes vague criteria for allocating land for housing south of Warwick. It is wrong in principle to consult without more clear-cut proposals, leaving local people and interest groups in a position of great uncertainty.
The plan is far too deferential towards the growth aspirations of Warwick University. The plan should not give the university carte blanche to do whatever it wishes to do, but that in effect is what is proposed.
A general problem is the heavy reliance on master planning for comprehensive development of the larger proposed housing sites. This will make it even less likely that the housing proposals will be implemented on anything like the timescale envisaged in the housing trajectory, particularly where land is in multiple ownership.
In new paragraph 1.09, the plan talks about new development enhancing the setting of natural and heritage assets. This is delusional and makes a mockery of what little remains of the plan's environmental credentials.
New paragraphs 2.1 to 2.43 talk about taking land out of the Green Belt so that it can be safeguarded for possible future development. In relation to government policy, there is even less of a case for this than where development is claimed to be needed during the plan period, and I have already shown that the latter is contrary to government policy.
I have not found a policy directed towards controlling or influencing the types and sizes of dwelling to be constructed in the district. This plan seems to treat planning for housing as no more than a numbers game and in doing so it ignores government policy that the nature of new housing is important .
8. Conclusions
The housing proposals in the emerging Warwick Local Plan are unworkable, unsustainable, contrary to key elements of Government policy and against the interests of residents of the borough. They are deluded and unsound. They stem from a fundamentally misconceived growth-orientated strategy that reflects wishful thinking about the economic prospects of the sub-region by the Local Enterprise Partnership and the Coventry and Warwickshire local authorities compounded by some far from independent technical work of questionable quality to support it. The proposals give minimal weight to the environment and character of the district, which have hitherto been cornerstones of successive plans. They will result in the Council effectively abandoning control over planning for housing and in a significant reduction in environmental quality.
Much of the problem with the housing strategy stems from Coventry's overweening growth aspirations, which result in dumping large quantities of housing and employment development on neighbouring local authorities. This is counter-productive, unsustainable and unachievable. If Coventry cannot live within its means, it should not simply decant large-scale development to neighbouring authorities with no thought for the consequences..
The question of what would be a realistic and achievable level of housing provision for Warwick between 2011 and 2029 is a matter of judgement rather than calculation. Taking into account all the factors discussed in this Critique, my view is that provision of between 10,000 and 10,500 dwellings would be appropriate. This would have a good prospect of being achieved and would meet the reasonable housing needs of the district, as opposed to the inflated figure assessed by G L Hearn and the huge additional uplift provided through overspill from Coventry. Provision at this level would allow a much higher proportion of development to be on brownfield sites within the urban area (including windfalls) and would require little or no release of Green Belt land for housing.

see attached

See attached

See attached

See attached

See attached

See attached

We write on behalf of Taylor Wimpey UK Ltd in respect of their land interests on land at Old Budbrooke Road, Hampton Magna. A site location plan is enclosed with these representations at Appendix 1 alongside a leaflet detailing the development proposals for the Site at Appendix 2.


The site is not part of a proposed allocation, with sites H27 (130 dwellings) and H51 (115 dwellings) being proposed for allocation in Hampton Magna. However, for the reasons set out below, we consider that given its sustainable location and proximity to services and facilities within the village the land in the control of Taylor Wimpey UK Ltd provides a better option for sustainably meeting the needs of Hampton Magna in the future and is capable of delivering circa 140 dwellings.


The Site occupies a sustainable location situated to the north-east of Hampton Magna. It is bordered to the south by residential development, to the west by Old Budbrooke Road, to the north by a farm track and then the Warwick Parkway railway station and to the east by Stanks Farm building and a disused sewage works. The boundaries to the site form logical and defensible boundaries and the site offers the opportunity to add sensibly to the built form of the village. The site would offer good pedestrian linkages, particularly to the railway station to the north of the site, along with the provision of substantial areas of public open space and landscape buffers to the north and south of the site.

In comparison to the proposed allocations within Hampton Magna, the site offers logical access direct from the Old Budbrooke Road, whereas the proposed allocations offer little opportunity for direct access, particularly for construction other than through the centre of the village itself. Furthermore, we consider that the landscape impact of the proposals to the south of the village will be greater as they benefit from inferior boundaries and levels of containment.


In relation to this Site, we comment Main Modifications as follows:

Mod 4 - Policy DS6

Whilst we are generally supportive of the Council's approach to increasing the housing target, taking account of unmet needs to assist the HMA in meeting the requirements of


24707/A3/VL/RC/lfw 2 22nd April 2016




the NPPF and satisfying the Duty -to-Cooperate, we remain concerned that the level of uplift at the HMA and District levels is insufficient.

We enclose at Appendix 3 a critique of the Council's position on meeting housing needs across the HMA.

At this time, we are of the view that the housing requirement for the HMA over the period (2011-2031) should be a minimum of 100,200 dwellings (5,010 dpa), with our updated and preferred methodology increasing this to 126,000 (6,300 dpa).

For Warwick District we consider that the OAN is a minimum of 20,800 dwellings (1,040 dpa), with our updated and preferred methodology increasing this to 23,400 dwellings (1,170 dpa).


The figures for Warwick do not take account of any need to redistribute housing within the HMA based on the Duty-to-Cooperate and Local Authorities, such as Coventry City, being unable to meet their own housing needs.

Mod 6 - Policy DS7

Notwithstanding our response to Mod 4, and the contention that the housing requirement should be increased further to 23,400 dwellings (1,170 dpa) for Warwick District over the period 2011- 2031 (not accounting for unmet needs within the Coventry HMA), we wish to comment on the amended Policy DS7, which sets out how the housing requirement will be met.


The Council has proposed to allow for the delivery of an additional 811 dwellings over and above the proposed requirement of 16,766 dwellings for the Plan period (2011- 2029). Regardless of any changes to the housing requirement, we support the approach of the Council in seeking to allocate additional land; as such an approach adds significantly to the soundness of the Council's approach by providing a positively prepared Plan that will be more effective in delivering the minimum housing needs of the area, and is flexible to changing demands over the Plan period.


The inclusion of safeguarded land will also play a key role in achieving these outcomes, which is supported in the NPPF at paragraph 14 - where Councils are asked to provide sufficient flexibility to adapt to rapid change in meeting OAN.

The proposed approach to allocations and safeguarding land will also assist the Council in demonstrating that they have been both aspirational and realistic in progressing the Plan in accordance with paragraph 154 of the NPPF; with the slight overprovision allowing for any slippages in the delivery of the strategic sites within the District - which may be particularly helpful given the proximity of a number of allocations to the south of Warwick/Leamington Spa - and maximising the chance of a five year housing land supply being demonstrable over the Plan period.


Mod 7 - Para's 2.21 to 2.24

Further to our suggestion for the provision of appropriate flexibility in the Plan, we note the housing trajectory that sits behind Policy DS7, which depicts the timeline for the delivery of housing over the Plan period.

The trajectory is seeking a sharp increase, from circa 850 forecast completions in 2015/16 to a minimum of circa 1,400 dpa over the period 2017/18 - 2022/23.

Such an increase is considerable, and to maximise the chances of this being delivered then the Council will require as many deliverable sites as possible to come forward to help meet this need.

24707/A3/VL/RC/lfw 3 22nd April 2016




We would therefore be supportive of land being allocated at Old Budbrooke Road in Hampton Magna for housing development, which is capable of early delivery and would assist in meeting its OAHN.

Mod 9 - Para's 2.37 and 2.38

We have no specific comments to make, other than to agree with the justification for releasing sites from the Green Belt to meet the needs of the Housing Market Area.

Furthermore, we note that the NPPF requires at paragraph 47 for the needs of the HMA to be met, however, how this is distributed across the District is a matter of planning judgement for the Council taking account of a number of considerations. As an example, elsewhere in the HMA it can be seen that North Warwickshire has adopted a Sound Plan in accordance with the NPPF that includes within it 500 dwellings to meet the needs of Tamworth without any sites immediately adjacent to the urban area from which unmet needs are originating.


Consequently, we consider that paragraph 2.38 should be amended to simply state:
'In selecting sites on the edge of urban areas, non‐Green Belt sites are‐ favoured over Green Belt sites where possible. However, where there are no suitable non Green Belt alternatives to meet an identified need, sites are removed from the Green Belt to enable development to take place which will help to meet the needs of the Housing Market Area. This applies to land to meet the needs of Coventry, Leamington, Kenilworth, some of the villages and land on the edge of Lillington to assist in the regeneration of the area.' (added / deleted)

Mods 10 and 11 - Policy DS11 and Para's 2.41 to 2.53

We disagree with the proposed allocations made in Hampton Magna, as we consider that the land under the control of Taylor Wimpey at Old Budbrooke Road is superior and offers a more sustainable and logical extension to the settlement of Hampton Magna.

We have commented previously on the suitability of the Site to deliver residential dwellings and enclose a leaflet which demonstrates how the Site could sensible be delivered (Appendix 2), as well as technical notes updating the position in relation to ecology/archaeology/agriculture and highways/drainage at Appendix 4 and 5 respectively.

Given the above, we object to the Plan on the basis that this Site is not included within it, either instead of or alongside H27 and H51.

Indeed, we note that the update to the Landscape Sensitivity and Ecological & Geological Study (Landscape Assessment Update - 2014) upgraded the classification of part of Site H27 to a 'High-medium' landscape sensitivity to residential development as opposed to a 'High' sensitivity. We would however point out that there is no evidence or justification behind this alteration as the only focus was around land to the east of Hampton Magna under reference HM_05. Site H51 remains assessed as having 'High' landscape sensitivity.

In addition we would add that Taylor Wimpey's site is subject to 'High -medium' landscape sensitivity to residential development and the assessment set out that "...there is potential for a small amount [of development] between the existing settlement edge along Blandford Way/Arras Boulevard/Gould Road and Stanks Farm. However, this would need to include a substantial landscape buffer in order to strengthen the green corridor along the railway and prevent any physical or visual link to Warwick..." As can be seen in Appendix 2, we note are aware of the need to provide appropriate landscaping and have incorporated this in to the proposals for the Site from an early stage.

We therefore consider that the land in the control of Taylor Wimpey offers a suitable and preferable extension Hampton Magna.

24707/A3/VL/RC/lfw 4 22nd April 2016




Mod 16 - Para 2.81

As set out previously we consider that the site offers the opportunity for release of Green Belt to provide for additional sustainable housing growth throughout the Plan period.

In 2015, the Council undertook a review of the Joint Green Belt Study (Parcel WA2) which also includes the proposed allocations of Sites H27 and H51. The parcel scored 15/20 in this assessment.

However, the scale of the parcel did not allow for an accurate assessment of this Site and thus we have prepared our own Landscape and Visual Appraisal of the Site - which respects the boundaries of the Site. This is enclosed at Appendix 6 and summarises that the Site is "...well related to the existing housing area and benefit from robust boundaries, including Old Budbrooke Road, the railway line and the A46 Warwick Bypass... subject to the sensitive design, detailing and layout, development at the Site would not result in urban sprawl; nor represent an encroachment into the wider countryside; it would not impact on local heritage assets; nor would it materially contribute to the coalescence with the neighbouring settlement at Warwick. Accordingly, development could be accommodated without resulting in significant landscape and visual effects, or offending the objectives of Green Belt policy."


Mod 20 - Policy DS NEW 1 Directions for Growth South of Coventry

In relation to this Policy, we wish to support the Council in their approach to capping of the assumed delivery of the Westwood Heath and Kings Hill sites due to infrastructure and delivery rates respectively.

It is important in meeting the needs of the HMA that the Council are realistic in this regard in order to ensure that the Plan is effective and deliverable by 2029.

Given the timescales for adoption of the Plan and progressing a site of the scale of Kings Hill, 1,800 dwellings by 2029 should be considered aspirational - and in order to ensure that the Plan remains realistic, consider that no uplift to this figure is appropriate. Indeed, the Council should ensure that they are fully confident of the build rates suggested being delivered before progressing the Plan.


Conclusion

We trust that you will take these comments are helpful in progressing the Plan. Should you require any further information, do not hesitate to contact me as per the details on this letter.

see attached

see attached

See attached

See attached

See attached

see attached

1.0 Introduction
1.1. McLoughlin Planning are instructed by Centaur Homes to submit representations on the proposed modifications to the Warwick Local Plan 2011-2029. This document will take each relevant modification in turn and where necessary, refer to the Evidence Base, National Planning Policy Framework (NPPF), Planning Practice Guidance (PPG) and other material considerations.
1.2. By way of context, Centaur Homes has an interest in Land at Old Budbrooke Road, (also referred to as Maple Lodge or land north of) as shown on the enclosed site location plan and seek its allocation for residential development within the emerging Local Plan. These representations cover policies relevant to the allocated housing sites at Hampton Magna.
1.3. Centaur's site is adjacent to the settlement boundary on the western side of the village. Hampton Magna is identified within the Local Plan as a 'Growth Village' and suitable for development. It is ideally located to provide sustainable housing development in accordance with the Framework paragraph 55 and has excellent connectivity to Warwick and the wider area.
1.4. The Old Budbrooke site extends to 5.5 hectares in size. This consists of a mix of brownfield and greenfield land, with approximately 1.5 hectares of this being brownfield. The site already benefits from an access fronting onto Old Budbrooke Road and facing the existing village. the site is contained by the existing road network to the south, east and west, with mature field boundaries to the northern edge. The site sits within a valley that rises up to east and the village.
1.5. The existing uses on the site create a significant number of lorry movements and associated noise and disturbance. The allocation and redevelopment of the site will bring the land into a use that is more suitable to its village location.
2.0 Modifications 1 & 2, 4 & 5
2.1. Centaur Homes support the Council in meeting its Duty to Cooperate and the increase in housing need to accommodate the unmet need from outside of the District. However, this unmet need should not be separated out from the actual need for Warwick DC.
2.2. As acknowledged, the 2015 SHMA has a critical role to perform in helping the Council prepare a Local Plan, which is sound. However, it is noted that the SHMA covers a 20-year period, but the plan period is only 18 years. To allow for this, the Council has applied a pro-rata figure the to the plan period. Centaur's concern with this is that although the total need over the 20 year period is known, the breakdown of demand for housing during the period is not, it is not a constant perfect linear line, but dynamic.
2.3. Therefore, the Plan's target of 16,776 new dwellings is not justified and potentially could under deliver in the short term. Failure to provide the required level of housing will further compound supply problems as well as hinder economic growth and fail to address affordability concerns. This is further supported by the affordability of market housing data shown in table 46 in the SHMA, which identifies that Warwick District is less affordable, than the England average.
2.4. If the Council insist on using a figure different to that in the full OAN identified in the SHMA, This figure needs to be justified for the shorter period. It is also considered that in accordance with the need to "boost" housing supply that the housing target should be expressed as a minimum to provide for additional flexibility to make for any under-delivery on allocated site.
3.0 Modification 3
3.1. Centaur Homes supports the change to Policy DS4. This clarifies that allocations can occur to a wider range of settlements across the district.
4.0 Modifications 6 & 7
4.1. Following on from the Inspector having found the windfall figure as previously put forward unjustified, the Council have lowered the figure.
4.2. However according to the letter from the Council leader, Cllr Andrew Mobbs, to the Inspectorate dated 14th October 2015, work is still on going "regarding a justifiable level of windfalls" and the figure put forward is "just an estimate" and no further evidence has been provided within the proposed modifications to support this figure, even though it is lower than the previous allowance.
4.3. As a result, Centaur consider the Plan's approach towards windfalls to still be unsound as it is clearly contrary to national guidance and the fact that the Plan is supported by a robust SHLAA. Given the detail in the SHLAA, further housing allocations can be made to further reduce any risk of the housing target being met.
In addition, subject to other representations looking for the Plan's target to be
expressed as a minimum, it would provide the necessary flexibility for windfalls to come forward.
4.4. It is considered that the concerns about the windfall figure can be redressed (in part) through the allocation of additional land at Maple Lodge at Hampton Magna for housing development.
5.0 Modifications 8 & 9
5.1. Centaur Homes supports the revised distribution and the increase of dwellings to the Growth Villages. Such an approach is consistent with paragraph 55 of the Framework.
6.0 Modifications 10, 11, 16 and 19
6.1. Centaur Homes objects to these modifications on the basis that they are unsound as they are inconsistent with national policy and not justified by the evidence base.
6.2. Centaur Homes do not dispute the need for additional housing in Hampton Magna as reflected by earlier representations supporting the development of land on the western side of the village. However, these modifications underline the flawed approach the plan has made to development in the village in respect of:
* The Green Belt.
* Landscape Impact.
* Sustainability Appraisal.
6.3. Each is addressed in turn below.
The Green Belt
6.4. The green belt is the key issue relating to the modifications is that both sites are proposed to be removed from the green belt. In so doing, the additional release proposed and intensification of the allocated site, have to be justified by the evidence base.
6.5. In this respect, the modifications are flawed as there is no cross-reference to the appropriate evidence base to support the allocations. As per earlier representations, Centaur Homes is unconvinced about the Modifications put forward as Core Document CD V13 and makes a more robust case for the release of land on the western side of the village, rather than on the eastern side, where the two allocations are proposed.
6.6. Whilst it is unreferenced in the EiP Core Documents list, the 2015 Warwickshire Green Belt review does provide an analysis of the green belt around Hampton Magna in terms of parcels WA2 (where allocations H27 and H51 are sited) Old Budbrooke Road (HM2).
6.7. A general criticism of the approach by the 2015 document is that it is too broad brush, that the assessment parcels are too large, encompassing areas with different sensitivities to the green belt. This is especially the case with HM2, where the southern part of the parcel is not close to Warwick, unlike the northern part. In contrast, CD V13 does look to provide a more fine grain analysis of development areas.
6.8. In terms of allocation H27, the Modifications impose an arbitrary additional 30 dwellings on the site, with no evidence suggesting how this could be accommodated or what the associated impacts are.
6.9. In the case of H51, the concerns are more fundamental, in that the extent of the allocation does not account for the whole of the field in which the allocation sits. This is considered to be a serious misjudgement in terms of how a site should be allocated for housing development, when releasing it from the green belt and the need to make use of clearly defendable boundaries.
6.10. Making specific reference to the guidance in paragraph 80 of the Framework, the following analysis of the intensified H27 and newly allocated H51 is as follows:
Check unrestricted sprawl
6.11. Both allocations are identified in an area in CD V13 that are characterised as being very open. Therefore, their development will have an immediate impact on the green belt. In the case of H51, given the arbitrary extent of the allocation, not using the whole of the field in which it sits, its development would lack context and effectively sprawl.
Prevent neighbouring towns merging
6.12. Notwithstanding the presence of the Warwick bypass, this is a critical area of the green belt, where the gap between Warwick and Hampton Magna is as little as 1km (2015 GBR). Clearly the intensification of development on H27 and the development of H51 will clearly increase the perception of Hampton Magna and Warwick merging.
Safeguarding the Countryside from Encroachment
6.13. The key concern here is the openness of the allocated sites. Their development, topography and lack of a layered approach to multiple field boundaries means that development will clearly encroach into the green belt and be heavily reliant on the creation of new boundaries. Whilst the presence of sports pitches in assessment area WA2 are noted, their presence does not confer that housing development would be equally acceptable as sports pitches are appropriate development in the green belt, whereas housing is not.
Prevent the setting of historic towns
6.14. Core Document V13 makes reference to the inter-visibility of the area in which these sites sit an the Warwick conservation area. Especially as these sites have an elevated location overlooking Warwick.
Assist in urban regeneration
6.15. Clearly, given the scale of Warwick's housing challenge, there is a need to allocate additional greenfield sites.
Strong & defensible boundaries
6.16. Following on from the critical assessment of the Green Belt Assessment, and it having been undertaken at an appropriate scale, it is clear that the Council has not identified the allocations in accordance with the final bullet point of NPPF paragraph 85. This requires boundaries to use physical boundaries that are clearly recognisable and likely to be permanent.
6.17. With allocation H51, the allocation boundary does not follow any existing boundaries at all. It sits within an asymmetric shape field and the allocation cuts off the bottom and eastern sections of the field. This will leave areas of land that are not connected to the neighbouring field and may lead to further hedgerow loss as they are incorporated into the neighbouring fields having a very significant landscape impact and making the developments even more visible from the long distance views of the site from the south and east.
6.18. For both allocations the likelihood of the permanence of the boundaries should be questioned. Apart from H51 having no boundaries at all, allocation H27 is only contained by field boundaries on its two longest sides, these are generally considered to be weak and are easily broken through, especially as they are not particularly dense, deep or contain a significant number of mature trees. The location of a public right of way along the southern boundary does not add any weight to the boundary as this could be incorporated within a development.
6.19. As such, the allocation, as it is put forward within the modifications version of the Local Plan is not NPPF compliant.
Landscape Capacity Study/ Assessment Concerns
6.20. The second area of concern with the Modifications is the compatibility of the Modifications with the landscape evidence which underpins the Plan.
6.21. The main Landscape Sensitivity and Ecological & Geological Study dated November 2013 considered the sensitivity of all sites around Hampton Magna. This located Land South of Arras Boulevard (site H27) within land parcels HM_05 and HM_06 and Land South of Lloyd Close within land parcel HM_07.
6.22. Regarding land parcel HM05, the study focus on land to the east of the village, down to the A46, however, it does state that new development should not extend beyond the current settlement edge to the east, or to the south of public right of way WB12.
This public right of way links into public right of way W84, this is not mentioned in the commentary on land parcel HM_05. This study acknowledges that there is: "some potential for a very small amount of development in this zone providing that views towards Warwick from the existing settlement are preserved."
6.23. Based on this evidence document, how can the intensification of allocation H27 comply with this Landscape Sensitivity Assessment? Any development of allocation H27 will restrict existing (public) views from the settlement towards Warwick, as these are currently open and far reaching. Therefore it is not possible for these to be preserved as new development will break up the view and sight lines, especially the current open view from Arras Boulevard and the intensification of development on the site will further compound this loss.
6.24. The commentary on land parcel HM_06 provides further evidence against the intensification and development of the whole, again it notes that there is some scope for "limited development adjacent to the existing settlement edge" and the graphic provided within the Landscape Sensitivity Assessment acknowledges that this should be limited to the northern half of the eastern field. Any intensification of this allocation will significantly alter the key views within land parcel HM_06, the evidence document notes that existing mature trees break up the "hard edge" of the settlement to some extent and a significant landscape buffer will be required to mitigate any development of this site and to maintain the existing relationship between urban and rural that will greatly impact on the density of development across the main site and therefore, further compound the problem.
6.25. The Landscape Sensitivity Assessment for Allocation H51 again acknowledges the scope for some small scale development and the graphic within the assessment suggests that this should be within the extremities of the existing development and bot push the settlement boundary further into the rural landscape. Public views from the existing settlement boundary are far reaching and it is possible to see Warwick from this point. The site is on the high point in a rolling landscape and therefore, it would be highly visible from a significant number of viewpoints including the surrounding public rights of way and Warwick to the east.
6.26. Centaur are concerned that the Landscape Assessment's conclusions that H51 could accommodate "small scale development" does not reflect the level of development which is proposed in the allocation (115 units). The allocation covers an area of land measuring some 5.5 ha, in a open field parcel measuring 10ha in size. With this latter point, the size of the 10ha field parcel could be more than able to accommodate the whole of the housing allocation for Hampton Manga without the need for allocation H27. This fact underlines, the difficulty associated with the allocations made by the Plan in the village and why both allocations are considered unsound.
6.27. In contrast, the Centaur site sits within a natural depression and is visually contained, unlike the land to the south of the village (allocations H51 and H27), although the site sites within a green landscape, it does not benefit from the rolling landscape views that make it highly visible. Therefore, it should be considered a suitable location for development on two grounds. The first being partly brownfield and therefore the allocation of this site would see it redeveloped and save a greenfield site from being lost. The second is the contained nature of the site makes it more suitable in landscape terms then the allocations being put forward within these modifications.
Sustainability Appraisal
6.28. An addendum SA has been provided with the modifications to the Local Plan. There is very little content within this addendum regarding the allocated sites beyond the content within the original Submission Local Plan SA Report February 2015. Within the 2015 SA, allocation H51 was rejected based on it having "some connectivity to the main settlement but potentially significant impact on nearby residents and little regenerative impact"
6.29. There is no justification provided within the modifications documents to justify how these sustainability concerns have been overcome.
6.30. Within the justification for the intensification of H27, the SA addendum states that the site has a medium to high landscape value, but that the intensification will save the loss of greenfield land elsewhere and that mitigation can overcome any significant effects. There is no justification for how any significant effects might be overcome, especially against biodiversity, or what the mitigation might be.
6.31. Referring to the 2015 SA, the reason for the Old Budbrooke Road site being rejected was: "located within a parcel of high landscape value - disconnected from the main village and its core services / facilities."
6.32. As highlighted above, the landscape assessment for the site is flawed as it has not considered the site itself, but combined it with a land parcel and the analysis of this has focused on the land to the north of the village. Therefore, the evidence base does not find the site itself as of high landscape value, in fact the evidence base is silent when regarding this site.
6.33. As for the site being disconnected from the main village, this analysis has not taken into account the wording within Appendix Vi of the SA. This clearly states: "With regard to travel and transport, the potential allocations have excellent access to public transport with a bus stop within 0 - 400 m and there are pavements which provide safe access for pedestrians into the village centre or to public transport"
6.34. It continues to note the distances for some of the sites from Warwick Parkway, namely the sites within 1km. it should be noted that the shortest walking distance from the represented site to Warwick Parkway is 1.2km, whilst for allocation H51 this distance is 1.4km. Likewise to the local shops and primary school both sites are equidistant.
Material Considerations : The Brownfield Register
6.35. It should also be highlighted that the modifications to the Local Plan does not appear to have considered the requirements of the emerging Planning and Housing Bill currently progressing through Government. This will require all authorities to maintain a register of brownfield sites that it considers suitable for housing development. As such, it is possible that the brownfield element of the represent site may come forward through this process anyway. However, if the Council were to allocate the whole of the Old Budbrooke Road site it could create a more suitable form of development that could to be comprehensively planned as one whilst delivering a level of housing suitable to the settlement.
Summary
6.36. Therefore, the Plan's evidence base clearly continues to contradict the allocations made in the plan.
6.37. In conjunction with previous representations, whilst Centaur seek the de-allocation of H51 in preference to its site, it also objects to the intensification of development on H27 and seeks this modification to be deleted.

See attached

See attached

See attached

See attached

See attached

see attached

see attached

see attached

see attached

See attached