I am writing to you on behalf of the Burton Green Parish Council in response to the Amended Local Plan and in particular to the proposed development of 425 houses at Westwood Heath.
INTRODUCTION
I begin with a description of the main features of Burton Green and some of the problems we face, especially that of increased traffic on our roads.
I will endeavour to ascertain whether the proposal is legally compliant and whether it is in accord with the present Government's policy towards Green Belt and the National Planning Policy Framework. (NPPF) The subject of legal compliance is not always clear cut and is often a matter for the courts to determine but it does seem that the development at Westwood Heath rests uneasily with national policy and is at odds with the principles enshrined in the NPPF.
Thirdly, and perhaps more importantly, I question whether the development is sound and whether all the infrastructure implications have been addressed, especially in relation to sustainable transport. I will argue that the figure of 425 houses is not properly evidence based and that other information is needed for this proposal to go forward.
Finally I will examine other concerns we have about this proposal and the changes made to the original development at Burrow Hill Nursery.

BURTON GREEN
The village of Burton Green is a ribbon development which covers a wide area, including parts of Crackley but the parish boundaries have now been extended to include the ward of the University. Burton Green is a community of 387 houses, lying in a semi-rural, elevated position between Coventry and Kenilworth. Surrounded by Green Belt, the village benefits from open views across the countryside including ancient woods and hedgerows. Westwood Heath is an essential part of the landscape. It sits in the Crackley Gap and separates Burton Green from Coventry. Environmentally it is of a very high value. It is perhaps the most important open space in Burton Green with fantastic views towards the university. It is enjoyed by residents, walkers and even motorists and it provokes a feeling of well-being which will be lost forever if this proposal is accepted. Already Burton Green has been severely impacted by HS2 which goes straight through the heart of the village. Many residents have left because of the proximity to the route and their houses are now rented out by HS2 Ltd. A considerable amount of land has been set aside for the route while our special amenity, the Greenway, is irreparably damaged. Despite these setbacks, the sense of community remains very strong. We have taken on board the projected 30 mobile homes in Red Lane and have supported the development of 80 houses at Burrow Hill Nursery. However we believe that the Westwood development, which is far in excess of our present housing stock, is a step too far and threatens our community sustainability.
In our Parish Plan, Planning for the Future, April 2014, the aspirations and the concerns of our residents were noted. The respondents (at least 75% of households)" rated the openness/views, rural nature, village environment, trees, fields, verges, wildlife and Greenway as the most important aspects of the village" and it was considered essential that "people's views on what is really important to them about BG are reflected in the Neighbourhood Plan." (Page 8) Sadly this hope has been extinguished by the Revised Local Plan and certainly residents would be shocked and disappointed by the comments in Appendix 6, on the Site Appraisal Matrix, that "Burton Green has been identified as a growth village with a range of services and facilities."
In the Parish Plan, there were concerns about traffic, mainly on speeding and parking, but there was little mention of the volume of traffic on our roads. The situation is very different in 2016 from the time the Steering Group came together in 2012 and produced their report in 2014. Traffic levels are much higher as motorists drive along Cromwell Lane towards Westwood Heath Rd. on the way to the A45 or to the Science Park or to the University etc. I know from personal observation. I live in Cromwell Lane, opposite the water tower about 350 yards from Westwood Heath Rd. Today, Monday, April 11th, I did a simple survey of traffic between the hours of 8-25 and 9-25 travelling in the Coventry direction. Between 8-25 and 9-05, there were 361 motorists at an average of 45 motorists every 5 minutes with over 50 motorists in the time slots, 8-25 to 8-30, 8-30 to 8-35 and 9-00 to 9-05. Between 9-05 and 9-25, there were 101 vehicles at an average of 25. During the whole time, only 4 intrepid cyclists braved the traffic.
It may well be that the number of motorists is not that different from previous years but the problem has been compounded by the much higher levels coming from Tile Hill village, many from the new Bannerbrook Estate. Motorists coming from the opposite direction cannot turn right and consequently you can get a huge congestion of cars, very often outside my house. Burton Green residents are acutely aware of this problem. They have difficulty in getting off their drives and more seriously, pupils experience danger when they cross the road for the school bus to the Heart of England Comprehensive School in Balsall Common. I have spent some time looking at road transport in Burton Green at the present time but I will return to this subject when we look at the impact of the Westwood development of a further 425houses on transport links.
COMPLIANCE WITH THE LAW, GOVERNMENT POLICY AND THE NPPF.
As I intimated in the introduction, it is not always easy to interpret the law and I have not the legal expertise to tackle this subject. However it is the task of governments to determine policy and shape the law. In the Coalition Government, Eric Pickles, the Communities Secretary, and Brandon Lewis, the Housing and Planning Minister issued guidance to Councils on how to use their Local Plan. They were to draw on "protections in the National Planning Policy Framework to safeguard the local area against urban sprawl and protect the green lungs around towns and cities." Of course the Coalition is no longer with us but it would seem that the present Conservative Government is still intent on safeguarding Green Belt. In their Manifesto, there was a strong commitment to the Green Belt; "We will ensure local people have more control over planning and protect the Green Belt" and were ready to publish "planning guidance which reaffirms the importance of the Green Belt during Local Plan preparation." Of course, promises in manifestos may be ignored but to be fair to the present Conservative Government, ministers have shown a relish to implement Manifesto proposals.
But what about the guidance of the NPPF and what light does this show on the development at Westwood Heath? The answer is simple. This proposal to build 425 houses is in complete contradiction to the principles of the NPPF as is absolutely evident in Appendix 8 of the Green Belt and Green Field Review of November 2013. A series of questions are posed on a possible development at Westwood Heath which show conclusively that this development is not fit for purpose and here are a few of them.
Question 3. Would development in this area impact negatively on the visual amenity of the Green Belt?
Question 6. Would the loss of this Green Belt parcel lead to or constitute ribbon development?
Question 11. Would the loss of this Green Belt parcel result in a small settlement being absorbed into a large built up area?
Question 16. Would the loss of this Green Belt parcel reduce the defensible boundary between the existing urban area and open countryside?
Question 25. Would the loss of this Green Belt parcel reduce the character, identity or setting of a village or hamlet?
The answers are obvious and it would have been a massive shock if the District had supported an earlier development at Westwood Heath but are circumstances so exceptional to allow such an environmentally damaging proposal now? Does the duty to cooperate with Coventry mean that all environmental considerations are discarded? Moreover it is likely that this development will lead to changes in our boundary with Coventry and it would be no surprise if Coventry were to extend to the HS2 line. Burton Green has always been a target for Coventry and in the 1960s, an attempt was made to include it in Coventry's boundaries. The attempt failed but it now seems that the District is acquiescing in their demands. In their recommendations, they seem to suggest that the integrity of Burton Green has been protected by maintaining space between the development and the back gardens of properties in Cromwell Lane. But this development is in Burton Green but for how much longer? Of course, such a situation would be really attractive to Coventry as it seeks to extend its finances. With 70% of all Coventry homes within Council Tax bands A and B, (Coventry Local Plan, p45), the building of aspirational homes would be a great triumph for Coventry.
IS THE WESTWOOD HEATH PROPOSAL SOUND?
Warwick District seems to have absolute confidence that 425 houses can be built without any adverse impacts on road transport. It follows a "Do Nothing Option Scenario". It does recognise that there would have to be significant improvements to the strategic highway network, including the construction of a new link road between the A46 junction and Kirby Corner and onwards towards the A452 or the A45 if, for example, the safeguarded land lower down Westwood Heath were developed. But how can the Planners be so confident and how can they be so sure that 425 houses can be built without adverse impacts? Despite all the magic formulae, such as the Geoffrey E. Havers statistic, or all the advanced computer technology, predicting transport patterns is surely not an exact science. In Appendix 1 of the Sustainability Appraisal Addendum Report, it states that "there is an element of uncertainty for all the options as the precise nature and level of the provision or improvements to associated facilities/services and sustainable transport modes is not known at this stage." Likewise in the Strategic Transport Assessment by Vectors Microsim in Appendix A, 4-53, Crackley Lane would come under significant pressure at this time but it was not possible to identify what additional impacts may occur or what an appropriate mitigation strategy could be. Indeed the situation on the Crackley route appears precarious and in the Supplementary Analysis of the W.D.C.Strategic Assessment Phase 5, it concluded that with 425 dwellings, this route "is likely to be nearly over capacity." Yet despite these reservations, Warwick District have complete faith that 425 houses could be built without having any impact on existing transport links. Perhaps councillors and planners should consult the Warwick District Phase 5 Supplementary Analysis by Vectos Microsim. In the introduction, it notes "that some of the area of network which may be affected by the allocation of these sites is missing from the existing microsimulation models meaning it is not currently possible to fully assess impacts of these sites." On the other hand, it may be prudent to ignore the technical language of the planning fraternity and concentrate on more simple issues.
Warwick District focusses on housing within their area but seem oblivious of developments across their borders. The development at Westwood Heath is closely linked to that at Kings Hill but what about the possible housing developments in Coventry? Within a stone's throw of Westwood Heath Rd., Coventry could build 236 houses. If this proposal goes ahead, many motorists will head towards the University and will join up with the residents from the 425 houses in Westwood Heath. At the same time, Berkswell and Balsall Common will also need to build more houses under a revised Solihull Local Plan, and motorists from those areas will head for the already congested Cromwell Lane route and will join forces with motorists from the 90 houses at Burrow Hill Nursery. Faced with these pressures on our transport infrastructure, would it not be prudent for Warwick District to consider more carefully their proposal to build 425 houses at Westwood Heath? Perhaps understandably, Warwick District has rushed to find a solution without proper consideration in an attempt to secure a Local Plan which will stop property developers riding roughshod in the Leamington and Warwick area where there are ample opportunities to build on land which is not Green Belt. But it seems that there are sufficient grounds for rejecting the Westwood Heath proposal as unsound and surely if this consultation is to be meaningful, all interested parties should know what additional roads will be needed and where they will be located if Kirby Corner is to be joined up with the A46 and subsequently to the A45 or the A452.
In deciding on a figure of 425 houses, I am not sure what weight has been given to improvements in public transport. Obviously planners want to optimise public transport, but it is still doubtful, even with bus shelters at key stops, that residents will forsake their cars to join car clubs or participate in car sharing. (Appendices. Sustainable Transport Strategy Overview). It is perhaps a similar situation with cyclists. Burton Green would support improved cycle paths but how achievable is this objective? At this moment in time, if I were a parent, I would make sure that my children kept well away from Cromwell Lane and Westwood Heath Rd during week days. We also recognise that pedestrians should have access to green corridors but the reality is that pavements in Burton Green are in a very poor state and there is no money to repair them. It may be that some residents from the Westwood Development would walk to Tile Hill railway station, especially as it is increasingly difficult to park there, but it is doubtful whether improvements in public transport, cycle paths or in green corridors will have any real effect on the number of motorists going to work or dropping their children at school, thus increasing the numbers on Westwood Heath Rd. and Bockenden Road.
OTHER ISSUES AT WESTWOOD HEATH AND CHANGES TO THE BURROW HILL PROPOSAL
If the development at Westwood Heath does goes ahead, we would welcome a Health Centre and a retail facility but we do have serious concerns about educational provision in Burton Green. At first, we were alarmed to see that significant changes were made to the original Burrow Hill proposal. We were concerned that provision for parking had been removed and no mention was made of a playing field for the Burton Green Primary School but it now seems that the concessions to the School remain. However we are concerned that the increase to 90 houses is excessive and may have a negative impact on the development. The acquisition of the playing field does give the school some scope to expand but it is highly unlikely that the school can cope with the increased demand from a development of 425 houses at Westwood Heath.
In the Table of Proposed Modifications to the Publication of the Draft Local Plan, emphasis was placed on the need for educational capacity in a coordinated manner. But that is easier said than done. There is a shortage of places in Coventry's Primary Schools while the merging of Woodland Boys with Tile Hill Girls reduces the number of places in Secondary Schools, despite the emergence of Finham 2 at Torrington Avenue. It seems that there may be 2 Primary Schools at King's Hill but does that mean children from Westwood Heath will attend these schools? If they do, of course, it means that even more cars will be travelling on Westwood Heath Rd. than hitherto considered, making it imperative that additional roads will be required. Surely, if this consultation is meant to be transparent, knowledge of these roads should already be in the public domain.
CONCLUSIONS
1) The Westwood Heath development will have a massive impact on our community, already beleaguered by HS2. The projected houses, both at Burrow Hill Nursery and Westwood Heath, will be far in excess of our present housing stock and the openness of our village, which residents value so much, will be severely compromised. Burton Green's genuine concerns about the volume of our traffic will even more be exacerbated by this new development.
2) It is probable that the proposal is compliant with the law, (it is a matter for lawyers) but it certainly runs counter to supposed government policy and contradicts the guidance of the NPPF. The duty to cooperate with Coventry is a binding commitment but should it be at the complete expense of the environment?
3) It is doubtful if the proposal is sound and it would be a really interesting experience if planners were called to justify its soundness. Predicting transport patterns is not a precise science as some of their own literature makes clear. There are serious doubts about their research, especially on the Crackley route, and at times the Revised Local Plan seems rushed and incomplete.
4) The statement that 425 houses can be built without additional roads does not stand up to scrutiny and the failure to identify routes of possible roads to Kirby Corner and beyond is a serious failure and puts at risk the democratic process.
5) The Local Plan ignores the housing developments of our neighbours, whether in Coventry, Berkswell or Balsall Common which will impact considerably on Cromwell Lane and Westwood Heath Rd. All Authorities are under pressure to build more houses and it is likely that the pace will be unyielding in the years to come.
6) It is almost certain that improvements in public transport and in cycle and pedestrian pathways will have little effect in reducing the volume of traffic along Westwood Heath Rd., making it even more likely that the existing transport infrastructure will be unable to cope.
7) The development at Westwood Heath will have serious implications for educational provision in Burton Green. It could well be that the solution to these problems, especially in the primary sector, will result in further traffic on our roads.

Modification: Removal of land north of Milverton from the green belt
Mod Number: 16
Paragraph Number: 2.81
Mod. Policies Map Number: H44

Modification: Allocation of land north of Milverton for development
Mod Number: 14
Paragraph Number: Policy DS15
Mod. Policies Map Number: H44

In my opinion the Local Plan is unsound because it is not justified, effective nor is it consistent with National policy.

Warwick District Council ("WDC") has failed to demonstrate the EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt and to permit the proposed development.

Initially 250 houses are proposed to support Coventry City Council's housing need. In practice people who want to live and work in Coventry will not buy houses on land North of Milverton and, therefore, this development will not support Coventry's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton so as to reduce unnecessary commuting, inevitable congestion and further road construction. The proposed development is therefore not sustainable. In addition this is a very small development, which equates to an annual additional build of only 19.2 houses over the remaining 13 years of the Plan period. These houses could be accommodated on other sites and, therefore, the harm caused to the green belt by this development by reason of inappropriateness outweighs any potential benefit.

The proposed park-and-ride scheme is unsustainable because:
* There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
* The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
* Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers
* Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
* Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
* The proposal is predicated on a significant increase in car parking charges as an attempt to change behaviour and will have a detrimental effect on the Leamington as a Town Centre.

Additional land north of Milverton is to be "safeguarded" for development beyond the Plan period, to provide a further 1100 homes for Coventry. This will not support Coventry's hosing need because in practice people who want to live and work in Coventry will not buy houses on land North of Milverton. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to prevent unnecessary commuting, inevitable congestion and further road construction. The proposed development is therefore not sustainable.

WDC has also said that the "safeguarded land" north of Milverton could be used in the future to support Leamington's housing need. There are other green field sites that are available, and deliverable which should be used in preference. Therefore, WDC has previously accepted that the Exceptional Circumstances necessary to remove this land from the Green Belt to support Leamington's housing need do not exist. Nothing has changed which could alter this acceptance.

Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.

The proposed railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical.

The land North of Milverton is used by many people for recreation. If developed the residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.

The land North of Milverton has performed the requirements of the Green Belt and it should continue to do so:

* It has stopped Kenilworth, Coventry and Leamington merging. If this land is removed from the green belt the "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

* It has stopped Leamington "sprawling". Development stops at the green belt boundary

* It protects the historic setting for regency town of Royal Leamington Spa which will be destroyed if development is allowed.

* It has encouraged urban regeneration in the neighbouring towns

* It has safeguarded the countryside. If this land is removed from the green belt, highly productive farming land will be lost together with long established wild life habitat.

In order for the modifications to the Local Plan to become sound the land North of Milverton should remain in the Green Belt.

In total Warwick District Council has agreed to provide land for 6000 houses to meet Coventry's housing need. However the modifications to the Local Plan propose that only 2245 of these houses will be close to Coventry. The remaining houses will be located in Kenilworth, Warwick and Leamington. WDC's proposal to encourage commuting (most of which will be by road) on this scale is irresponsible and bad planning.

1) The Exceptional Circumstances required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.

2) The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land north of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.

3) In practice it is unlikely that people who want to live and work in Coventry will buy houses on land north of Milverton and therefore this development proposal will not support Coventry's housing need.

4) Precedence for releasing land from the Green Belt requires the "value" of potential sites in the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in co-operation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.

5) The rural gap between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

6) The attractive northern approach to Leamington Spa will be adversely affected.

7) Good farming land will be lost together with long established wild life habitat.

8) The residents of local towns will be deprived of an area which is highly valued and regularly used for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.



9) The proposed park-and-ride scheme is impractical because:-

a) There will be no dedicated buses, so users will have to time arrivals to coincide with the bus timetable.

b) The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.

c) Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers

d) Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington

e) A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical



As a solution the development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing in a more convenient location for the residents.

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.

I fully support the points made in the submission by the Hampton Magna Action Group (submitted by Martin Taylor) and have added my name to that submission.

However, I would emphasise/add the following:

1. I feel that the flaws in the process started with the identification of Hampton Magna as a Category 1 Village without any research into suitable sites available or the effect any development would have on the infrastructure. Once that decision was made the Council were compelled to identify a site(s) in the village and did not fully assess all available options. This is like ordering a new lounge suite without ensuring it will fit in the lounge! The government's policy is against green belt development except in very exceptional circumstances. The Council has failed to identify such circumstances.

2. I would refer to the report commissioned by the Campaign for the Protection of Rural England, which highlights major flaws in the assessment of housing need in Warwickshire and neighbouring Coventry and Birmingham and the lack of adherence to government planning guidance policy.

3. I can confirm that we regularly see bats flying over the land at the rear of Lloyd Close.

4. Hampton Magna will not only have to deal with significant housing growth in the immediate area but the school, GP and other amenities will also have to cater for 175 homes proposed at Hatton Park.

5. The development in and around Hampton Magna is grossly disproportionate with an increase of 41% in housing provision in the village.

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Consultation on Revisions to Warwick DC Local Plan
I am writing in response to the consultation on the revisions to the Local Plan which Warwick District Council is currently proposing. Specifically, I wish to object to the revised proposals for Hampton Magna, namely the increase in the density of housing on land to the south of Arras Boulevard, and the allocation of land south of Lloyd Close for 115 houses.
My objection addresses three issues:-
Whether the plan is legally compliant.
Whether the proposals are sustainable in the context of the district's needs
Whether there are alternatives which would better meet the needs.
There are a number of issues which potentially question whether the plan is legally compliant.
The change to the plan for Hampton Magna more than doubles the amount of housing proposed. As a consequence, the plan constitutes a major revision to the proposals. On the grounds of reasonableness, an issue governed by the Wednesbury principle, and indeed under the district council's own policies on communicating with local communities, there should have been consultation on the plan with Budbrooke Parish Council and the local community. There was none in advance of the proposals being published and agreed for consultation. Moreover, the documentation relating to the district council decision was not published until the latest possible date for the consultation, and it is in a form which is unintelligible to a layman.
Secondly, the plan considers proposals for Hampton Magna and Hatton Park separately. Other than a small local shop, there are no facilities in Hatton Park, and residents there use the facilities (school, GP surgery, etc.) in Hampton Magna. The impact of development in both Hampton Magna and Hatton Park should have been considered jointly, and has not been.
Thirdly, at a public meeting, residents of Hampton Magna were informed that the plan has been prepared only on the basis of taking account of land available for sale. This means that a substantial number of sites, indeed most sites, have simply not been considered. Given that a compulsory purchase process takes eighteen months typically, and the plan is for the period up to 2029, this again has to be of questionable legality in a Wednesbury context.
Finally, the proposals for Hampton Magna are all on land currently delegated as greenbelt. Greenbelt development is permitted in situations where an exceptional need is demonstrated. The revised local plan over-programmes the amount of housing required in the district by 800. This would tend to indicate that far from an exceptional need for greenbelt development, for the development of 800 properties there is, in fact, no need whatsoever. The threshold for exceptional need cannot, therefore, be met.
In summary, for the foregoing reasons, there is a significant question of whether the local plan is legally compliant, and I would contend that it is not.
The issue of sustainability relates to a number of factors;
i) whether infrastructure is sound and adequate and has both the capacity and capability to absorb additional load;
ii) whether there is adequate access to employment in a way which does not impact on the environment unduly detrimentally;
iii) whether it meets the district's housing needs in a reasonable way.
On the first of these issues, Hampton Magna has a range of community facilities, a school, a shop with post office, a beauty salon, and coffee shop, a public house and a GP surgery. These facilities are also extensively used by residents of Hatton Park which has only a small shop.
The school has room on site to expand, but parking around the school is a major issue, i.e. it is unsafe, and there is no possibility of sensibly absorbing the additional Hampton Magna and Hatton Park students. Other respondents have, I understand, included photographs of the current parking problems.
The GP surgery does not have room to expand in size, and already suffers from significant parking problems, with a very small number of parking spaces.
The most significant infrastructure constraint is provided by the roads into the village, all of which have severe restrictions. Ugly Bridge Road and Old Budbrooke Road have height restrictions. Both of these and Woodway have weight restrictions (which would have significant implications for developers' heavy traffic). All roads into the village are single lane at some point along their length (although Woodway purports to be two-way, which it is not). A study for the district council demonstrated that with only an additional 130 vehicles the road capacity would be exceeded in the morning rush hour, leading to routine traffic hold-ups. The revised proposal worsens this. There are no road proposals in the parish which would alleviate this (a proposed development at the A46 roundabout would have no effect on the parish roads. Even disregarding other impacts of the development, simply from a transportation perspective, any development on the scale proposed would require new access roads into the village from either the Henley road or the A46 directly.
Hampton Magna has had longstanding problems with its sewerage and drainage systems (the Parish Council have regularly met STWA and local councils about the issues). These would require major upgrading to cope with development on the scale now proposed.
Air quality in the village is poor. The revision to the plan is being proposed to take account of an additional housing need falling into the district from a corresponding shortfall in Coventry. It is, therefore, entirely likely that a reasonable proportion of new residents would have Coventry as their place of work. Despite Hampton Magna having excellent rail links, and some local bus services, travelling to Coventry by public transport would mean journeys in excess of an hour. In all likelihood, as a consequence, car usage would increase significantly in the village, further degrading air quality.
The proposed density of development is different to that currently found within the village, which is relatively low density with plenty of green areas and open spaces. Higher density development would change the intrinsic character of what is, despite it's relatively young age, a very rural village.
The proposal for Lloyd Close would also degrade the amenities of the village in two ways. Firstly, and recognising that no individual has a right to a view, the view across the fields to the south of Lloyd Close is an important public amenity, in that there are very few sites (the proposed area of development and Hampton on the Hill only, in all likelihood) where both of the historically important Warwick North and South Gates (St Mary's Church and Warwick Castle) can be seen together. As such, this is an important vista which should materially affect whether the exceptional use of a greenfield site can be considered in this context. Warwick has had a history of losing significant and important views (for example, through the development of the County Council's Barrack Street building), and it would be tragic to lose this as a public amenity. Secondly, the site, which has a footpath (dating back several hundred years) running across it, is used daily by walkers and dog walkers. Bats, a protected species, have also been reported on this site, and consequently a full survey should have been carried out.
The question of how the employment of incoming residents would impact on the village is an important one. There are very limited employment opportunities within the village. Good rail links exist to Birmingham and London, and intermediate stations, but, as stated earlier, public transport links to Coventry are very poor, and road links are along already heavily congested roads. Additionally, while rail links are good, parking at Warwick Parkway already operates at or near capacity, and four extensions to parking provision have already had to be made, with limited potential for further expansion. New residents from both Hampton Magna and Hatton Park would place additional demands on this parking.
Finally, an important consideration is whether the revised proposals meet the identified needs in the most appropriate way. A number of issues are relevant here.
As the additional need derives from a shortfall of housing in Coventry, having the largest proportionate increase in housing in a village 11.8 miles from Coventry, and without adequate public transport links to the city, is perverse.
The presumption of only using land available for sale was coupled with a wholly unreasonably short period for vendors to notify the Council of land availability (which was, I believe, only fifteen days) means that many potentially suitable sites have simply not been considered.
There is a Warwickshire village, Bubbenhall, which is much closer to Coventry (only 6.7miles), with similar facilities to Hampton Magna (and considerably better facilities than Hatton Park), and with considerably better transport links to Coventry, which has been excluded from consideration as a growth village, by the adoption of an arbitrary cut-off by the district council in a subjectively scored assessment matrix. This is unreasonable, and Bubbenhall should be reconsidered as a growth village.
If development at the revised level is required in Warwick, there are also freestanding greenfield sites (including a large site opposite Ajax football club on the Henley Road, which should have merited consideration for the development of a wholly new village (as Hampton Magna and Hatton Park were when they were developed). This would provide a number of advantages:-
The amenity of existing villages would be substantially unaffected.
The costs of creating the wholly new infrastructure required for a new village are much more readily determinable, meaning that the costs can be much more readily recovered through s106 agreements with developers, rightly limiting the costs falling on the public purse. Writing as a retired local authority treasurer, it is notoriously difficult to recover from developers anything like the full cost of enhancements to existing infrastructure for smaller scale developments.
A new development would much more clearly meet the threshold for exceptional development in the greenbelt, albeit subject to my earlier comment about whether any over-programming of provision could be considered legally to meet this threshold.
In summary, there are significant question marks about whether Warwick District Council's revised plan is legally compliant. There are further significant concerns about the sustainability of the revised proposals, and whether they provide for the most appropriate way of meeting the identified housing need for the district and the overspill need from Coventry. My conclusion would be that they do not.

I believe that Modifications 16 and 14 are unsound because:

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.

The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.

In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need. The costs of houses in the Leamington area will also be higher than in Coventry restricting the viability of people buying houses with the express purpose of commuting to Coventry. This is not the best financial option for the council in helping boost affordable housing.

Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.

The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
In short rather than adding value to the area this development will degrade it and create unnecessary pressure on the road network going in and out of Leamington - which is already stretched to say the least!

The proposed park-and-ride scheme is unsustainable because:
* There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
* The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
* Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers
* Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
* Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
* There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical
I believe that in order for Modifications 16 and 14 to become sound:

* The land North of Milverton should remain in the Green Belt
* The development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing.
* The road network is already overwhelmed and this whole project will be a stain on the green and pleasant land that is Leamington Spa.

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I have read the proposals in the WDC Draft Local Plan and would like to express my concerns and objections.


I would like to register a formal objection to the removal of land from the Green Belt north of Milverton, and the proposed building of 250 houses and park-and-ride scheme, followed by a further 1100 houses, railway station and commercial property within 5 years.

Whilst there may be need to provide additional housing in South Warwickshire in the future, it is not logical nor permissible to consider using this green belt land to support Coventry City's housing need. This proposal does not demonstrate removal of Green Belt Land in and around Old Milverton is a viable solution for that purpose nor does it have any merit in demonstrating Coventry folk both living and working in the City would contemplate buying houses in Old Milverton.

Traffic congestion in the Leamington/Warwick area is already a significant problem on both Southern and Northern entry/exit routes and whilst the suggestion of Park and Ride facilities are put forward it has not been demonstrated that residents of the proposed area will want to use the facility to travel into Coventry, and will certainly not use it for trips into Leamington Spa. They will use their cars.

The proposal for an additional railway station in the Milverton area again has no logic considering the existence of existing under-utilised facilities in inter alia, Leamington Spa, Warwick, Warwick Parkway and the Kenilworth facility under construction..

The "Exceptional Circumstances" needed to be demonstrated to allow a decision to remove this land from the green belt have not been demonstrated and do not, to my sight exist. To my understanding there are lesser value sites closer to Coventry which, on the basis of planning precedent, should be used in preference to the land in Old Milverton.

In order for Modifications 16 and 14 to become sound:

The land North of Milverton should remain in the Green Belt

The development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing.

Removal of green belt land of such high value - geographically, socially and agriculturally, would not be consistent with national policy.
Reasons for my objections are as follows:-
Milverton.
The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will want houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.

The proposed park-and-ride scheme is unsustainable because:
1. There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
2. The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
3. Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers
4. Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
5. Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
6. There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding

A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical.

The land North of Milverton should remain in the Green Belt. If it is lost, it is gone forever.
The development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing.
In short:
* There is no viable reason why green belt land of such value north of Milverton should be used to support Coventry City Council's housing need.
* The "Exceptional Circumstances" needed to remove this land from the green belt do not exist. There are lower value green belt sites closer to Coventry which on the basis of planning precedent should be used in preference to the land in Old Milverton.
* The idea that Warwick District Council should promote commuting from Old Milverton to Coventry is ill conceived, irresponsible and bad planning.

It is essential that the plan does not return to a scheme involving any development on the North Leamington Green Belt. The Green Belt in this area meets the 5 key roles of Green Belt and is an excellent and well used cultural and exercise related resource. Development in Kenilworth, Baginton and Lillington already take land from this essential Green Belt and further development on it would not be sustainable. It must not be permitted.
I would also like to make the following points:
1. A Joint Strategic Housing Needs Analysis is currently being performed with Coventry City Council. If this review identifies that it is necessary to increase the number of houses above those currently proposed I believe that there is sufficient non Green Belt land to accommodate this additional development.
2. The Revised Development Strategy has a fair distribution of new housing across the District. It is fair because there are still plans for new houses in the Green Belt at Thickthorn and Lillington as well as proposed development in villages.
3. The Revised Development Strategy proposes that most of the new development is located close to where employment opportunities already exist (e.g. industrial parks to the South of Leamington & Warwick) this provides an opportunity for people to live close to their place of work, reducing or eliminating commuting for many people, reducing pollution & improving quality of life. Furthermore there is ample space to build to the south of Leamington as the next nearest town is Banbury.
4. Focusing development in the South, in one broad area, ensures adequate public services can be provided and developed to meet the needs of the new population. These services can be designed to meet the exact needs of that new population and planned within easy walking and cycling distance, minimising traffic congestion. If development were to be more spread across the district public services would have to be developed in an inferior and unacceptable "make-do-and-mend" fashion which would provide poorer levels of service to both existing and new residents in those areas.
5. The Revised Development Strategy provides for improvement to the road network South of Leamington to relieve the existing congestion and to cater for the new development. The transport assessment clearly shows that development in the North would generate more traffic congestion in the district as it would have forced people to travel south to employment land, shopping (e.g. supermarkets) and the M40. Loss of vital Green Belt recreation land would also have resulted in more people travelling by car for recreation.
6. It is possible that mitigation methods may need to be employed in the Southern areas to reduce pollution and congestion but the work needed to do this would be less than for development in the North. For instance putting the country park in the South next to the existing houses, with new housing beyond it, would make the green-park more accessible. It could be crossed by cycle-ways and would act as a green-lung to reduce air pollution.
In conclusion the exclusion of development in the North Leamington Green Belt enables the plan to comply with the NPPF. Any attempt to re-introduce development in the North Leamington Green Belt would be unacceptable and be bitterly opposed as no exceptional circumstances exist; the land is a vital and immeasurable resource for the future of the district and is critical to its future sustainability.
Development in the South reduces traffic congestion and reduces air pollution, it enables better provision of public services and other facilities with better access to the employment hubs in the South.

see attached

A C Lloyd Ltd
Land at Blackdown, Leamington Spa.

1. An objection is submitted to Modifications 16, 19 and 22 on the basis that inadequate provision has been made for the removal of land from the Green Belt to meet 'longer term development needs stretching well beyond the plan period'.

2. The District Council has found it necessary to define Green Belt boundaries on an exceptional basis - fundamentally to promote sustainable patterns of development.

3. It is noted that in New2.2 as part of Modification 23 "The Council recognises that there is a limited amount of suitable land currently available outside of the Green Belt to meet long‐term development needs, particularly those needs arising in Coventry. Therefore identifying 'safeguarded land' in appropriate locations may assist in meeting the long‐term development needs of the functional housing and economic market area".

4. Therefore, it is clear that there is no realistically foreseeable planning strategy whereby development needs of the District in the next plan period can be met, other than requiring the use of land which is presently designated as Green Belt.

5. In the context of paragraph 85 of the Framework, we submit that insufficient provision has been made for safeguarded land , to meet development needs 'stretching well beyond the plan period' and that Green Belt boundaries will not need to be altered at the end of the plan period.

6. Furthermore, in terms of geographical provision of safeguarded land only two large scale sites are relied upon to meet future development needs , namely north of Milverton and south of Westwood Heath Road bordering the administrative area of Coventry.

7. In the context of the urban form of Warwick and Leamington Spa, the scale of Safeguarded Land should be increased so as to avoid subsequent redrawing of Green Belt boundaries in the roll forward of this Local Plan, A spread of sites should be identified which can promote sustainable patterns of development, promoting housing choice of location and increasing the propensity to increase the delivery of housing.

8. The site edged red on the accompanying plan identifying land south of Sandy Lane, Blackdown is not proposed for release from the Green Belt as an allocation for housing or safeguarded land in Proposed Modifications to the Local Plan as submitted for Examination, although it was proposed to be released from Green Belt and allocated for housing in earlier versions of the emerging Local Plan.

9. The Preferred Options Document, which was published for consultation between June and August 2012, proposed the release of the land from the Green Belt and the allocation of the land together with other sites to the west and the east.

10. We have attached a Plan taken from the Local Plan Preferred Options which shows the location of the proposed sites around Warwick, Leamington and Kenilworth. Policy PO4, proposed to allocate the site as part of an overall allocation of 1,170 dwellings with employment, open space and commercial at Blackdown.

11. As would be expected the Council undertook an assessment of the site to assess whether exceptional circumstances existed that would justify the release of land from the Green belt. The document comments as follows:

7.26 The northern, western and eastern edges of Warwick and Leamington and the whole of Kenilworth are bounded by the southernmost section of the Warwickshire Green Belt. If development is to be distributed across the District it will be necessary to alter the boundary of the Green Belt. NPPF states that, once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. Further, when reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development.

7.27 Exceptional circumstances can include the need to accommodate housing and employment growth to meet the needs of a community where there are insufficient suitable and available sites outside of the Green Belt. Where it can be justified to review the Green Belt boundary in order to accommodate development, it is necessary to assess Green Belt land in terms of its contribution towards the five "purposes" of including land in the Green Belt (NPPF Para 80). The Joint Green Belt Study [2009] carried out such an assessment of parcels of Green Belt land on the edge of Warwick, Leamington, Kenilworth and Coventry.

7.29 In the case of meeting the housing needs of Warwick, Leamington and Whitnash, the SHLAA identifies a potential capacity within the urban area of 650 dwellings on sites of 50 or more. Outside of the built up area, and outside of the Green Belt, the SHLAA identified a capacity of 7,200 dwellings. These sites are concentrated in the area around Europa Way, Gallows Hill and Harbury Lane as well as to the south and east of Whitnash.

7.30 The Council has concerns about focussing around 6,000 new homes in such a concentrated area. The reasons for this include:
* The impact on infrastructure, in particular transport and the increased car journeys between the Europa Way area, the town centres and the M40
* The continued southerly spread of development and the impact of closing the gap between Warwick /Whitnash and Bishop's Tachbrook
* The lack of choice of location of new housing and uncertainty about the ability of the markets to deliver this level of development in the locality within the plan period

7.31 There are advantages to locating some development to the north of Leamington Spa and Warwick. These include:
* The possibility of including some employment land within the development - employment areas are currently concentrated in the south of Leamington, leading to many cross town centre trips
* Greater choice of location of new homes
* The benefits which could be realised from the construction of a northern relief road which would relieve congestion on through routes between Warwick and Leamington town centres

7.32 Assessment of Green Belt land to the north of Warwick and Leamington in the Joint Green Belt Study concluded that the land bounded by the A46 in the west, the River Avon to the north and Sandy Lane to the east was worthy of further study. This was largely because there were no other towns to the north, from which the Green Belt would provide protection from encroachment, but also because there were other physical barriers to the wider open countryside. The Green Belt assessment suggested that the land at Blackdown was not suitable for further study. However, the land has similar characteristics to land to the west in that there are no towns to the north, from which the Green Belt would provide protection from encroachment, and there are clear boundaries to the site to protect the open countryside beyond.

12. As can be seen from above, the Council itself did demonstrate that exceptional circumstances existed which justified a Green Belt release and specifically included the land south of Sandy Lane, Blackdown as part of the Blackdown proposed allocation.

13. We agree with the Council's previous assessment of exceptional circumstances in terms of paragraphs 84 and 85 of the Framework. If such an approach was valid as a Green Belt analysis in 2012, it is logical that a similar conclusion should be reached now if it was necessary for the Council to release land from the Green Belt. It should be noted that this was against the backdrop of a proposed housing requirement of 10,800 dwellings between 2011 and 2029.

14. Subsequently the Council amended their proposed allocations. A revised document, The Revised Development Strategy was published for consultation between June and July 2013. Following the June/July 2012 consultation, the Council revised the broad locations for development. This was partly due to the consultation responses, but also as a result of new information on the ability of non-Green Belt sites to the south of Warwick, Leamington and Whitnash to absorb new development. The analysis of representations received following the June/July 2012 consultation showed considerable opposition to development in the Green Belt to the north of Warwick and Leamington, particularly if there were alternative non-Green Belt locations to the south of the towns. Further, there was a general desire for more development to take place on brownfield land.

15. In the light of representations received and new evidence, the Council re-examined the capacity of non-Green Belt land, to the south of Warwick/ Leamington/ Whitnash, and brownfield land to accommodate new development. Therefore the Green Belt release north of Leamington Spa were dropped from the Plan.
16. This strategy eventually evolved into the submitted plan (January 2015) which was considered at the Examination in May 2015 based on a housing requirement of 12,860 between 2011 and 2029

17. The proposed Modifications are based upon an updated Assessment of Housing Need (Coventry‐Warwickshire HMA September 2015) which sets out the objectively assessed future housing needs of the Housing Market Area and the six local authority areas within it. The report indicates that Warwick District's Objectively Assessed Housing Need is 600 dwellings per annum, which equates to 10,800 dwellings over the plan period. However, in recognition that Coventry City Council is unable to accommodate its housing needs in full within the City boundary, the Local Plan seeks to provide for 332 dwellings per annum (5976 over the plan period) towards Coventry's housing needs. Warwick District therefore aims to meet its housing requirement by providing for a minimum of 16,776 new homes between 2011 and 2029.

18. Consequently, part of the housing requirement set out in Proposed Modification 4 - Policy DS6 seeks to meet Coventry's housing need.

19. In January 2016, there have been a two appeal decisions (The Asps (Appeal Ref 2221613) and Gallows Hill (Appeal Ref 2229398)- combined capacity of 1350 dwellings. Neither of these sites were proposed as allocations in the Submitted Local Plan. As a consequence of these decisions the Council now proposes to introduce a new allocation north of Gallows Hill for housing.

20. It is possible that the appeal decisions at the Asps and Gallows Hill may have impacted upon the Council's strategy for Green Belt release north of Leamington Spa.

21. It now even more the case that nearly all of the non-green sites suitable for development south of Warwick/Leamington have been identified. Thus one of the principal reasons for rejecting the option of further release of land from the Green Belt to meet the growth of Warwick District has been superseded - notwithstanding the Coventry factor.

22. As a result, WDC has as part of the Proposed Modifications process identified Green Belt releases (Proposals H44 and S2) north of Warwick/Leamington in terms of this being a sustainable location in terms of paragraph 84 of the Framework. Provision is also made for an area of search for a Park and Ride. However, the extent of this area of search is confusing as it appears from the Proposed Modification to the Policy Map (Leamington, Warwick and Whitnash - Milverton Extract to include land east of Kenilworth Road in the vicinity of Blackdown.

23. The Council has concluded that it is 'necessary' to identify areas of safeguarded land between the urban area and the Green Belt to meet longer term development needs (Framework 85, third bullet point).


24. While the potential capacity of the two areas of land identified under Policy DSNEW 2 (Sites S1 and S2) are not identified, a reasonable assessment may be:

S1: Land south of Westwood Road
Circa 1000 dwellings (on basis the Safeguarded Land is about twice the allocated site H42 (capacity 425)).

S2: Land north of Milverton
Circa 700 dwellings (on the basis the area of Safeguarded Land is about two and a half times the allocated site H44 (capacity 250 dwellings)).

25. Some basic principles should apply in the identification of Safeguarded Land:

i. While housing is the largest scale of development need in terms of land take, it should not be assumed that land is identified as Safeguarded Land solely for the purposes of accommodating future housing needs. Other spatial development needs, including for example provision for employment, education, health may require land beyond the limits of existing built up areas that are bounded by the Green Belt.

ii. Paragraph 84 makes it clear that national planning policy expects a review of Green Belt boundaries to 'promote sustainable patters of development. Paragraph 85, confirms that where necessary (as in Warwick DC's case) the LPA should identify 'safeguarded land' , so as to meet longer term development needs well beyond the Plan period. As such, national planning policy seeks the safeguarding of a sufficient quantity of land to meet reasonable expectations as to development requirements for a period well beyond 2029.

iii. The third bullet point of paragraph 85 is to be read with the fifth. Unless sufficient provision is made for Safeguarded Land, then there is a real risk that the boundaries of the Green Belt will need to again be reviewed at the end of the Plan period to accommodate future development needs.


26. While it is recognised that the allocation of land is to meet development needs in the Green Belt is contentious with local communities - often on a less than full comprehension of the Green Belt policy - confidence in the proper application of Green Belt policy is likely to be undermined to a greater extent with the local community if in the review of the Local Plan - which may be anticipated to commence within 5 years - proposes new proposals for redefining Green Belt boundaries.

27. As such, it is submitted that the public interest - and confidence in the plan-led planning system - is better served by excluding more land from the Green Belt and safeguarding, rather than making an inadequate provision which then requires further alteration of Green Belt boundaries on the first review of the Local Plan. In that way, provision for Safeguarded Land is made to meet longer term development needs 'stretching well beyond the plan period.'

28. The fact that the precise scale of development needs for the Plan period beyond 2029 cannot be determined - does not make ineffective the process of identifying adequate Safeguarded Land - and should not be considered 'consistent with the national planning policy' as a reasoning for not making further provision.

29. For the current plan period, the Plan proposes the alteration of Green Belt boundaries to make provision for residential development at the following locations:

Location Site Ref No of Dwellings

Red House Farm, Leamington Spa H04 250
Rouncil Lane, Kenilworth H12 130
Thickthorn, Kenilworth H06 760
Southcrest, Kenilworth H40 640
Warwick Road H41 100
Westwood Heath H42 425
Kings Hill H43 1,800
North of Milverton H44 250
Oak Lea Farm, Finham H08 20
Baginton H19 80
Burton Green H24 90
Cubbington H25, H26, H50 195
Hampton Magna H27, H58 245
Hatton Park H28, H58 120
Kingswood H29, H30, H31, H32, H33 56
Leek Wootton H37 5



30. This scale of necessary release of land from the Plan period may be compared to the provision for Safeguarded Land of circa 1,700 dwellings - of land that may not be required only to meet residential development needs.

31. It is submitted that this scale of provision cannot reasonably be considered consistent with national planning policy to 'meet longer term development needs stretching well beyond the plan period'. If a basic proportionate assessment is made, this scale of provision would extend about 3 years into the roll forward of the Plan period.

32. A response to the plan - making adequate provision for longer term development needs is a claim that the land will be released unnecessarily for development, as though the notation Safeguarded Land weakens the management of development by the LPA. The fourth bullet point of paragraph 85 of the Framework dispels this fear.

33. Indeed, in research undertaken for the report 'The Effectiveness of Green Belts' [1993], this concern was examined for an evidential basis. The Report concludes:

'Three further arguments against safeguarded land were put to us. It was suggested that safeguarded land would attract much extra speculative activity, and its maintenance would therefore be impossible. There was little evidence however to demonstrate this.'


34. In conclusion, we consider that land south of Sandy Lane, Blackdown should be released from the Green Belt and be identified as Safeguarded Land as part of the Local Plan process for the following reasons:

* WDC has previously identified in 2012 that exceptional circumstances do exist which would justify the release of the subject land from the Green Belt. These exceptional circumstances apply equally in 2016, in the context of ensuring that the Green Belt boundary should be capable of enduring beyond the plan period.

* The Council has provided no evidence to demonstrate that it can be satisfied that the proposed Green Belt boundaries are capable of enduring well beyond the plan period. Indeed the disproportionate provision of Safeguarded Land suggests that Green Belt boundaries would need to be altered at the end of the plan period.

* As part of this Local Plan process, the Council has previously moved away from a Green Belt release option due to further information being available which meant that more non-green belt land could be released south of Warwick/Leamington. However, most of the land suitable for development south of the town have now been identified as proposed allocations or has planning permission and there appears to be a view amongst the general public that south of the town has had enough.

* The level of housing requirement in the district has been increasing consistently. There is no sign that this growth will tail off at the (contrived) end of the plan period in 2029. Thus, more land is likely to be required in the Housing Market Area beyond 2029.

* The analysis that informed the 2012 Preferred Options Local Plan i.e. Blackdown, and the subject land in particular, demonstrates that the land can be released from the Green Belt. This analysis forms part of the Council's Local Plan evidence base and is contained within a document entitled 'Options for Future Urban Expansion in Warwick District Considerations for Sustainable Landscape Planning - Richard Morrish Associates November 2012.

35. Having regard to the above, we conclude that exceptional circumstances exist which justify the release of land south of Sandy Lane, Blackdown from the Green Belt in the context of paragraphs 84 and 85 of the Framework. The land should be identified as safeguarded land.

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