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

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

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

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

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

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

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

see attached

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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