The Sustainability Appraisal for the site is based on flawed and out of date data regarding flood risk, and in particular the flood risk posed to other properties. The Warwick DC SFRA used in the appraisal makes no mention of significant flooding that occurred in Kenilworth in 2012, or that Finham Brook is now part of an EA Flood Alert/Flood Warning zone. In particular there are houses situated downstream of the development that were flooded in 2012, that would be put at further risk due to run off from this development. The confusion in the Sustainability Appraisal continues in that Finham Brook is variously referred to as both a minor and main river (it is a main river). For more info on recent flooding, the Warwickshire County Council local flood risk management strategy published in Sep 2015 is a useful resource: https://askwarks.files.wordpress.com/2015/01/lfrms-and-appendices-2015-09-11.pdf
The PPG states:
Local planning authorities should use the Assessment to:
*determine the variations in risk from all sources of flooding across their areas, and also the risks to and from surrounding areas in the same flood catchment;
*inform the sustainability appraisal of the Local Plan, so that flood risk is fully taken into account when considering allocation options and in the preparation of plan policies, including policies for flood risk management to ensure that flood risk is not increased;
I do not see how the above can be fulfilled with an out of date SFRA.

I object to the development of Kings Hill Lane. My reasons for objecting are outlined below.

The neighbourhood borders on green belt land and is occupied by many families attracted by the rural aspect which would be destroyed by such a development. There is a huge quantity of brown field sites in both Coventry and Warwick that could easily be developed to accommodate the quantity of housing required without destroying green belt land that once utilised will be gone forever. Coventry's massive expansion of University accommodation shows what can be done if minded to do so. Without development, brown field sites will remain as eyesores and should be developed first.

The existing infrastructure cannot support an explosion in the number of residents in the area. The roads are already severely congested, lacking in ability to cope with the existing number of residents and in a dreadful state of repair. Schools and hospitals are already severely stretched and unable to cope with demand.

The neighbourhood is rural in nature and has a significant amount of wildlife that would be adversely impacted by a change to the environmental conditions in the area. There are protected badger setts, bats can regularly seen flying around the gardens and we have our fair share of squirrels, foxes and other wildlife, all of which would be seriously affected by any such plans.

Badgers and bats are protected species and there are also newts, dormice, butterfly's and moths in the area all of which are also protected by Schedule 5 of the Wildlife and Countryside Act 1981 which includes protection for the animals from injury and death, protection from being taken from the wild, and protection for the places they use for shelter and protection, as well as disturbance to an animal occupying such a place.

In addition, The Protection of Badgers Act 1992 protects badgers from cruel ill-treatment, including damage or destruction of their setts, or disturbance whilst a sett is in occupation. This proposed development would undoubtedly disturb the existence of sett's.

The area already has potential for flooding as can be evidenced any time there is anything more than routine rainfall in the roads adjacent to Severn Trent. Building on land that absorbs rainfall will exacerbate this problem hugely and inevitably cause issues for the existing residents of the area.

Overall these plans would destroy the rural character of the local area and neighbourhood, create adverse noise and disturbance affecting residents and wildlife, and breach established acts such as those cited above and as such the development should not be allowed to take place.

The Inspector correctly states at para 31 of his letter of 1st June 2015 that "The merits of individual site allocations and the assumptions about delivery have not been subject to detailed scrutiny at this stage in the examination." It is of major concern that the Modificatons now allocate additional sites rather than just indicating that there is more than adequate deliverable land to meet the housing need requirements of the Plan
By allocating certain sites and not allocating others, this implies that a fully transparent, public debate has taken place on an objective analysis of the selection criteria.
If it has not, then such a public debate should take place as part of the Examination in Public as the allocated sites, with consequent release from the Green Belt, are a fundamental part of the Modified Plan.

There is opportunity to make representation on the allocated sites but NOT on those not being allocated. Comparative comment must therefore be made in relation to a proposed, allocated site.
The site selection appears to be based on the Sustainability Appraisal Addendum Report of February 2016.

The Council makes a strong proposal to allocate land at Kings Hill and release it from the Green Belt. The principle of allocation in this area is not opposed - only the scale of release and the lack of clear and objective analysis of the site and the alternatives. As a result, the Modified Plan remains unsound and may also fail to be 'positively prepared' as it does not allow for proper public consultation on possible allocations of land and therefore does not give the required degree of certainty for residents and future residents.
In common with other possible sites for allocation, this land adjoins the built up area. The most significant and comprehensive study into the possible release of land from the Green Belt for development on the periphery of Coventry, which is fully in the public domain, was published in 2009. This study analysed all the potential development sites and classified them into the degree of constraint which applied to the land.

See the attached figure.

It will be noted that a large portion of Kings Hill was classified as "Least Constrained" but this does NOT cover the whole site which the Council now propose to allocate for development.
It is possible that the Council is merely being pragmatic and attempting to maximise the development in specific areas rather than positively choosing the least constrained land.

Land at Cryfield Grange / Land South of Gibbet Hill Road (SHLAA Ref C27/C28) has been proposed to the Council.
● It directly adjoins the built up area;
● 100% of the land was classified as "Least Constrained" (not just part)
● it is suggested that part of Kings Hill could be developed (but not extending too far from the built up boundary or into the area previously not classified as "least constrained") and the land at Cryfield/Gibbet Hill could be developed at the same time.
● Both areas are of very similar standard (neither being 'worse' or more constrained than the other);
● it would limit the geographic distance of new development from the current built up boundary;
● it would add diversity to the land choice available;
● provide enhanced competition; and,
● ensure early development would be achieved.

Comparison between Cryfield/Gibbet Hill and Kings Hill:

The Council has chosen to "allocate" land at Kings Hill (SHLAA Ref C06) in preference to land at Cryfield (SHLAA Ref C27/C28. The reasoning appears to be based on the Sustainability Appraisal Addendum Report Feb 2016 from Enfusion. An analysis of the reasoning shows very little objective difference between the two sites other than Kings Hill is larger and may apparently provide for a greater range of services within the site.
However, whilst the possible housing numbers are larger it is also recognised that the site contains a Local Nature Reserve, an area of Ancient Woodland, a Scheduled Ancient Monument and 3 Listed Buildings.
There are very positive comments on Cryfield/Gibbet that updated landscape evidence found that the site offers potential for expansion of the Gibbet Hill residential area...... and these matters are reflected in slightly higher scores than Kings Hill, in related objectives.
A significant difference is that Air, Water and Soil Quality Objective 9 rates as a Major Negative on Cryfield and a Slight Negative on Kings Hill. The narrative does little to explain other than it is not known on either site whether the land contains Agricultural Classification 3a or 3b with both having an area of Grade 2. The report then assumes that that Kings Hill would avoid the Grade 2 land but doesn't make the same assumption on Cryfield, which then obtains a more negative score.
Other than that, there is no material negative difference on Cryfield that should result in it not being allocated.
As another example, it is also noted that whilst the narrative for both sites indicates that some noise, light and dust pollution may be possible during the construction work, at Cryfield there should be no significant health disbenefits whereas at Kings Hill the potential effects appear to be less insignificant and in order to mitigate properly it would restrict the capacity of the site.
The effects on Biodiversity and associated landscape matters at Cryfield would be little or none whereas at Kings Hill it would appear that there is a far greater risk and the necessary mitigation has not yet been fully ascertained.
In most other respects (agricultural land quality, Green Belt, flood risk, landscape, etc) there is little or no objective difference although the summation seems to conclude a very minor preference for Kings Hill - partly because of the negative score for air, noise and soil quality(?) - see above.
Objectively, it is not believed that there is any material difference between the sites.
Whilst it is appreciated that that there may be a fine difference between the two sites with Kings Hill being "allocated" in preference it is not believed that the minor differences withstand objective scrutiny. As this allocation process SHOULD be objective, transparent and open to public input, it is suggested that the Plan is clearly unsound and has not been comprehensively prepared i.e. not positively prepared.

The original plan made no mention of Kings Hill. Coventry Council have been underhanded in taking Kings Hill out of greenbelt, without any consultation. There also has not been proper consultation by WDC with Coventry Residents. WDC assured me on an email that there would be proper consultations in Coventry regarding Kings Hill, with letter drops, radio station coverage in newspapers. There have been NO letters to residents in Finham and coverage very sketchy. A lot of residents are unaware of this consultation.

The amendment places the whole of H34 in the local plan. It has taken no regard of existing long term tenancies in the area and has been rushed through without proper consultation.

Local drinking water originates from a bore hole in Finham Brook Basin.

The scale of the proposed development is ridiculous. Finham currently has approx 1500 dwellings. The proposed plan will dwarf Finham.

Green Lane/ Kings Hill already has flooding problems.

2 Anglo saxon Sites, Ancient Arden Forest, protected oak trees and hedgerows will be destroyed.

No survey in relation to bats, crested newts and badgers. Numerous badger sets within this area.

Wainbody Wood is as least partly included in the plan and I understand will be destroyed to build Finham Railway Station.

For years the area has been affected by works, including Tollbar island. As well as the pproposal to build on all of Kings Hill, we will have HS2 being built across the Kenilworth/Coventry Road, with hundreds of lorries per day using this route. The Jag/ Landrover being built by Baginton Airport in Siskin Drive. How will the area cope with the scale of building and transportation/disruption.

Finally the gap between Coventry and Kenilworth will be reduced to less than half a mile. Extrodinary circumstances rule?

Coventry Council has falsely stated that they cannot fit 4000 houses within the Coventry boundary, meaning that Kings Hill needs to be built on. There are numerous sites within Coventry where housing could be built, but Coventry are taking the "lazy" option. If land is that precious, why are Coventry Council selling land within the City Centre to Coventry University for student flats. These could acccomodate Coventry housing needs. Coventry should be forced to provide a proper assesment of housing needs and possible locations.

If this change is made to the Local Plan it will have deleterious effects on traffic in and around the Parish of Stoneleigh. I would only be in favour of the Kings Hill development if a detailed proposal was made to improve traffic volumes and the free flow of traffic on the Birmingham Road and Coventry Road in Stoneleigh village.

Improvements such as a small bypass, one way traffic through the village and one way traffic over Stoneleigh Bridge have been discussed by Parishioners as appropriate alternative measures.

It is very clear that this could become a major development site. Without adequate prior infrastructure, this could effectively disrupt local services, facilities etc. As a resident of Stoneleigh with a growing traffic issue, we do not want any more traffic routing through the village, in fact we want less.Consideration has to be given to the route and connection Leamington to Coventry direction avoiding th Kenilworth Rd / A46 which routes traffic over Stoneleigh Bridge and through the village.

I cannot agree pr accept any development on Kings Hill Lane before getting action and clarity on road improvements around the village of Stoneleigh. I live on Coventry Road - the volume of traffic has tripled since I moved to Stoneleigh 16 years ago and is just not sustainable. I have to cross the road to catch my bus for work and there are not many of them so I have to leave my house at least 20 minutes before the bus comes into Stoneleigh so that I can try to safely cross the road. The volume and speed of traffic through Coventry Road and Birmingham Road is absolutely ridiculous in a conservation area .

H43 Kings Hill Lane proposal is unsound and fails to comply with the duty to co-operate. WDC has worked with CCC in a very closed manner to rush this plan through and avoid public involvement. The area cannot support that many housing units. There is not enough suitable land for building that many housing units, there is no room for adequate infrastructure inside or outside of the marked area, and it would eradicate the character and history of the wider local area by essentially concreting over the entire area of map 36 to attain that density.

As a resident of Coventry who has lived on the border of Warwick District Council for 40 years I am writing to place on record my objection to the plan to build on the area known as site ref H43 (Kings Hill).
I have listened to all the arguments both "for" and "against" and I can see no justification for building within this area. I request that these plans are reviewed and turned down on the basis that Coventry has more than enough of its own "brown field" sites to accommodate this house building plan.

King hill is home Badgers,Muntjac deer,Newts that populate the ponds on kings hill and numerous varieties of birds plus a bat colony .
The land contains the sites of a least two ancient Saxon settlements.
The land is prone to high levels of water in parts .
Why would Warwickshire build a stand alone development next door to Coventry AND Coventry allow this to happen if it were not to receive any benefit from it ie council tax. As i see it Finham would be over whelmed with the extra traffic, noise ,schools and medical services unable to cope. Green lane south in particular is no more than a country lane with its protected ancient hedgerow (mentioned in the Doomsday book) running down the road marking the border between the West Midlands and Warwickshire.Why not build onto existing Towns and Villages !!!!!.

The Alvis sports and social club is under threat from housing. The club is home to football teams of all ages young and older. There is a Netball team ,cricket teams and a bowling team plus a dominoes team and pool team.What would happen to this facility which supports the local community. Does health not matter anymore ?.
Kings hill is an area of beauty and should not be lost. It forms a natural screen of Coventry from Warwickshire as you travel along the A46. Houses would destroy this.Other areas should be considered first and foremost before green fields. Regeneration might cost more but would have less impact on the environment in the long term.

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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.

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The proposals would mean an equivalent number of houses of twice as many as are already in the Finham area of Coventry. This would need a large increase in the water treatment plant capacity.

Coventry is already densely populated, to propose this many new dwellings concentrated in one area will greatly exacerbate the situation.

There is no allowance for any green belt land between the two housing areas.
It seems a hurriedly prepared plan with no in depth study to its overall effects and with little time for proper public consultation.

There seem to be too many houses in one area, twice as many as are already in Finham area of Coventry. There is no allowance for any green space between the two areas.

I am concerned regarding our water supply which comes from the proposed building area and may become contaminated.

The plan will remove a large amount of arable farmland and concentrate and increase the carbon footprint in the area.

I refer to the above and in particular to the Kings Hill section. It is this section to which I object, for the following reasons for not developing:-

A) The plan area has been highlighted with complete disregard to those who live and work in the area. Even the ancient woodland is designated to go!

B) Not only does the highlighted area contain an ancient woodland (Wainbody Wood) which is a nature reserve, but the hedgerows have, as researched, been undisturbed for several centuries.

C) The area contains four working farms.

D) The area has two areas of Scientific Sites

E) The area has a Sports and Social Club that supports nearly 30 children's football teams (the biggest club in Coventry), adult teams, plus children's and adult cricket teams, plus children's and adult netball teams and a crown green bowling club.

F) The area has two education centres complete with greenhouses teaching those with learning difficulties.

G)The area has a Business Centre for small businesses.

H) Ancient Marl ponds are on the area.

I) Previous development plans have been turned down for access reasons.
a) When the A46 was built the offer of an access to this area was not taken up
b) Another enquiry advised only access should be from Stoneleigh Road and not from Green
Lane as this road was not capable of taking more traffic.

J) Stoneleigh Road already has a traffic flow of up to 776 vehicles per hour (Sept 2013). This road
is linking A46 to Warwick University and Westwood Business Park.
So adding up to over 8000 vehicles (2 per dwelling) does not make sense.

K) The plan mentions using Coventry Schools, both the Primary and Academy are already heavily
subscribed.

L) A few years ago land on Kings Hill was deemed not suitable for a Cemetery due to the water table (coffins not being retained in the ground). This plus using Green Lane as the entry/exit was
unacceptable as this road was incapable of accepting extra traffic.

M) How can a map be marked "railway station" just because a railway line is in existence? No explanation given. No size given, just a symbol.

Unoccupied houses in the West Midlands is 22257 with 3000 in Staffordshire. I am unable to obtain Warwick District or Coventry figures, however this scenario must be considered in your calculations and revealed.

It has not been stated what type of property is to be built or density.

A lot of basic information such as Medical, Schools, Shops, Community is missing leaving a lot of guesswork.

I will appreciate an acknowledgement of my letter so that should this fanciful idea of houses to be built on Green Belt, a railway station built on Green Belt and ancient hedges dug up continues in Warwick District Council's plans my objections can be referred to and not claimed to have never been received.

Should the approval be made I strongly believe that the full Government subsidy for the building of new houses should be revealed, what are Warwick District Council plans for using this money, and also what the Section 106 money is to be used for, plus how much money is received from the developers.

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We have carefully reviewed the modifications proposed within the document based on the Planning Inspectors Interim Report and we find the it meets the tests of soundness:
We agree that the plan is positively prepared, justified, effective and consistent with national policy with the proposed modifications.
We have the following comments to make:
Modification 15
We support the wording of the proposed modification. Modification 21 - Section 1.8
The Finham Brook, a designated Main River flows through the King's Hill site H43 near the southern boundary. We would support proposals to create land for open space and this should be linked in to the provision of green and blue infrastructure. Every opportunity should be taken to create additional flood storage to reduce the risk of flooding elsewhere. Ammendments to Policy DS11 Paragraph 2.4.1
We note that sites were assessed for their suitability against the SFRA Level 1. Warwick District Council's SFRA is dated April 2013 and we recommend that it is updated to take into account changes in Policy (NPPF) and the revised climate
change allowances. The Environment Agency updated their guidance on how climate change could affect flood risk to new developments - 'Flood risk assessments: climate change allowances' published on gov.uk on 19th February and came into immediate effect.
The update is based new scientific evidence. The main changes are to the peak river flow allowances. We are currently preparing new guidance which can be appended to the SFRA before the examination of the Local Plan is resumed.

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