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