COMMENT on para 7.14

Sprawl is a pejorative word and its use to describe proposed new development around existing towns is not considered helpful and should be avoided. If the Council is referring to the need to avoid poorly designed urban extensions then it would, we consider, be preferable that this is stated in the plan instead.

COMMENT

A total of 10,800 new homes are proposed to be applied to three separate year periods that make up the 18 years of the plan (2011-2029); as the plan will not be implemented until its adoption in spring 2014 this effectively means that the overall housing provision is to be applied to three separate 5 year periods that make up the remaining 15 years of the plan following adoption.

Unfortunately no explanation is provided in the plan as to why the Council considers it appropriate to phase housing delivery and what the anticipated benefits would be in following such an approach. Having regard to the SHLAA (May 2012) and potential housing trajectory (Chart 7.1) it would appear that the sub-division of the plan period is an estimate, based on current data, of how long it may be expected for development momentum to pick-up and on the earliest practical delivery of the larger site allocations. We also recognise that phasing can have an important role to play in helping ensure that new development keeps pace with infrastructure delivery. Nonetheless, even if the above is the reasons for introducing phasing in the plan, we would like reassurance from the Council that it is not intended act as a cap and/or a break on housing delivery where infrastructure necessary to support the planned development is either already available or planned to be delivered in parallel with proposed new housing.

COMMENT.

Table 7.1 sets out the details of the number of dwellings which the Council believes need to be allocated in the plan once committed housing sites (1,224), small urban SHLAA sites (290) and other windfall housing sites (2,300) have been subtracted from the overall District housing provision figure 10,800 (2011 to 2029). On reading the SHLAA we understand that the Council has assumed that all existing housing commitments will come forward and, along with newly emerging windfall sites, will provide the housing supply over the next 3 to 5 years. However, given the volatile state of the housing market in recent years and, amongst other things, the reduced likelihood of public funding being available for infrastructure, we feel the that the Council's assumption that 'suitability' equates to 'deliverability' is overly simplistic. Furthermore, we believe that the SHLAA should not have assumed that all existing housing commitments will come forward in the first phase of the plan.

In accordance with best practice, the housing trajectory and the five-year supply of specific deliverable sites in the SHLAA should be based on whether:
* sites with planning permission are now under-construction and what progress has been made;
* planning applications have been submitted or approved on sites and broad locations identified by the Assessment;
* progress has been made in removing constraints on development and whether a site is now considered to be deliverable or developable; and
* unforeseen constraints have emerged which now mean a site is no longer deliverable or developable, and how these could be addressed.

It follows that as part of the SHLAA all commitments should have been assessed as to when and whether they are likely to be developed and phased accordingly. More specifically with regards meeting the 5 year housing land supply requirement, sites should be completely removed from said supply if new evidence questions their 'availability' or 'achievability'. In the absence of such an assessment we consider that it would be appropriate to apply a 10% reduction to the amount of dwellings expected to come forward from existing commitments to reflect the likelihood that not all planning permissions will be implemented.

A 10% reduction in the stated overall number of committed housing sites would be 122 dwellings. Table 7.1 should be adjusted accordingly with the 'balance to be allocated in the plan' increased from 6,986 to 7,108 dwellings

CORRECTION

The individual elements presented in Table 7.2 sum to 8,330 dwellings, not 8,360 as presented.

Land north of Gallows Hill/west of Europa Way is a highly sustainable and logical location for meeting a significant share of the identified growth needs of the District, and its inclusion under policy PO4 as a strategic site allocation is fully supported.

While EWC and WCC (Physical Assets-Resources) support the allocation of land north of Gallows Hill/west of Europa Way, we wish to take this opportunity make the following comments about other aspects of the policy which relate specifically to this site:

* No. of dwellings. Based on our own detailed analysis of the site, we consider that the site can deliver in the order of 1,250 dwellings at an average density which is in line with the standards proposed in the Council's garden cities prospectus. An allocation of 1,250 dwellings was previously proposed for this site by the District Council in the Preferred Options version of the Core Strategy, and this quantum of housing we feel makes best use of the site and will help deliver much needed housing in a highly sustainable location.

* Phasing. We support the Council's decision to identify land north of Gallows Hill/west of Europa Way as a site allocation to be brought forward during Phases 1 and 2 of the plan. It is our clients' intention to bring development forward on the site as soon as practicable and, responding to market needs, to deliver as much development as possible within Phase 1. In the interest of ensuring that development is not unnecessarily hindered as a result of the proposed phasing, we consider that it would be helpful if clarification was provided on how development phases are to be interpreted, applied and, as necessary, monitored. If a phasing policy is introduced it should maximise flexibility so that sites can be brought forward and developed in line with market demand and infrastructure provision.

* Land Uses. We note that under Policy PO4 that the Council has proposed that all of the "strategic site" allocations (i.e. sites of 500+ dwellings) will also include a "full range of supporting uses" including employment. Neither the policy nor the stated justification for the preferred option explains why employment is considered a "supporting use" to each individual strategic housing site allocation. It is our assumption that, irrespective of the wider local land use context, WDC is calling for some employment on each site in the belief that doing so will deliver a mixed-use development, which itself is synonymous with improved sustainablility over dispersed land uses. However, mixed-use developments can be found in a range of locations, and vary significantly in terms of the scale, type, volume of activity generated by different uses and, ultimately, the benefits they offer.

With specific regard to land north of Gallows Hill/west of Europa Way we consider that simply by providing residential development within this part of Warwick, the result will be a more sustainable pattern of development through the creation of a better mix of land uses; the site is already surrounded by employment opportunities which are within easy walking /cycling distance including, but not limited to, Warwick Technology Park (WTP), Tachbrook Park, Spa Business Park and Heathcote Industrial Estate. Furthermore, having regard to the existing employment land supply within the District (78.91 hectares of B1, B2 and B8; AMR December 2011) we contend that there will not be the market for additional employment land in this part of the District, especially during the first phase of the Plan. This argument is reinforced by the recent decision to grant planning permission for housing on part of Tournament Fields, a site allocated for employment use and recognised by the Council as one of the District's most important employment opportunities currently available to meet future needs. If additional demand were to arise, we believe that there is already enough committed employment sites across the district including Warwick Gates/Gallagher Park and Tournament Fields, plus other better placed sites which could come forward (e.g. land immediately opposite WTC/ south of Gallows Hill).

* Garden cities. We acknowledge and broadly welcome the Council's commitment to bringing forward new sustainable development which accords with 'Garden City' principles.

Warwick Gates Employment Land. Under Policy PO4 it is proposed that the committed employment site at Warwick Gates (9.77 hectares, SHLAA) is developed for housing (200 dwellings), and that this site is brought forward in Phase 1 of the plan. In the 'Economy' section we are informed at Para 8.29 that the Council believes that the employment site is in the wrong location and that a compensatory provision of employment land located in the vicinity of WTP would have a number of advantages. However we have not seen any evidence to back the advantages claimed and wish to contest each here:

o Support the clustering of industries and expansion of knowledge based sectors.

It is our considered view that the Warwick Gates employment site is, in terms of its proximity to WTP, well located to encourage both the clustering of industries and expansion of the knowledge based sector. This view was shared by the Inspector at the last District Local Plan Inquiry who, in his response to proposals for additional employment land opposite WTP, stated in his Report that "In terms of synergy with the adjacent Warwick Technology Park and the HTC [High Technology Corridor], I am satisfied that sufficient committed sites [Warwick Gates/Gallagher Park] are available nearby of such a quality as to accommodate those needs without expansion into the adjacent rural area" (para 10.3.48). Although our clients' site sits adjacent to WTP, there are no existing pedestrian or vehicular links between the two and, given existing development on WTP and local topography (WTP sits in a 'bowl'), no prospect of any being established in the future. Therefore we strongly disagree with the suggestion that having employment on land north of Gallows Hill/west of Europa Way would better than the existing Warwick Gates site in supporting the clustering of industries and the expansion of the knowledge based sector.
We acknowledge that the Warwick Gates site has sat undeveloped for many years but do not believe that this is because it is in the wrong location to be attractive to the market. The site lies in a prominent position on the main southern route into Leamington and is within easy access of the M40 - a 'premier location' according to the Council's Employment Land Review. The reason why the site has not yet been developed is most likely the result of one or more of the following factors:

* Current economic climate

* Ineffective marketing
At the time of the last District Local Plan Inquiry the Inspector remarked in his report (para 10.3.46) that he believed that the Warwick Gates employment site was not being marketed aggressively. In the Council's Employment Land Review - Final Report (April 2009) the authors of the report state that the site is "possibly being held back for future residential use" (para 2.90).

* Existing planning permission
The existing planning permission on the site is for a mix of businesses uses; B1, B2 and B8. For this site to attract the kind of companies which are now found on WTP, then the site should be reallocated for employment under Use Class B1a and B1b. Doing so should help provide confidence to the market that investment in the site would not be undermined by incompatible neighbouring industrial uses.
o increase opportunities to utilise existing infrastructure

It is unclear what the Council's is referring to here. The Warwick Gates site is clearly already well placed to take advantage of /utilise existing infrastructure, and that it would be the case that providing an 'alternative proportion of land' would in fact require new infrastructure to open up and service the site.

o support the development of new infrastructure to serve the needs of businesses such as a Park and Ride.
While we see some possible benefits of providing a Park and Ride facility to the south of the urban area, including less congestion and reduced CO2 emissions, we do not support proposals for such a facility in the area depicted on Map 5 in the Preferred Options. The term "Park & Ride" (P&R) refers to remotely located car parking linked by an attractive public transport service with the key urban or other high demand centre(s) it is designed for. Therefore we cannot see how a P&R located adjacent to or actually part of an employment development within the urban area can serve the needs of business in the area (nor potential users of the service generally). To have any chance of being effective, a P&R needs to be located either on the very periphery of the urban area/ or beyond it to capture 'customers' before they are caught in the very traffic they wish to avoid (please also refer to separate comments on P&R proposals under Policy PO14: Transport)

Whilst we object outright to the proposed allocation of housing development on the Warwick Gates Employment Land site, we also object to the allocation being identified for 'release' in Phase 1. Having regards to its location, the site would be poorly served by community infrastructure and given its size would not provide the critical mass to support service on site. With specific regard to secondary education, the development would fall within the catchment of Myton School and the likely take up of places at that school as a result of the new development may have negative consequences for how much development could be brought forward at the same time on the Myton Garden Suburb site in Phase 1 if there are insufficient secondary school places available locally.

The policy would benefit from clarification as to what "Larger sites" means under bullet 'A'. We note that on page 21 the plan also refers to "Strategic Sites". If they are one and the same, this should be clarified.

Under bullet 'A' the Policy states that a 'Development Brief' will be required for all "Strategic Sites" of over 500 dwellings and that said brief would be prepared jointly by the Council and developers in consultation with the community. In principle, we do not object to the requirement but believe that additional information is required to explain what the purpose of the briefs will be, how they will be brought forward and whether or not it is the Council's intention to formally adopt the document. Regards the last point we would be opposed to the documents being formally adopted on account that it would, due to consultation requirements and ratification by the Council, add further delay to sites being brought forward and developed.

South of Gallows Hill/ West of Europa Way.

The proposed allocation of 1,600 in this location is not supported. It is our considered view that an allocation of this scale, in this location would result in an un-sustainable form of development. The proposed allocation, as graphically shown on Map 5, does not encourage a compact urban form but instead would result in a linear form of development stretching out into open countryside. With no existing services within a reasonable walking distance, and prospects for viable new or improved public transport services in the area considered limited, we believe that the allocation would encourage car based journey with resultant negative impacts on existing local highway infrastructure and traffic flows, in particular, those along the A452 (Europa Way).

It is interesting to note that this site was previously submitted to the Council for housing development as part of the preparation of the Core Strategy. However, based on an assessment of the sites availability, achievability and suitability as a housing site, it did not make it on to an 'Amber' list of potential sites to be considered as part of the Strategy. The Amber list was further whittled down to a list of 'Green' sites which was taken forward and included in the Preferred Options version of the Core Strategy.

COMMENT

An explanation should accompany the Council's view as to the potential housing trajectory over the course of the plan period as illustrated in Chart 7.1.

COMMENT


We broadly support the Council rationale for 'balancing' the housing needs of Warwick, Leamington and Whitnash around the urban area as outlined under para 7.30. However, we do not believe that the reasons presented here justify a reduction in the overall quantum of housing which is now allocated on sites to the south of the urban area, compared to what was previously presented in the Preferred Options version of the Core Strategy. In particular, we object to the reduced number of houses allocated for land north of Gallows Hill/west of Europa Way and request that under Policy PO4 the number of dwellings allocated on this site is increased from 1,100 to 1,250 dwellings.

Para 7.31 presents what the Council sees as the advantages of locating some development to the north of Leamington Spa and Warwick. Whilst we broadly agree with the first two stated advantages, we consider that with regards the third stated advantage the Plan should acknowledge that the initial transport evidence presented to date does not suggest that the construction of a northern relief is definitely required or that it would be cost to do so.