Preferred Options

There is nothing in the Local Plan about the size of the dwellings to be built, only the number.

A 25% reduction by 2027 would be welcomed (12.13). However, To achieve an overall 25% reduction by 2027, new developments (with all the opportunities of new build), will need to contribute more than a 20% reduction.

Developers will want to build on Greenfield sites first as they are more lucrative with less risks.

The Green Party recognises that indefinite growth of the economy and population is not possible and would result in catastrophic collapse. Whilst this is not yet generally accepted, many will agree that the UK has a problem with over-population and most accept that there will not be significant economic growth for at least the next 5 years. It is also generally accepted that economic activity should be such that the impact on the environment and future generations ought to be minimised. As indicated under PO8 (Economy) we note that there is no evidence for a connection between the economic health of the district and the number of houses built.

Our objection to PO10, below, explains why the proposal for 600 new homes every year is unnecessary and very damaging to the district.

Under PO10, we explain why housing should be concentrated within existing urban areas.

In this response we focus on the broad issues, so feel it is inappropriate to respond in this section other than to note that issues of location often amount to a 'divide and rule' tactic, pitting different areas against each other.

However, under PO10, we do explain why housing should be concentrated within existing urban areas.

The council's own Strategic Housing Market Assessment (SHMA) suggests that if all affordable housing needs are to be met, about 77% of new homes should be affordable. Therefore, the council's lack of ambition regarding affordable housing is disappointing and suggests greater concern for developers than local residents who are in desperate need of suitable housing. The Council accepts the Affordable Housing Viability Assessment (AHVA) assessment that it is possible to have up to 50% affordable housing, yet it is not willing to take a flexible approach and categorise sites by level of viability i.e. insist many sites have more than 40% affordable housing. This is despite good work of the AHVA in setting out 3 categories of site. The Council should work harder to maximise affordable build and therefore should:
* Categorise each site by viability to maximise the number of affordable houses which it recognises are so badly needed
* Increase density of housing which will reduce the cost per home and therefore enable more affordable properties to be built
* Follow the advice in the AHVA, 7.49 and reduce the threshold for affordable properties to 7 properties in urban areas
* Seek independent opinion regarding the 20% of Gross Development Value (GDV) return figure in the AHVA upon which viability figures are based. This figure is not justified in the document and expected GDV returns are falling in the property industry e.g. see http://www.thepropertyspeculator.co.uk/tag/gross-development-value/ which suggests 15% is more realistic. LDZ who wrote the AHVA also work for developers and so potentially they have an interest in inflating this figure to the benefit of developers at the expense of local residents
* Demonstrate with detailed commitments how any remaining short fall in affordable housing can be met through innovative working with the private sector, so that the local plan is compliant with the National Planning Policy Framework (NPPF)

House building will not help the local economy as so many people commute out of the district i.e. this is a very desirable residential district; more people living here will reduce the desirability and increase outward commuting but is unlikely to lead to more jobs.

The Background Technical Paper indicates that in recent years very little land has needed to be developed for employment. Indeed many units in the district are currently unused. This is partly due to the difficult economic climate but is also due to a move away from industrial activities towards office work that requires much less floor space.

Economic redevelopment should be solely undertaken within existing industrial areas, including Coventry.

As with the Economy section of this consultation, the idea of "future retail growth" is probably fanciful and certainly optimistic. With lack of economic growth and rapid expansion of internet shopping, it is unlikely that all the existing empty shops will ever re-open. If new developments are built and operate successfully they would be at the expense of existing retail locations. For example the proposed Clarendon Arcade would reduce the number of shops in South Leamington, Warwick and Kenilworth. It should be noted that the National Planning Policy Framework (NPPF) says 'It is important that needs for retail, leisure, office and other main town centre uses are met in full' but does not suggest that retail growth is required. Therefore no provision for improbable retail growth is required.

The District is justly proud of the excellent rural areas surrounding for our small towns. Therefore it is scandalous that this local plan seeks to build recklessly, and almost exclusively, on green field sites. This is entirely unnecessary for the following reasons:
* There is not a clear link between economic growth and housing (see response to PO8)
* Housing should be focussed on brownfield sites within urban areas
* More effort should be made to use currently vacant homes and retail/ office spaces, especially homes above shops
* Excellent residential schemes of up to 200 homes per hectare are quite common, so there is absolutely no reason to advocate 30 homes per hectare (note section 4.23 of the Strategic Housing Land Availability Assessment, SLHAA). As household size is tending to reduce, the need for small homes continues to grow, enabling much higher housing densities than proposed in this plan
* The SHMA report indicates that the majority of older people live in homes with 3 or more bedrooms and that over 40% of homes are under-occupied. Therefore a high priority is to set the conditions whereby high quality, attractive smaller homes are developed in all areas of the district to encourage those in under-occupied homes, particularly older people, to move into them. This has the potential to free-up enough homes to obviate the need to build any more
* Warwick University, along with other Higher education institutions around the country, have made the strategic decision to keep as much student money to themselves i.e. they are engaged in a major programme of building student accommodation on campus. This dramatic reduction in the number of students in the rest of the District is another reason why house building is unnecessary

Even if the council does not accept the full force of the above arguments, it should still be acknowledged that there is uncertainty in their prediction that so much housing is required. Therefore, it is imperative that there is gradual release of land for housing over the timescale of this plan, with the most suitable land released first e.g. only brownfield sites usable for the first few years, then selective low-grade agricultural land. Only when all other sites have been built upon, should the rest of the allocated land be released for development.