Proposed Modifications January 2016

First, I want to say that I appreciate the huge load of information involved in the Local Plan process. I have no doubt it puts your staff under a heavy work load.

This e mail is to explain our actions in submitting a Leamington Society response to the consultation. I had drafted a response, which was reviewed by our committee, and the final details checked with Marianne Pitts (our Vice Chairman). Marianne kindly undertook to submit this on your website.

Our total response was less than 1 & 1/2 pages but Marianne came up against restraints of space, leading to her breaking the text into ad hoc sections as she was entering it. This is now spread over 6 responses (68407 - 68412) and is not as coherent as we intended. For clarity, I am attaching the complete text,
which is much more compact than the 6 responses would suggest.

I understand the wish to receive short, digestible comments. You will see that our main issue is with the density of developments. This is a key factor, central to land allocation, but also engaging sustainability. Indeed the ideal of breaking down the information into topics often goes against the grain of cross-cutting issues within the Plan.

I am aware that suggested changes to density have not been welcomed by Council leadership. But it is such a key factor that respondents should surely be allowed to express a reasoned argument - not at great length but in more than simple sound bites. Our response needs to engage with what are often very lengthy documents. For example the recent Sustainability Assessment alone runs to nearly 200 pages. i also note that the file - Council item 14, 24th February on submission of the modified Plan - was of similar size. In that context I believe our submission is brief and concise.

Finally, MAY I CORRECT ONE IMPORTANT DETAIL arising at the end of each representation lodged on the website. It is our wish that a Leamington Society representative be involved as and when the issues we have raised are examined by the Inspector. I make this request because they are absolutely central
to the shaping of the Local Plan. My apologies for having to make this correction ; I believe Marianne Pitts, while concentrating on fitting our text to your format, overlooked the significance of "written representation" and its relation to the Inspector. In previous rounds of consultation the Society made submissions and
asked to take part in the examination ; we took part in some of the initial hearings last May.
The modified draft includes very substantial extra housing sites to meet the Inspector's requirement particularly on the duty to cooperate with Coventry's housing needs. All the new sites and the previously adopted sites, mainly to the south of Warwick and Leamington, are based on profligate use of land.

Although described as "urban extensions" they are designed at far lower density than the towns and this spread of "garden suburbs" does not reflect the context and urban quality of either Warwick or Leamington. This is in spite of the high value that the market clearly attributes to existing accommodation within these two towns.

We note that, in the February 2016 SA consultation on the WDC website (p6, para. 2.8) provided
several options for testing
* four housing growth options
* seven broad locational options
* four distribution options
The obvious option of providing urban extensions at urban density has been excluded from the working brief handed to the consultants. This key factor of density is the "elephant in the room" which WDC appears to have resolutely refused to recognise throughout the procedure for developing a Local Plan. The Council has therefore struggled to accommodate housing needs within the local geography while avoiding Greenbelt land. After the initial examination of the original Local Plan, WDC has been forced to consider major breaches of the Greenbelt.

At the recent February Council to consider the modified Plan there was widespread dismay across the chamber, including members from all parties. The justification cited for low density sprawl was to provide "green spaces" but this housing policy inevitably covers huge extra areas of green countryside, now also within the Greenbelt, with sprawling suburbs. It is the negation of the original purpose of Greenbelt - to contain settlements and protect adjoining countryside.

A policy of low density layouts has plainly exacerbated Warwick District's problems in providing the necessary extra housing: it is a matter of simple arithmetic in land requirements. Yet that is by no means the only effect. It also is bound to compromise the sustainability of these new developments. This is particularly evident in the provision of transport options and other local services. Historically communities have clustered and towns have functioned because of the proximity of people to local services. It became enshrined in planning policy to encourage close-knit communities as distinct from scattered sprawling development.

In the early 20th century, garden towns were proposed largely as a reaction to Victorian city slums. Circumstances have changed out of all recognition in the past century: both in housing standards and sanitation and with millions of cars now competing for road space.
The major and growing challenges of congestion, air quality and climate change are clearly recognised as critical planning issues within the NPPF.

4.29 The transport system needs to be balanced in favour of sustainable transport modes,
giving people real choice about how they travel.
4.32 Plans and decisions should take account of whether:
the opportunities for sustainable transport modes have been taken up, depending on the nature and location of the site, to reduce the need for major transport infrastructure.
4.35 Plans should ... be designed ... to give priority to pedestrian and cycle movements, and give access to high quality public transport facilities.

The SA consultation considers "Likely Effects of the Local Plan Modifications" (pp 21-25) on Transport & Accessibility, Air Quality and Climate Change. It acknowledges in each case the "potential to increase the significance of negative effects". It then comments on "a range of mitigation strategies ... which will contribute to reducing the extent of these negative effects" but will not eliminate them.
The SA also shows extensive colour coded charts featuring numerous question marks in the various boxes. Thus we are offered a verbose, shuffling, imprecise narrative, which suggests the outcome may not be all that bad.

In the infrastructure planning there are hopeful suggestions of bus services to all these new developments. Yet well-established professional experience indicates that at low densities of 30 - 35 dwellings per hectare there is little prospect of effective bus services to provide a genuine and attractive alternative to the car. There is therefore no doubt that these proposed suburbs will be highly dependent on the motor car. Road planning, such as for Europa Way, confirms this expectation that the Local Plan is car-dependent and continues unreformed highway policies giving priority to motor traffic, largely in disregard of the NPPF clauses quoted above. This attempt to facilitate ever increasing volumes of traffic means that the extra flows along Europa Way will impact heavily on Warwick or Leamington or both. In mitigation we are offered schemes like the South Leamington gyratory, where the impulse to force through more traffic is most unlikely to "give priority to pedestrian and cycle movements". On the contrary, shoppers and visitors to the intended Creative Quarter will face an intimidating traffic circuit together with more air pollution.

Finally, as the NPPF sets out, there are three dimensions to sustainable development. The economic role involves ensuring sufficient land. The profligate use of land in the WDC plan is plainly a huge compromising factor. It should also be noted that car dependency, along with two or even more cars per household, is likely to impose a significant strain on family budgets.
Under the social role comes not only housing supply but also local services, which will be less accessible amid the sprawling low density developments envisaged in the Plan. The environmental effects are discussed above.