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.