We object to the modified Local Plan for the following reasons.

We now have a 6.4 year housing land supply. We note that last year's figures are to be revised by Mr. Barber.

The growth in the number of households remain exaggerated and unnecessary.

So much land has already been approved that the total number of houses will not be built for many, many years, if ever - land banking!

ONS figs show migration into Warwick District will probably be very much less than the JSHMA has indicated.

The NPPF requires 'sustainable development'. The three criteria of sustainability are environmentally, economically and socially sustainable. The development south of Warwick is not sustainable.

Infrastructure

The necessary infrastructure is not in place, nor is the funding to provide it, i.e. transport mitigation, schools, healthcare provision, police and fire and rescue, flood alleviation. There is little information on how this infrastructure can be provided. The Plan is neither sustainable nor deliverable.

The NPPF (17) states that strategies should "deliver sufficient community and cultural facilities and services to meet Local needs". Also (NPPF 162) "Local planning authorities should work with other authorities and providers to:
* assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demands and
* take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."

Yet you confirm that infrastructure will not be put in place before building commences but that you hope that infrastructure will be provided from developers' contributions, whilst admitting that this may not raise enough to cover escalating costs of new roads, bridges, schools, extra health provision, policing, fire service, community centres etc. If left to developers, history has demonstrated this may not happen. Infrastructure needs will then be prioritised and some areas may miss out. You have admitted that infrastructure proposals will be prioritised and there will be a cut-off point when the money runs out. We have seen no architects' proposed site plans showing each area with all the necessary infrastructure in place. You have provided no idea of potential costs at all. You have provided no results of studies at all. Warwick has already lost its police station and fire station, roads are completely congested at peak times, schools are drastically oversubscribed and have no places, the hospital is at breaking point and cannot cope with the load, having day surgeries, evening clinics and Saturdays to clear backlogs and lack of parking leads to innumerable late attendance for appointments, and the police haven't a clue how they can cope with more communities. Utilities such as water, sewers, electricity provision will have to be provided at escalating massive cost. The public sewer discharges to Longbridge Water Treatment Works. Severn Trent currently transport sewage from Longbridge to Coventry by tanker several times a day. They do not have the capacity now to deal with sewage at the Longbridge site and it is inconceivable how they will cope with sewage from another 4,000 houses in Warwick. How many more tankers will be required and at what extra cost?

Transport - Severe Traffic Congestion and Car Dependancy

Extensive sprawling urban development proposed will inevitably exacerbate car dependancy. The transport strategy is car-based, just squeezing more congested traffic on to the existing road network, bridges over the River Avon, and parking. Contrary to transport policies, it would make walking and cycling less attractive, and could not have good public transport. All traffic crosses river on 3 bridges - Castle, Princes Drive, Adelaide Road. Leads to congestion and dimishes trade.

The Park and Ride suggestions are unworkable.

The County's Chief Medical Officer has stated that lack of exercise is related to an increasing number of avoidable deaths in the area - one heart attack per day in Warwickshire! It is noted that a major 'bus company has submitted a scathing 17 page report on the traffic situation and stated that they could not even serve one of the new developments. Buses have not proved to be sustainable. The only service for Myton Road is one per hour and therefore hardly anyone uses it.

Danger to schoolchildren and others is currently problematic on our roads and will be exacerbated near schools such as at Woodloes and Aylesford/Newburgh.. We are given no concrete proposals for new roads, only ideas. A North Leamington relief road suggestion could cost £50million+ and the idea that the A452 could be routed to the Fosse - one of the most dangerous roads in the County is preposterous. The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and on to the M40 will have the opposite effect at the eastern end of Myton Road with the addition of Morrisons and the proposed trading estate and Aldi supermarket all exiting out on to the double roundabout system. The present Plan does not address these traffic problems sufficiently and should be "refused on transport grounds where the residual cumulative impacts of development are severe" (NPPF 32).

The NPPF (34) states that "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised." "A key tool to facilitate this will be a Travel Plan" (NPPF 36). All developments which generate significant amounts of movement should be required to provide a Travel Plan". We have not seen such a Travel Plan.

Myton Road, Banbury Road, Europa Way, Castle Bridge, Emscote Road and Prince's Drive are all highly congested with long queues or at a standstill at peak times including the Town centre and often emergency vehicles cannot negotiate a way through, even via the pavements. If the closed Warwick Fire Station were to be relocated at Queensway, their vehicles would experience increased problems and response times would be worsened. There is a suggestion that Europa Way could be widened but this would exacerbate bottlenecks when the traffic reaches the roundabouts. The County say they can mitigate but not contain the resulting increase in traffic and admit there are places where congestion will worsen. One of the mitigation measures suggested includes a gyratory system at the Castle island which, with its traffic lights etc. will severely harm the setting of the castle in a conservation area. The green space forms the approach to Warwick and views from Warwick Castle. WDC say the area south of Warwick is environmentally sensitive but then put it in for development - why? Traffic would increase at the Butts, the narrowest road in the town and the no right turn plan for St. Nicholas Church Street would impact severely on the economy of Smith Street. Vibrancy of the town centre is important. Think about what the effect will be on people sitting outside cafés in danger of being knocked over and pollution from all the traffic being funnelled through Warwick. People won't want to shop in Warwick because they won't be able to get into the town. It will be the destruction of Warwick and the people who want to shop here. There will be an adverse affect on Tourism.

Air Quality:

The NPPF (17) states that the Plan should "support the transition to a low carbon future" and contribute to "reducing pollution". Also "Local planning authorities should plan for new development in locations and ways which reduce greenhouse gas emissions." (NPPF 95)

The NPPF (17) states that policies should "recognise town centres as the heart of their communities and pursue policies to support their viability and vitality". (30) "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion". Also (NPPF 124) "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

Policy ER.2: Environmental Impact of Development
"The environmental impact of all proposed development on human beings, soil, fauna, flora, water, air, climate, the landscape geology, cultural heritage and material assets must be thoroughly assesse, and measures secured to mitigate adverse environmental effects to acceptable levels. Local plans should include policies to ensure this takes place. The impact of existing sources of environmental pollution on the occupants of any proposed new development should also be taken into account. Ass assessment of environmental impact should take account of, and where possible seek to reduce, uncertainty over the implications of the proposed development. If adverse impacts cannot be mitigated to acceptable levels, development will not be permitted."

Pollution from car exhausts in many streets in Warwick town centre and some in Leamington is already worse than is legally permitted. Figures produced by officers from public health Warwickshire were based on 2011 measurements of roadside nitrogen dioxide concentrations, the main contributor being road traffic.

An Emission Study commissioned by Warwick District Council showed that "Nitrogen dioxide concentrations in the Warwick Air Quality Management Areas currently exceed the annual limit value of 40 µg m-3 at several locations where there is relevant exposure of members of the public. It is unlikely that the limit value will be achieved at some locations on Jury Street until well beyond 2018 without additional control measures. Traffic in Warwick can be very congested and it is likely that the road network is operating at capacity. This study therefore assumes that there will be no growth in traffic between 2011 and 2015."

However this report did not take into account the impact of this increased traffic on our health. The officers could not confirm that they had carried out any modelling on the impact of the increase and what would the impact be on our health. Pollution is strongly linked to irregular heartbeat and lung clotting.

Even more worrying is there are no measurements taken in Warwick of the particulate matter, mainly emitted by diesel engines, which is more dangerous because it goes deep into the lungs. Records show that fifteen times more people die from air pollution related illnesses than die in road accidents.

The Traffic Assessment commissioned states, "Schemes proposed within the modelling at this stage have not been tested to a sufficient level of detail to determine that they are the optimum solution" and "an obvious concern surrounding the implementation of this strategy is that this will result in an increase in the overall levels of traffic travelling through the town centre"!

The traffic congestion that Warwick already suffers will increase by a possible 6,000+ extra cars from extra South Warwick housing alone, let alone the increase from 17,000 new homes throughout the District, bringing with it increased pollution in areas where air quality is already over the limit. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. Air quality remains in breach of these regulations and will become toxically high with the 27% increase in traffic volume resulting from the Local Plan preferred options. There is no management plan to address these levels. The Government says there is a definite link between pollution and traffic causing health problems such as asthma, some cancers, heart problems, etc. The County Council admitted that air quality will suffer as carbon emissions will increase in surburban sprawl. There are schools in the town and in the areas of high traffic congestion such as Myton and Banbury Roads with playgrounds and playing fields and children are already being exposed to nitrous-dioxide above legally permitted levels, risking asthma and all the other health problems associated with pollution. You admitted that you did not know how the carbon emissions could be reduced by the 20% currently necessary. It therefore seems incredible that the large-scale housing developments on the edge of Warwick are suggested with a likely 40% increase in the town's population, over 15 years. This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?
The 2008 Air Quality Action plan for Warwick shows the very worst area being Warwick town centre.

The District Council is required to improve air quality, but the Local Plan and its transport strategy would worsen it. Noise and vibration would also be constant, businesses and tourism would be damaged. Worse, the long-term health of residents of these streets would be even more threatened.

NPPF 124 states, "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

We request that a Health Impact Assessment will be carried out including air quality testing well before any Local Plan in its current form is approved.

I note that the House of Commons' Environmental Audit Committee has published a report on the subject recommending the Government issue new planning guidance to ensure local authorities prioritise air quality in planning decisions. However, neither County Highways nor Public Health Warwickshire use their powers as statutory consultees to robustly object to housing developments on the grounds that they going to impact on the health of all the people enduring the constant traffic congestion.

Brownfield Sites

The NPPF (111) states "Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land) provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land."

So why are we not making it a priority to develop brownfield sites first and regenerate poorer housing in urban areas? There are many more examples of brownfield sites in Warwick District which could be regenerated.

Alternative Sites

The previous Core Strategy identified several other sites with potential for housing. Local villages where there are good transport links and the potential to improve road access should be developed rather than the urban fringe development of Warwick. The Warwick Parkway area provides a first class rail link. Hatton has a station and easy access to the A46 and Barford has immediate access to the M40 and A46. Two other areas of potential for large scale housing provision are Radford Semele and Lapworth which already have infrastructure to cope with further development, with good public transport, roads and a railway station.

This in turn would mean much smaller developments around Warwick would therefore be required. Although you state that there are three gas lines near Bishops Tachbrook. I can see from the map that there is an area to the west which could take some housing whilst avoiding the gas lines. There are other areas which were identified in the Core Strategy options which have not been considered this time, such as the A46 corridor and further development at Sydenham. The commercial units at Sydenham have mostly closed and been boarded up and would offer an ideal brownfield site for development.

Green Belt

The NPPF (79) states "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. The essential characteristics of Green Belts are their openness and their permanence."

The new Local Plan now incorporates housing in Green Belt at Milverton and Kings Hill. The NPPF (76) states "By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances". "Once established, Green Belt boundaries should only be altered in exceptional circumstances." (NPPF 83) Yet Warwick District Council's reason for allocating development on Green Belt is that "there is nowhere else to build".

NPPF (88) states "When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.."

We are objecting to this scale of development which will undoubtedly impact negatively on the character of Warwick and the quality of life of existing residents. We are facing urban sprawl rather than the housing being spread equitably around the District. Less than 10% of housing is proposed for villages, some of which, such as Barford, would welcome more homes including low-cost housing to build up sustainable communities with schools and facilities and meet the need for affordable rural housing. Those that grew up in the villages and wish to remain there would then have the opportunity to do so. We propose that at least another 1,000 could be spread around the villages and the number proposed for Warwick reduced.

Coalescence and Ecology

Green space is essential to separate the towns of Warwick, Whitnash, Leamington and Bishops Tachbrook. An incredible number of homes proposed for Warwick District are to be built on the land south-east of Warwick, covering nearly all of the green space between the Banbury Road, Greys Mallory, Europa Way, Myton and the Technology Park. This would mean estates more than three times the size of Warwick Gates, Woodloes Park or Chase Meadow! The towns would ultimately be amalgamated into one giant urban sprawl.

The area to the west of Europa Way was identified as an area of restraint at the time of planning the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa to prevent the two towns becoming one urban sprawl. The current Local Plan states in para 9.11, "It is important to protect the areas of restraint from development proposals that could alter their predominantly open character. Their value and importance lies in their contribution to the structure and character of the urban area, providing open areas in and around towns and preserving open wedges that separate one urban area from the next." The District has 85% green belt but 45% of this is to be built on, thus reducing the gap between conurbations. The green space threatened is valued rich and versatile agricultural land, essential for food self-sufficiency, environmentally precious landscape with many wildlife habitats and biodiversity including owls, uncommon woodpeckers, roe deer and badgers. Our existing green space provides open space, sports and recreation and such land, including playing fields, should not be built on! The NPPF 109 states "the planning system should contribute to and enhance the natural and local environment by:
* protecting and enhancing valued landscapes, geological conservation interests and soils;
* recognising the wider benefits of ecosystem services;
* minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures."


Loss of Prime Agricultural Land

Housing developments already approved or included in the new Local Plan which are on valued countryside and grade 1 agricultural land which will be essential in 12 to 15 years time.

Historic Environment

The historic environment would directly be damaged by the increase in traffic and by wide new junctions cluttered with traffic lights and signs at beautiful places: in Warwick at Bridge End, over the Castle Bridge, on Castle Hill, and at St John's; and on the approach to Leamington via Europa Way, giving no impression of the beauty of the spa town.

Pinch points at bridges cannot be alleviated and the 300-year old Castle Bridge already carries 20,000 vehicles per day and cannot sustain an increase in traffic without threat to its very structure. We should be trying to reduce this traffic to prevent the bridge collapsing, not increase it. We need an impact assessment to ensure its conservation. English Heritage have offered to help with this.

The NPPF (112) states "As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional."

The precious historic and listed buildings in Warwick are being damaged by traffic vibration and pollution and this problem will only worsen. Increased commuting traffic must not be funnelled through Warwick's congested urban centre.

Flood Risk

The NPPF (94) states that "Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk". Also "Local Plans should take account of climate change over the longer term, including factors such as flood risk....." and (NPPF 99) "When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure." We already have existing green infrastructure to mitigate against water run-off and flood risk the proposals are to build on it!

The NPPF (101) states "The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic Flood Risk Assessment will provide the basis for applying this test." There are other available sites as already stated. "A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall." (NPPF 102)

Europa Way and an area to the south of Gallows Hill are in flood zones and at significant risk of flooding, yet housing is proposed in Flood Zone 1, adjacent to Zones 2 and 3. Areas at risk of flooding have always been designated areas of restraint but you are dispensing with these. More concrete on green fields here which currently soak up heavy rainfall must increase water run-off and impact on the areas of Warwick which already suffer from flooding, especially around Myton Road and Bridge End. You have received photographic evidence of flooding from properties in Myton Crescent and the Malins. When the Warwick Technology Park was created, there were severe flooding problems in the adjacent Myton Gardens. The field donated to Myton school as a restricted covenant playing field has proved to be unusable because of water-logging, demonstrating on-going water-management problems. Even more relevant to the Malins and Myton Crescent was the severe flooding in 2007 caused by the re-orientation of the water run-off flows and the disturbance and removal of top soil from the Round Oak School playing fields behind Myton Crescent. It was only after threats to sue the County Council that remedial action was taken. This consisted of a bund to capture excess run-off and a pump situated in the north-west corner to return water uphill into the drain near the Round Oak School. This action has proved ineffective and inadequate as run-off water has periodically flowed into the gardens in October 2012 and in the recent floods, when the water level reached was only a few inches below the level of the electricity sub-station situated between 26 Myton Crescent and 1 The Malins.

The field at the end of The Malins slopes upwards from The Malins and run-off water from adjacent fields above and to the right and behind also flows towards The Malins and Myton Crescent. When there is a downpour on saturated ground, water flows quickly down, fills up the lower parts of the field and collects in the gardens of nos. 26, 28 and 30 Myton Crescent, and overflows into the gardens of nos. 3 and 12 The Malins and towards no. 1 The Malins and the electricity sub-station. There is little indication that the seriousness of this flooding is being taken into account.

Ignoring flood risk is contrary to NPPF 100 "Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere."

The previous Core Strategy decided that this area may not be needed for development in the future being an area of restraint and the worst area for infrastructural needs. Development is not necessary in these areas of flood risk and should be avoided, certainly not put into the first phase for building. Home-owners would also face being turned down for insurance in postcodes where there is flood risk. This area you have designated for building is vital for flood alleviation and should not be built on at all. At the very least it should be the last designated site.

 
Density

Garden Town suburbs sound admirable but naiïve when you look at the number of buildings proposed and the impact on the environment. This concept did not materialise in Warwick Gates or Chase Meadow and developers will build at high density for increased profit margins. 1,100 houses were first proposed for Chase Meadow and now it is to be 1,600. WDC has no budget for tree maintenance and developers cannot be relied upon to carry this out, as we have seen in other recent developments. Warwick Gates school and Chase Meadow play area never materialised but £1.4m of Chase Meadows developers' contribution was used instead for St. Nicholas Park remediation. They were then allowed to build more houses on the area allocated for sport/play area at CM. After 14 years Chase Meadow still has unadopted roads, only just received its link road to the local school and the prospect of a community centre for sports provision and social interaction. Developers will not be persuaded to build at 30 units per hectare and there is no means of insisting on this. This is just a red herring in our opinion, as are green wedges since you admitted that where these are proposed, you will be reliant on private landowners to permit their development. Once again, funding for this would be dependent on developers' contributions and these monies, being in short supply, would be diverted for other more essential infrastructure.

Coventry and Duty to Co-operate
The National Planning Policy Framework makes clear that local planning authorities should meet their own housing need and meet the needs of other authorities in the same housing market area as far as is consistent with the policies set out in the Framework. This includes policies for the protection of the built and natural environment.
The Duty to Cooperate requires authorities to work effectively on strategic planning matters that cross their administrative boundaries. The Duty to Co-operate is not a duty to agree and local planning authorities are not obliged to accept the unmet needs of other planning authorities if they have robust evidence that this would be inconsistent with the policies set out in the National Planning Policy Framework, for example polices on Green Belt or other environmental constraints.
An authority will need to consider its obligations under the duty to co-operate, the policies of the National Planning Policy Framework taken as a whole and any relevant Local Plan policies when considering requests from others to co-operate on strategic cross boundary matters.
Coventry Council should provide more dwellings for Warwick University students which would free up hundreds of dwellings (including Station House with over 200 student flats) in the South of Leamington to private affordable starter homes and family homes. WDC have recently been forced to change their planning policy because of the problematic increase in HMOS in the District.

It is known that Coventry University in particular has a policy of increasing its international students substantially and that this began in about 2008. The housing need for students, who tend to move between universities fairly often, is substantially different to that of the general population and this should be taken properly into account by the University and the City Council by providing appropriate new accommodation for students to reduce the pressure on family homes. The international student population and the housing provision made for it should be separately identified and accounted for in Coventry's Local Plan that is not taken into account in the Hearn report of Coventry's housing need. The Hearn September 2015 updated assessment report makes only two references to student housing provision and neither take into account the policy change or only relates to student households that utilise normal family homes. Since there were 25,000 students in Coventry in the 2011 census who were living in either in halls or in student only housing and that since then numbers may have risen due to the expansion policy, work should be done to establish the best way to provide housing for this sector of the market.

Coventry's Green Belt

Coventry doesn't want to lose its green belt so it is being allocated to Warwick District. Giving up green belt should be dependent on the quality of the land. Rural areas have more high grade agricultural land than the green belt land in Coventry.

I trust you will include all the above points within the analysis of all the consultation responses.