3. The Local Plan Process

The problem with the local plan process is that every stage of consulation there is not quite enough information to support or object. It is a pity you do not offer a "conditional support" option. The main issue with the current consultation is that we are being asked to object or support options for areas of new housing development without details of the infrastructure that will be put in place. It is therefore very difficult to judge what the impact will be on the area.

The 2011 public consultation resulted in the majority of respondents opting for agrowth of 250 houses per year.
Why was the voice of the public ignored?

I'm not clear what the aims of the consultation process are. Is it really to listen AND ACT on the responses they receive or in reality has this all been agreed?

There is little in the Plan to demonstrate that any account has been taken of earlier consultations.

Paragraph3.4
"It is supported that new communities cannot prosper without infastructure requirements being planned for.
When the Infastructure Plan is formed it is submitted that the following extract from the NPPF should be taken into account.
""72. The Government attaches great importance to ensuring that a sufficient
choice of school places is available to meet the needs of existing and new
communities. Local planning authorities should take a proactive, positive and
collaborative approach to meeting this requirement, and to development that
will widen choice in education. They should:
● give great weight to the need to create, expand or alter schools; and
● work with schools promoters to identify and resolve key planning issues
before applications are submitted."""

WDC's preparatory work in an Infrastructure Plan is valued and appreciated. Although also resident within the district, my interest in this part of the new Local Plan is predominantly from new school premises needs along with having responsibility for Curriculum at one of Warwickshire's most successful and forward thinking schools. The Council's expressed desire in this section that it 'is keen to hear from all interested parties about infrastructure requirements' is appreciated. Encompassed in what yet needs to be done on this, I would urge that the following statement from the recently issued NPPF is taken account of and allowed to colour the Infrastructure Plan.
"Local authorities should take a proactive, positive and collaborative approach to the development of schools by working with schools promoters to identify and resolve key issues before applications are submitted. In determining planning applications for schools, local planning authorities should attach very significant weight to the desirability of establishing new schools and to enabling local people to do so."
The importance of assisting development and progress in the schooling sector directly from planning level within the local authority is significant and should be supported.

The use of the online consultation process requires considerable IT literacy skills and good eyesight. It may be easier for the WDC to manage the responses but is very difficult for respondents. eg It is even difficult to find out the date of the end of the consultation process

Whereas I am sure we are all aware it is wise to have a District plan I am disturbed about the way the District council has gone about it and more particularly the conclusions that have been reached.
I do not have an issue with local authorities taking responsibility for local planning, but the local authority must take into account the views of local people and not impose upon the electorate the Councils "Preferred options". I, as a Parish Councillor, am unaware of any previous discussions.
Having read the proposals and attended meetings about the preferred options I am left with the distinct feeling that the assumptions upon which the decisions have been made are flawed. Most important, the National Planning Policy Framework concerning Green Belt has been ignored despite the fact that the Council have ditched the Core Strategy options which were proposed in 2009.
The flimsy excuse that gas pipelines would impede development South of Leamington did not exclude development proposed there in 2009.
The assumption that we need to put employment in with housing is questionable, and the suggestion that travelling to and from work will have a significant effect on the environment pails into insignificant when we think of a Northern relief road running across a large area of Green Belt and Flood plane destroying for ever an area full of natural beauty and diversity.
The council do not appear to have considered Warwick and Leamington's history. Leamington is a Spa town, largely residential. Warwick is an historic County town. What is meant by "employment", does this include industry? The Ford Foundry has recently been demolished and now we are getting another super market. How does this fit into the preservation of the old town centres?
The Council has not discussed the needs and spare capacity of neighbouring Councils. We cannot plan in isolation.
To say we have to accept these options or accept a free for all is scare mongering, and to say "It is a waste of time" sending a copy of this letter to our M.P. is disingenuous.
We all recognise the need for a District plan, but we must be more aware of the value of our green belt and not just consider the financial benefits to the District, land owners and developers.
What about the Great- Crested Newt?

My objections are on three main grounds. Firstly, that the preferred options are based on fallacious reasoning and hypothetical statistical models. Secondly, that they will result in irreversible damage to the Green belt. Thirdly that they are grossly undemocratic and not in keeping with the spirit of the Government`s National Policy Planning Framework.
Fallacious reasoning
1. They use a statistical model prepared by a commercial company, Cambridge Econometrics in conjunction with IER at Warwick University, which uses data given by the District Council, although the company themselves admit there are few official figures for measuring the factors they input. The public has not seen that data, and it is hard to see why the District Council expects there to be so many jobs suddenly appearing in this area. Is their reasoning that if you build houses, the jobs will follow?
2. In PO1they claim their preferred level of growth between 2011 and 2029 is 10,000 dwellings ie an average of 600 p/a. Even if we were to accept this figure then they would have an overprovision of houses by 3,710 if they develop all the sites they have proposed. (ref 5.18 the SHLAA "identifies potentially suitable sites within and on the edge of built up areas. Taken together, these sites would be able to accommodate an estimated 11,410 new homes. In addition, it is estimated that further windfall sites could accommodate around 2,300 new homes.")
3. There is a sudden jump from the scenarios which were presented to the public to an ad hoc rejection of the first scenario on the grounds that "This level of housing would lead to an overall reduction in the number of jobs in the district (or increases in out-commuting)" (ref 5.14) and Projection 3 Employment growth with continued commuting is rejected because it doesn`t allow for a balancing new homes and jobs. You cannot insist that employers only take on staff who live locally any more than you can insist that people only take the jobs that are available in their area! They make the same mistake when providing employment land among the Blackdown development on the grounds that there is a `deficit` there.
4. The lowest projection in Table 5.2 is trend based, but there is no particular reason to believe that the increase in net migration of recent years will continue. In fact if these proposals go ahead it is likely that the area will no longer be attractive to newcomers and many established residents will move away. The other projections are based on the hypothetical model -the West Midlands Integrated Policy Model already mentioned. Paragraph 5.22 admits that the model`s projection "is likely to be optimistic since it was carried out in 2010 and forecast an increase in employment from 2011. Bank of England GDP projections in August 2010 anticipated continued, albeit slow, growth from a low point in February 2009. However, ONS data has since revealed that the rate of increase of GDP has been falling since mid-2010 and has yet to show signs of recovery."
5. Point 5.23 says "housing would need to be met largely on strategic Greenfield sites on the edge of the built up areas. This would be necessary in order to deliver the required infrastructure." This seems an instance of lifting themselves up by their own bootstraps- such massive infrastructure changes would not be necessary with lower levels of growth.
Irreversible Damage to the Greenbelt
The NFPP in `Protecting the Green Belt` states (ref para 8.8) "When considering any planning application, Local 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 is clearly outweighed by other considerations."
Of the five purposes served by Green Belt outlined in the NFPP, the proposals to alter Green Belt boundaries will cover the first two, but not the last three.
1. The third principle - to assist in safeguarding the countryside from encroachment- will not be addressed. The Council claims there are clear boundaries but in the case of the Blackdown development, for instance, the boundaries would include the Westhill Rd and the Stoneleigh Rd. At the moment there is a clearer boundary- ie the A445, a major road from the M1 and Rugby into Leamington, yet if the building goes ahead this boundary will have proved insufficient to prevent encroachment onto the Green Belt, so it is unlikely that the minor roads will fare any better. That District Council have their eye on further encroachments of the Green Belt is also revealed in 8.33 in a discussion of Coventry Gateway, where they quibble about the proposed location and want to `explore the case for releasing land in the Green Belt.` The Coventry Gateway would be a huge industrial complex, yet they want to destroy Green Belt for it, presumably because they are competing with Coventry City council.

2. The changes also will not address the fourth principle- to preserve the setting and special character of the historic towns of Kenilworth, Leamington and Warwick. The new developments described as `garden suburbs` will be clones of those in other overdeveloped towns. How can they `ensure viability and deliverablity` (para 173 NPPF) and expect to provide 40% affordable housing but architecturally innovative buildings (as recommended in the NPPF) and at the same time `provide competitive returns to a willing landowner and willing developer`? In his ministerial foreword to the NPPF, Greg Clark says, "Our standards of design can be so much higher. We are a nation renowned worldwide for creative excellence, yet, at home, confidence in development itself has been eroded by the too frequent experience of mediocrity." The District Council`s plans for the Green Belt are set to repeat the experience of mediocrity again.

3. Nor will they address the fifth principle-to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Although the Council mentions brown field sites it does not mention any sites arising from Para 51 "local Authorities should identify and bring back into residential use empty housing and buildings and where appropriate acquire properties under compulsory purchase orders". Surely this should be adhered to in an island as small and densely populated as ours?

4. The Council`s justification for using Green Belt land 7.15 claims "the Joint Green Belt Study carried out an assessment of the Green Belt around the towns and on the edge of Coventry. The findings showed that there were variations in the quality of land in the Green Belt and therefore some areas around the towns may be considered for development and therefore, removed from the Green Belt". This is extremely misleading. The remit of the Joint Green Belt Study was to rank the areas, any ranking involves some areas ranking at the bottom, but this does not mean they are not good quality areas and it does not imply they are more suitable for development than areas outside the Green Belt. The NPPF states "Plans should allocate land with the least environmental or amenity value" not least value in competition with other areas in the Green Belt.

5. The Council`s rejection of other proposals (ref 7.18- dispersing development on small/medium sites) claims it `would be impractical in terms of the number of sites that would have to be identified` `Further, this pattern of development would make it difficult to make fullest use of public transport, walking and cycling`. These are allegations with no evidence to back them up.

6. Similarly 7.19, while admitting that `the sustainability appraisal of the options showed that the option for focusing development outside the Green Belt had clear advantages associated with the provision of sustainable transport and reducing the need to travel. However, there would be significant impacts on the historic and natural environment due to such a high concentration of development to the south of the towns due to increased cross-town traffic.` What is the evidence?

7. On the other hand the proposal to develop the North Leamington Relief Road from the A46 to the Sandy Lane A445 roundabout will funnel yet more traffic onto the Lillington Rd into town- a road which is very congested already. The `virtual P&R carpark` and non-bespoke 2- stage buses pay lip-service to looking for a solution, but looking at it realistically, most motorists are not going to get out of their comfortable cars, wait in the rain for buses that don`t go exactly where they work, at times that don`t suit them. There is already a very good bus service from the Blackdown area but the buses are virtually always empty.

8. Point 112 of the NPPF states that "Local Planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land." The fields proposed for development in Blackdown and Old Milverton are extremely fertile and yield excellent harvests year after year. The NPPF says that councils must also look at the bigger picture and future food shortages are one of the biggest.

9. Although the District Council have copied sections from the NPPF about the Green Infrastructure into their Local Plan, they show little environmental vision. For instance, there is no mention of developing renewable energy (para 17 Core Planning Principles NPPF).

Lack of democracy
In his ministerial foreword to the NPPF Greg Clark says,
"Planning must be a creative exercise in finding ways to enhance and improve the places in which we live our lives.
This should be a collective enterprise. Yet, in recent years, planning has tended to exclude, rather than include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them."
This is an apt description of what continues to happen in Warwick District. The consultative period is very brief, and hardly any of the people living in the Blackdown area had even heard about the proposals. It would have been simple to let everyone know, in the same way that we are kept informed about waste collection plans, yet the District Council chose not to do this.
In March 2011The District Council consulted the public in `Helping Shape the District`. They have rejected the growth levels wanted by 90% of those consulted and have set their sights on very much higher growth than the majority voted for. Point 69 of the NPPF says, "The planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Local planning authorities should create a shared vision with communities of the residential environment."
Yet in para7.14 the District Council says `The "Helping Shape the District" consultation exercise carried out last year highlighted much concern about the levels of development which might be required to meet the District's housing needs and the impact this would have on the character and setting of the towns. Many felt that increasing sprawl around the existing towns would damage the rural setting of the towns to the detriment of both their economies and their environment. The Council will require new development to follow the emerging garden suburbs principles in order to overcome this loss of rural characterand facilities they wish to see. ` The Council fails to see that the `garden suburbs` would not in the least overcome the problem.
Again, para 155 of the NPPF says, "Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged so that Local Plans, as far as possible, reflect a collective vision and set of agreed priorities."
It is time that the District Council took these principles onboard.

This is my response to the New Local Plan Preferred Options Consultation

Number of homes
I have read the relevant material on how you calculate that 10,800 new homes will be required in Warwick District over the next 15 years, at a rate of 550 per year. I note that in your consultation questionnaire of 2011 the majority of respondents preferred the option of a lower number of houses per year, fearing overdevelopment and coalescence among other concerns, but it seems these views are being ignored. I would also question the figures predicting a growth in 'high level' and managerial jobs and wonder what and where these jobs are going to be. What jobs are those occupying affordable or low cost housing going to be doing?
Green Belt
The National Planning Policy Framework requires that development on Green Belt land should only be allowed in 'very special circumstances' which Warwick District Council maintains exist here. I would question this and note that you propose to 'alter Green Belt boundaries in line with development sites described'. You acknowledge that 'The Green Belt ... seeks to stop urban sprawl that would harm the open nature and rural character of the open countryside around the towns and the urban areas of the West Midlands', and yet 43% of preferred option sites are on Green Belt land.
In 2009 after substantial investigation and public consultation WDC adopted a development plan, for slightly more homes than the present proposals, which did not require release of Green Belt land. What has changed between 2009 and now? Most noticeably the land to the east of Radford Semele and Grove Farm that was in the 2009 plan has now been removed, in the case of Radford, because of gas pipelines and at Grove Farm because of coalescence with Bishops Tatchbrook. Why is coalescence with Bishops Tachbrook, which is outside the Green Belt, more important than coalescence with Leek Wootton and Kenilworth or the fact that Blackdown will be joined to Leamington? Why has the land at Radford been rejected when the gas pipelines did not pose a barrier to the previous plan?

The results of WDC's Green Belt study which scored Old Milverton and Blackdown highly have been ignored. If Green Belt development is necessary lower scoring land should be used.

Preferred Options and size of developments
According to WDC the Preferred Options have to be, and are apparently, supported by strong evidence. I would like to know what this evidence is.
WDC has presented a preferred plan rather than consulting on options. No options have been presented to the public for consultation. Who has suggested the proposed sites? Has WD carried out its own survey of possible sites, or have all the sites been proposed by developers? Apparently, these sites have become available because landowners wish to sell. Developers are very persistent with their offers to buy land and I'm sure some land owners could easily be persuaded to sell if they stood to make a substantial sum of money.

Some of the proposed developments are huge. 1600 on preferred site 3 would constitute a large village on its own and will merge with site 2, making a total of 2700 houses. This is an enormous development and would require a huge amount of infrastructure. It would not be part of either Warwick or Leamington, but would be a separate community therefore not integrated into either town. Sites 4 and 5 also represent a huge development, much of it on Green Belt.

The Thickthorn development in Kenilworth is also very large at 770 homes for the size of the town. Kenilworth underwent considerable expansion in the 1950s - 1980s; should it be further expanded to such an extent? Also, how was this site decided upon? Much of it is on Green Belt and farmland and includes a nature reserve which would be swallowed up by surrounding houses. It too would not be an integral part of the town. I do not live immediately near it but it does concern me that such a development would be so near the A46, the noise from which we can hear quite clearly from our garden. I don't think building business premises alongside the A46 would lessen the noise much for those living there. A new primary school and other facilities are proposed for this development. Why not build extra houses in some of the villages which could afford to expand and already have schools etc. Leek Wootton is a case in point where the school was once under threat of closure could take an increase in pupils.

Transport
It is estimated that £50,000,000 will be needed to improve roads. Where is this to come from? Regarding the road links between Kenilworth and Leamington, does this mean making the A452 a dual carriageway? This scheme was rejected a few years ago after a successful campaign and the realisation that it was not really needed to alleviate a minor problem of congestion twice a day. It provides a very pleasant green corridor between the two towns and should not be spoilt. Access to and from the Thickthorn development at one end of the A452 and to and from the Blackdown and Lillington developments at the other end would result in a massive increase in traffic. However, a dual carriageway would still lead to congestion at the entrance to either town as it funnelled into a single lane. A dual carriageway linking the A452 with the A46 would cut across a swathe of countryside and spoil the village of Old Milverton.
Communication
I am concerned that many people in Kenilworth are unaware that there has been this consultation period even if they are aware of the Local Plan. It is not enough to assume that everyone reads the local press as many do not, and most people would not be looking at your website unless they were aware of this plan and therefore there was something to look at. There has been some limited information in the library but for most of the time this was tucked away round a corner and I had to ask where it was. I know there have been various meetings but these were not well publicised. The exhibition in Kenilworth Library was staged only a week before the end of the consultation period and again there was little publicity. In the interests of transparency, surely every household should have been leafleted about this very important plan, not just people who had already responded to the questionnaire or registered on your website? I hope the next consultation will be better publicised.
I have other concerns but these are the main ones. Please listen to the views and concerns of the people and don't force this plan on us without giving us alternative options to consider.

Following a review of the Preferred Options, I believe that there are some fundamental flaws in the proposals.

Informing Residents

My initial concern is with the level of marketing surrounding the Preferred Options that has been undertaken. As a resident of Barford I cannot recall seeing anything in the local free press regarding this and merely stumbled across the current consultation process whilst talking to a neighbour. As you are no doubt aware Barford is a very vocal village on issues that will have a major impact on its future and so feel somewhat disappointed that the residents have not be suitably informed on such a major issue in order to shape the village as a whole.

Strategy

Distributed development across the District
Whilst it is acknowledged that a more distributed approach to development is preferable, the weighting of the proposals needs to be considered in more detail.

As a village, Barford's history and character is formed by its organic growth and the fact that it is surrounded by swathes of fields and green belt. Anyone who has had the pleasure of walking around the village and its periphery will appreciate how both interact with each other.

Any large scale development would undermine this character and would infact be detrimental to the area. Barford Village Design statement states that large scale development such as that found at Dugard Place should not be repeated again.

"While small infill does not threaten the overall character of the village, large scale development would be extremely harmful and inappropriate since it would place enormous stresses on the village infrastructure and distort the balance of the community.....Large scale development would be extremely harmful and inappropriate"

This is an adopted document and should be considered carefully when allocating the village a further 100 dwellings through the life of the plan. The village must currently stand at approximately 600 houses, therefore the proposed extension would be an increase of nearly 20%.

One of the aims of the Local Plan is to protect and maintain the character of the District and enhance the assets including the green belt, listed buildings and conservation areas, therefore it seems unreasonable that the Council are proposing a carte blanche for villages on where the development is allocated indeed removing all protection that the Green Belt is afforded whilst decisions are made as to where the preference is to develop further housing. By extending the village envelope and allocating such a large number of houses to the village it would be out of scale with the environs and will have a detrimental impact on the area.

The Green Belt study demonstrates that there are variations in quality of land in the Green Belt and so it would be assumed that these areas that can be found on the whole around the periphery of towns should be the focus of development over any development that is proposed in villages.

It must also be noted that Barford has a core Conservation Area. The 'Barford Conservation Area - Areas of Special Architectural or Historic Interest' document produced by Warwick District Council clearly states:

"Further infill of new dwellings within the Conservation Area should be strictly limited".

The document also goes on to say

"There are significant open areas within the Conservation Area which should be protected. These include.....the playing fields, open areas and grounds of Barford House".


Ensuring the Countryside and areas of Importance for Wildlife and informal Recreation are Maintained and Improved
As previously discussed, whilst the green belt surrounding the village forms part of the setting that provides Barford with its character, it also houses an abundance of wildlife along with offsetting the risk of flooding, which villagers would confirm has in the recent past been utilised on numerous occasions and has protected the village from flooding of the Avon. Barford is most certainly at a critical point whereby the pressure for development is threatening the natural environment.


Ensure that education is provided for in major new developments
Whilst I recognise that most residential developments will attract planning contributions either in the form of S106 payments or the recently introduced CIL. However the current village school is already at maximum capacity with no further room for extensions, therefore any additional residential development in the village would only seek to exacerbate the current situation. The Preferred Options talks about the importance of the existing community and facilities and services and whether they can meet current and future needs. If the proposed 100 houses are located in Barford, then it can be guaranteed that the services will not meet the locals needs, indeed it will be detrimental to the vitality of the community.

Sustainability
Over the past 10 years the number of dwellings in Barford has grown by in excess of 60 houses with the major input coming from the former Oldhams site. However conversely the provision for public transport has been on the decline. The village is on the whole composed of individuals that are reliant on their cars to go to town, to work and generally live their day to day lives; they do not and cannot rely on local transport. Whilst in theory it could be concluded that the proposed 100 houses would increase the use of public transport and encourage additional routes and frequency of buses, there is clear evidence to indicate that this is not the case. Therefore is should be questioned whether Barford should be considered a more sustainable location as any new homes in the area are likely to increase car-bourne journeys, congestion and pollution in the village.

It must be accepted that one of the attractions of living in Barford for those of a working age is that it is indeed only a mile from the M40 and the A46, with most surrounding towns being 10-15 minutes drive. Whilst it is accepted that there are some employment opportunities within the village, this is limited. The majority of the people are required to commute to the surrounding towns and cities. Therefore any large scale proposals such as this should be located in close proximity to the towns and larger conurbations to ensure that T2 of the WMRS is met, in order to reduce the reliance and use of cars, rather than in the outlying villages such as Barford, which encourages their further use.

Scale of Development
The Preferred Options has identified Barford as a Category 1 village which imposes 3 times as many houses on the village than a Category 2 village. However the categorisation of the villages is somewhat flawed. For example Cubbington has a substantial level of facilities in comparison with Barford, yet it is only required to allow for 30 dwellings.

CF2 of the West Midlands Spatial Strategy (WMRS) seeks to limit housing in rural villages to that which meets the local needs and or supports local services. Whilst it is recognised that a limited amount of affordable housing is required within the area, it cannot be accepted that development to such an extent is required to satisfy this requirement.

Conclusion

In conclusion, whilst it is accepted that additional dwellings are required within the District; too much emphasis has been put on the allocations of residential development in the surrounding villages. It is clear to any of the residents of Barford that the proposed figures that are being discussed would be detrimental to the village as a whole in terms of its character, its wildlife, it's conservation area and the community's services.

Therefore it is proposed that the distribution of the development is reviewed with further consideration and the Barford allocation is reduced dramatically to a figure that is more akin with the existing village and of appropriate scale.

We wanted to provide some general feedback on the plethora of information available related to the New Local Plan Preferred Options Consultation. Having attended two meetings in Hampton Magna we are aware of some of the issues that residents are concerned about. We will aim to outline the main issues below and also include our own personal thoughts. However, these are not exhaustive and we should strongly encourage you to speak to your representatives, who attended all of your meetings, to get their feedback on issues that were raised.

Evidence base
We are extremely concerned that the available documents are not fully engaged in "evidence-based" consultation. Specifically, it is our concern that there are limitations in the methodology being used to develop this Local Plan Preferred Options Consultation. This is an important foundation to any research, report and future recommendations. The consultation documents lack transparency in terms of the employed methodology. For example, we strongly encourage you to document how you plan to utilise the information gathered at meetings across the district. This is a valuable opportunity to gather qualitative evidence on people's acceptability, satisfaction and attitudes towards the plans. There has been a lot of frustration voiced at meetings related to the apparent failure to consider, appreciate, and operationalize people's views. There is a need to inform people how their views are going to be considered and synthesised to inform your decisions. For example, large scale questionnaires have been undertaken with residents by local parishes (Hatton Park and Hampton Magna) which provide valuable information. People need to feel listened too. It is important you allow people to voice their opinions and acknowledge how they will be considered. You need to empower people. Your research will then be richer and more representative.

We are extremely concerned about the generalizability of your research to date. We strongly encourage you to work more closely with academic departments like Warwick Business School, Warwick Medical School and the Economics department at the University of Warwick. There are clear weaknesses in the rigour and robustness of your methodological approach and evidence base which need to be considered again. Collaborating with an academic department will help overcome some of these problems. They will help with economic modelling, operational research and mixed methodological approaches. How you synthesise the data you collect is crucial. If you have lots of meetings and don't report the views at these meetings then your data gathering is confounded. You may want to host smaller focus groups in different areas, recording information, and thematically analysing the common issues. This is rich qualitative evidence which appears not to have been considered.

Housing in smaller villages:
From a personal point of view we need to express our disapproval over expanding housing in smaller villages like Hampton Magna, Hatton Park and Shrewley. There is considerable worry and upset among residents who live in these areas about potential increased housing on these sites. This would significantly impact on their quality of life. These small communities are already overburden by through traffic and schools are at capacity. Please work closely with parishes and residents before considering any expansion in these areas. They have a good insight into the wealth of issues that you would need to factor into your financial plans to enable these smaller developments to take place.

If some growth does go ahead, the standard of this housing needs to be inkeeping with the housing already in place in these areas. Residents are extremely concerned about the impact this will have on the prices of their existing properties.

Schools and early year care:
More housing does seem to take president in the new consultation. There needs to be greater focus on how schools will be expanded. For example, as you are aware, Budbrooke Primary is at capacity and it takes children from Chase Meadow & Hatton Park. The Ferncumbe Primary School at Hatton is over capacity. How much expansion is needed? Please provide projected statistics of how much expansion will be required in the local schools to accommodate the foreseen housing growth.

Early-year care needs careful consideration at an affordable price. Already many nurseries are at capacity or in considerable demand. The costs are also unmanageable for many parents wanting to return to work after maternity leave.

Respecting our green spaces and green belts:
These need to be respected and the natural habitats for our wildlife maintained. Housing on green belts has resulted in considerable frustration and objection at meetings we have attended, in particular that around smaller villages. Consult with residents please. Muntjac deers, bats, birds of prey reside just outside my property and we are sure that we are not the only people to be fortunate to have this natural beauty around them. Protecting our natural flora and fauna is important.

Transport:
Expanding our road networks is going to be important to deal with the increasing cars on our roads. We also need to consider the impact this will have on noise and air pollution for residents already residing in places of growth. How will this impact on their quality of life? Consult with residents please.

Public Transport:
There needs to better public transport in areas of expansion. More regular bus services, in particular, to train stations and Universities are needed.

Parking:
More affordable parking in town centres and at train stations are urgently needed,

Drainage:
We are extremely concerned about how the current drainage system will cope with expansion. The costs this could involve should not be overlooked. For example, only a small expansion in villages could cause considerable problems (e.g. Hatton Park). Caution is needed and careful mapping of the current foundations is essential.

Employment:
Greater housing expansion requires more employment. Expansion in the health, retail and educational sector presents good opportunities.

Emergency services:
An increase in the population of the District will lead to an increased need for community policing and an increase in the number of local "incidents" to which the policing service will be required to respond. We need to make sure residents are protected from crime.

Healthcare:
Ensuring that GP surgeries and hospitals can cope with the housing expansion will be of upmost importance. GP surgeries are already struggling to cope.

With the exception of the smaller housing growth in the villages highlighted and the issues raised related to evidence base and research methodology, we feel the proposed plans are worthy of further consideration and community engagement.

Preferred Options.
Not should be located could be located.
Not should expect would expect

Part 1 Intro
Local Plan, key to help War Dist deliver its vision for next 15 yrs.
Produced with Police, fire and rescue and health and many others

Part2 our vision for district
To make Warwick district a great place to live, work and visit.
Council and partners trying through the Sustainable Community Strategy.

Try means fail. Do there best is what they mean. I make no comment on
how good this is.

This sets out 4 key priorities and 5 cross cutting themes.

Priorities

Safer Communities
Health and well Being
Housing
Economy, Skills and Employment

Cross Cutting Themes

Narrowing the Gaps
Embedding sustainability throughout.
Families at risk
Engaging and strengthening communities
Rurality

The Sustainable Community Strategy is central to improving life in the
District across all the themes. Supported by series of Delivery Plans
and Locality plans which set out approach to improve areas of the
District.

Local Plan a key element to deliver Sus Comm Strat
Preferred Options for Local Plan have been aligned with Strategy to
ensure it will address these priorities and themes.

Strategy for Future Sustainable Prosperity of District
to deliver vision, Council agreed key principles to develop Local Plan.

These include

Economy
Facilitating growth and development of local economy to support a
dynamic, flexible, low carbon, mixed economy
Agreement to pursue the potential for sub - regional employment
site at the Gateway. The need to provide new employment land in and
around the thee main towns to meet local needs encourage creation
of jobs.

the need are food, water, air etc. This is a want.
local needs. If this is the above ok, if not this is a want.

Commitment to maintain and promote thriving town centres

How does building out of town supermarkets achieve the above ?

Commitment to maintain current strengths in districts economy.
Promoting regeneration of more socially / environmentally deprived
areas and support rural economy

Providing for growth and population changes.
meeting housing of the existing / future population of District including
land for around 550 new homes per annum on new allocated sites
Providing for diversity, including affordable homes for elderly and
vulnerable. Sites for gypsies / travellers and other specialised needs.

If these are green sites Please quote the Green Party's Countryside
policy

Please see above

Providing for neighbourhoods that are well designed, distinctive and
based on principles of sustainable garden towns, suburbs and villages.
Providing home and neighbourhood designs that are sustainable,
low cost and carbon efficient.

Environment
Distributing development across District.
Avoiding coalescence
Ensuring developments based on principles of sustainable Garden Towns,
suburbs and Villages.
Protecting biodiversity, high quality landscapes, heritage assets and
other areas of significance

They have been reading the Green Party's Countryside Policy

Emphasis on infrastructure
Developing an effective / sustainable transport package
Ensuring parks, open spaces, countryside and areas for wildlife are maintained
and improved

They have definitely read the Green Party's Countryside Policy

Ensuring education is provided for in major new developments

Does this include gypsys and travellers

Ensuring community activities, health services and other key services
are provided for in new developments
Develop sustainable communities with strong local centres and / or
community hubs

Done so far
May 2011 Document of key issues and scenarios for growth published.
This was subject of consultation.
Substantial amount of evidence gathered, to help understand changes
locally and what we need to plan for.

Please see above

This information important in helping develop preferred options
December 20011 Council agreed Future and sustainable Prosperity
of Warwick District. This set out key criteria for Preferred Options
Range of options appraised lead to selection of a preferred option
for each aspect of plan
The Government has published National Planning Policy Framework
This underlines importance of well justified upto date local plans and
means local plans play vital role in shaping future of local areas.
Whilst options can be justified. Important to underline they are
suggestions and not proposals for L Plan. The Council also prepared

Infrastructure Plan to go with Preferred Options. This Plan outlines
transport, schools, health open spaces, which is needed to help new

Please see above

communities prosper. More needs to be done on this, but again,
the Council is keen to hear from all interested parties about
infrastructure requirements.

Please see above

For those interested infinding more why these options chosen see
chapter below or www.warwickdc.gov.uk

Following consideration by Executive consultation starts 1st June
to 27 July Council keen to hear from anyone. Consutation is number
of public meetings, exhibitions and roadshows, local press and website.
Following consultation, work undertaken to develop draft Local Plan
with detailed Infrastructure Delivery Plan and Community

infrastructure Levy scheme. Then, approval of Daft Local Plan and

investment strategy, delivery to Council late 2012 early 2013.
Publication of Plan Feb 2013. 6 week consultation March / April 2013
Submission to Secretary of state June 2013
Pre - hearing meeting July / August 2013
Examination Public Hearing October / November 2013
Inspector's report February / March 2014
Adoption Estimated March / April 214.

4 Spatial Portrait, Issues ansObjectives see map 1
Warwick District has a growing, ageing, urban, ethnically diverse
and highly skilled population.
90% of the 138,800 live in Kenilworth, Warwick, Whitnash Leamington
areas. 10% in small villages. Population grown from 124,000 in
2000 12% increacse, forcast to grow 15% in next 15 years.
Compared to other parts Warwickshire,a higher proportion of
working age. Highest rate expected over 65
District diverse population, high proportion non - white 15% compared
to rest of county.
Notwithstanding current economic downturn, district has strong local
economy with skilled population higher productivity, earnings
compared with reginal / national averages
significant proportion of is designated for environmental or
historic value. To protect and maintain the character of District
Local Plan will balance growth and protecting enhancement of
assets.
So it is supposed to be
Areas of historic and environmental importance include 81% 28,000
hectares of Green Belt. 7 sites scientific interest. 15 sites important to
Nature Conservation. 2145 Listed Buildings. 29 conservation areas
4% of District. 11 Registered Parks and Gardens 4% of District.
ISSUES
District faces a number of opportunities and issues, important Local Plan
addresses these. Council consulted on issues facing District during
spring 2011 and thought consultation on following issues identified
important: Effects of recent recession and not knowing economies
future
House prices limit local peoples ability to buy or rent in area, creating
need to provide more affordable housing in towns and villages in the
future.
Please see above
Threat to economic strength of town centres in Warwick,Leam and
Kenilworth from retail and leisure developments elsewhere.
Size and condition of existing community facilities and services
( particularly schools and health - care ) and whether they can
meet current and future needs. Peoples health and well - being
and the need for people ( particularly teenagers and young
people ) to have access to sport and cultural experiences
such as cinemas and community events.
Road congestion and air polution around main junctions along
A46 and M40, routes into towns and in town centres.
Threat of flooding to homes and businesses in some areas
particularly where surface water may flood towns and villages
and concern that flooding will increase beacause of climate
change.
Areas of poverty in Warwick and Leam
Presure for development threatening the high - quality built
and natural environmets in district, particularly historic
areas and the cost of maintaining historic buildings in the areas.
Crime and the fear of crime, paticularly in town centres and the
need to protect the community from harm.
Governments plan ned high speed 2 rail line and possible
effects on the area (government cosulting on this ).
During consutation in spring 2011, number of objectives
identified. These set out key aims Local Plan will seek to deliver.
Following consultation objectives have ammended to take
account of views received and more recent changes ( such as
publication of National Planning Policy framework ).
Objectives have been used to link Council's Stratergy see above.
Providing sustainable of levels of growth in district.
And balance with housing growth to maintain high levels of
employment and deal with unemployment in deprived areas.
Local Plan will identify and maintain flexible and varied supply of
accommodation and land for right businesses.
Support the growth of knowledge - intensive industries, energy
and the rural economy;
improve business growth to support organic growth of local
economy.
Provide a sustainable level of housing balanced with economic
groth to reduce homeless and in unsatisfactory accommodation
to meet needs and help deal with future need for affordable
housing. Local Plan will : identify and maintain


right type, right tenure and in right location.
Make sure that new developments will reduce car use.
this improves air quality and help address climate change
reducing road congestion and carbon emissions, encouraging
people to walk and cycle more. Make sure new developments
are designed and built so they use water more effeciently and
reduce demand for natural resources. Increase renewable
and low carbon sources to reduce emissions.
.Make sure new developments are located, designed and built
so they can deal with the expected effects of climate change
particularly flooding. Make sure new developments are
distributed across district,and located to maintain and improve
the quality of the build and natural environment, particularly
historic areas and wildlife habitats and buildings and
areas of high landscape value. New developments should
respect the integrity of existing settlements. Make sure
new developments are built to high standard in terms of
design and provide incluplacessive liverly and attractive
places where people feel safe and want to live, work and visit
Make sure new developments provide public and private open
spaces where there there is a choice of areas of shade, shelter
and recreation which will benefit people and wild life, provide
flood storage and carbon management.
Make sure , if buildings and spaces particularly in historic
areas need to be adapted to meet the changing needs

Please see above

Check with Police WHITNASH

of the economy a nd to deal with environmental isssues
in a sensitive way 4.12 Enabling infrastructure to
improve and support groth. Enable organisations such
as schools and health service and provide and
maintain improved facilities and services in locations
peopoe can get to and that can meet current and future
needs and support sustainable economic groth in deprived

THIS may be correct, dwellings are another need

Even those sleeping rough go to the Salvation Army
for tents.
areas. Enable energy, communications, water and waste
organisations to improve their infrastructure and services
so they can meet peoples needs. Protect the environment

ALL TOGETHER NOW. Please see above

and contribute towards dealing with causes and contribute
dealing with the causes and mitigating the effects of
climate change.
Enable transport providers to make improvements more
integrated public transport cycling and pedestrians
organisations to improve their infrastructure and services
transport network, support sustainable economic growth.
Enable improvements to be made to the built and natural
environments which will help maintain and improve
historic habitats and their connectivity, help the public
access and enjoy open spaces such as parks and
allotments, reduce the risk of flooding. Keep the effects
of climate change

as local residents, living in the Milverton area of Leamington Spa since 1982, we appreciate, and are privileged to enjoy, the amenity of the Green Belt land which the council propose to develop North of Leamington.

We would like to express our extreme objection to the proposed new Local Plan to destroy this Green Belt land. Whilst we understand there may be a need for development, although little reliable evidence for this has been presented, we strongly object to the proposed development for the following reasons:

a) The National Planning Policy Framework requires "Very Special Circumstances" before such development should be considered, However, the fundamental aim of Green Belt policy as set out in the Government's National Planning Policy Framework is to prevent urban sprawl by keeping land permanently open.

b) The Government's National Planning Policy Framework requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development. According to Warwick District Council the "special circumstances" are that there is nowhere else for the homes to be built. However, in the "2009 Core Strategy" (the previous plan adopted by Warwick District Council) land south of Leamington (not in Green Belt), was identified and is still available, for development. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure (roads etc) to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities South of Leamington as well as existing out of town shopping facilities and good access to the town centres.

c) Therefore, the previous plan (the 2009 Core Strategy) is direct evidence that there are alternative areas for development other than the Green Belt and that the "special circumstances" put forward by Warwick District Council are wrong. It is not clear what has changed since 2009.

d) Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt, and indeed calls into question the motives and modelling assumptions used to underpin the argument for new development. The public has a right to be reassured that those in local government with the power to drastically alter the fabric of a community are truly independent, and have no interest, direct or indirect, personal or professional, in who the developers are, or how much profit they might make.

e) The proposals ignore Warwick District Council's study of the Green Belt land at Old Milverton and Blackdown, which concluded that these areas had high Green Belt value

f) The National Planning Policy Framework sets out five purposes for Greenbelt land. In summary these are, to prevent urban sprawl of built up areas, to prevent neighbouring towns merging, to protect the countryside from encroachment, to preserve the setting and special character of historic towns and to assist urban regeneration by encouraging the recycling of urban land. The Greenbelt land identified for development in the Preferred Option does carry out these purposes and its development would therefore be contrary to the NPPF.

g) The proposals will reduce the" Green Lung" between Leamington and Kenilworth to less than 1 1/2 miles encouraging the merger of these two towns and their loss of independent identities.

h) The land at Old Milverton and Blackdown is enjoyed by many walkers, runners, riders, and cyclists, ourselves included. It provides a countryside environment close to the centres of Leamington and Warwick.
Both the proposed building development and the "Northern Relief Road"
would substantially reduce the amount of land that is available to be enjoyed and have a detrimental impact on the ambience and hence the amenity value of the land. Turning some of it into a maintained park land would detract from, rather than enhance its value.

i) Old Milverton is one of the last surviving villages close to Leamington that has not been absorbed into the greater conurbation. It contributes greatly to the character of the area. If the proposals go ahead it is only a matter of time before it is also absorbed by Leamington.

j) Turning the A452 between Leamington and Kenilworth into dual carriage way will not help traffic flows. No matter what the planners say, and no matter what 'modelling technique' or assumptions they use, A452 traffic will be a nightmare at peak times

k) Building nearly 3000 houses north of Leamington will simply increase the congestion.

l) The dual carriageway will have a detrimental effect on the picturesque northern gateway to Leamington and southern gateway to Kenilworth.

m) A "Northern Relief Road" (budgeted cost £28m) is not required.
Traffic flows tend to be north to south rather than east to west. The road will serve no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns.
If the development does not go ahead the road will not be required.

n) A "Northern Relief Road" will form a natural barrier and encourage further development in the green belt up to this new road. It will need to be built across the flood plain (at considerable cost) and will violate an important nature corridor along the River Avon.

o) If the proposed development is concentrated in the South of Leamington there is an existing road network that could be upgraded at considerably lower cost than the £28m allocated to construct a "Northern Relief Road".

p) The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area an attractive place to live, deliver diversity and make it possible to shop without owning a car. Further "out of town" shopping will take trade away from the Towns.

q) There will be a loss of a significant amount of high quality agricultural land in Blackdown and Old Milverton at a time when the nation's future food policy is questionable

r) Warwick District Council has added nearly 1400 homes to the number that it anticipates will be required so as to include a "buffer" in the forecasts. If this "buffer" is removed from the forecast there is no need to include the land at Old Milverton and Blackdown in the proposals.

s) Warwick District Council has presented a preferred plan rather than consulting on options, making a mockery of the 'consultation process'.
No options have been presented for consultation, and it would appear that some of those involved have already made up their minds, at a time when they are supposed to be listening to residents' concerns. Are developers' concerns about profits more important?

Please will you ensure that our objections are noted and considered during this period of consultation, and addressed specifically during your deliberations on the future shape of this historic area. We are trusting you to make the right decision for the area, the residents, the community and the local environment. A bad decision will be impossible to put right and all of our children and grandchildren will pay the price.

We would like to register the strongest objections to the proposed North Leamington Development, contained in the Local Plan. Our reasons are several, as follows:

* The designation of areas of Green Belt was done for a reason and that reason has not changed. It is not possible to put a price on the amenity value of having ready access to green areas for walkers and people enjoying other recreational pursuits. These enrich the human experience and must never be sacrificed unadvisedly. This area is extremely blessed with wild life, which will be obliterated by the proposed development. When will we realise that we should be responsible custodians of our environment, not despoilers? Surely the destruction of rain forests provides enough evidence that there is no going back, once the vandalism has been perpetrated! The Green Belt must be preserved.

* One of the principles of Green Belt strategy was to avoid urban sprawl - the current proposals clearly ignore this and would destroy the distinctive character of the areas affected. They also constitute the "thin end of a wedge", in contravention of the strategy to avoid urban sprawl.

* As populations grow there is obviously a need for additional housing. However, we have a sacred trust to pass onto succeeding generations the kind of environment that encapsulates the very reasons why people choose to come to live here.

* It is fundamental that we make maximum use of existing brown field sites before considering any incursion into areas designated as Green Belt. These should be exhaustively pursued and utilised to the maximum. We must not allow the easy profits of developers to influence our longer term obligation to preserve what is good about our environmental inheritance.

* There is no convincing evidence that these proposals prove to be "the very exceptional circumstances" required by the National Planning Policy Framework.

* It is important that we encourage local people to shop within the Leamington area and preserve the special nature of the retail shopping experience. Independent shops are currently having severe problems in remaining profitable; we must aim to increase the variety of retail outlets to bring prosperity and vitality to the area and improve existing parking facilities. Any additional difficulties in accessing the town will inevitably drive people to use "out of town" facilities.

* There have been instances of flooding in some of the areas included in the proposals. Further concreting of land on the scale proposed will exacerbate these possibilities, unless significant expense is incurred in avoidance schemes and huge infrastructure changes, which will blight what is treasured today.

* In an age when "transparency" is a watchword for the activities of government and public authorities, at least the Executive Summary of the Local Plan, produced in May 2012, should have been circulated in hard copy form promptly to all residents affected. Posting on-line documentation alone gives the impression of a local authority that wants to exclude a proportion of the population and to railroad its proposals, with scant regard for the wishes of residents who support the area and pay their community charge.

We believe that the Local Plan is very bad for this area and we hope that wiser councils will prevail by those who wish Leamington to prosper in the long term. We, therefore urge that the current proposals be rejected.

An era of austerity dictates that profligacy can no longer be tolerated. Spending constraints are a
necessity with budgets at all levels. The following comments are submitted to address this particular
aspect.
Significant development opportunities have been neglected in favour of a financially wasteful
scheme. It has been nigh impossible to find the logic for the planning decisions made. Glossaries
and Source References in the published material appear to have been 'lost in translation'; and public
access to detailed Planning and Survey documents is limited.
No objective audit of Housing Need (quality and quantity), appears to have taken place. Equally
lacking is an audit of Existing Development Opportunity, including canvassing and incentives for
Windfall Sites offered up for consideration now or for release within the next 15 years. If demand
for these new houses is a fiction, then they will blight the area and depress market values generally
for the whole of the District. Added to which Employment Opportunities cannot be guaranteed for
the budgeted influx of additional people.
In South Leamington, we have the near perfect basis for a 'Transport Hub', based on the existing
Railway Station. Similarly, there is a 'Commercial Hub' already in existence immediately adjacent
to the 'Transport Hub' extending to the Warwick Gates development, just begging to be extended
and developed. So why have Planners shied away from exploiting these remarkable assets and
advantages ?
The selection and use of large areas of Greenbelt land for development is irresponsible, being
contrary to accepted National and Local policy. 'Very Exceptional Circumstances' have not been
demonstrated, nor can they. Once this land has been developed it is lost to all for ever, depriving
those living in the District, of a much loved green lung and offering opportunity for quiet, peaceful
recreation in an attractive environment close to Leamington Spa. This unacceptable sense of
impending loss is not confined to those living in the two parishes or those adjacent to them !
Large areas of the best local Agricultural Land, in a very sensitive area, have been selected for
development regardless of the ultimate consequences, they include :
a)
The loss of land devoted to Food Production.
b)
Irreparable damage to the local ecosystem, comprising the watershed to this loop of the Avon.
c)
Reduced separation between Leamington Spa & Kenilworth and the loss of separate identity.
d)
The present attractive gateway to North Leamington Spa will be significantly diminished.
The Social, Economic & Environmental losses incurred by developing this land far outweigh the
gains, particularly when it is perfectly clear that there are realistic and preferable alternative
development options, - but see later.
It is generally acknowledged that World demand for food fast approaches the tipping point, where
demand is set to exceed supply. This can only accelerate under the influence of Global Warming,
Climate change and the detrimental effect on Weather Systems. This in turn introduces the
circumstances leading to significant international conflict. It follows that UK food production must
be stepped up and be geared towards greater self-sufficiency. This is the only way to avoid serious
food shortages the like of which most cannot contemplate and which few UK residents, alive today,
have experienced.
At least one thriving Farming Business will be seriously damaged and its viability put at risk.
Further loss of Greenbelt land is threatened, as the planned development unfolds identifying sites
for the supporting commercial development, new road systems and infill. This is only hinted at in
the Local Plan, but it is an inevitable consequence. This further encroachment on Greenbelt land
could destroy as much Greenbelt land again.
Two road developments are contemplated, both of which are unnecessary and will achieve little.
The dual carriageway proposed for the A452, can only transfer congestion from one place to
another, slightly more quickly. The proposed new Northern relief road (additional to the A46 ), can
only realistically be used preferentially by those living in the houses comprising the proposed new
development in Blackdown and South of Old Milverton Lane.
Although the planners state the cost of this exercise will fall to the developers, an ambiguity is
apparent signifying there will be a cost over-and-above that met by the developers, which can only
fall ultimately on Rate Payers; this element has not been quantified. The allowance for the Northern
Relief road of £28m seems unduly small bearing in mind the problems faced in driving a road
through a large area prone to flooding, together with the construction of a new bridge over the
Avon and probably a new bridge over the Railway (or significant re-enforcement of the existing
bridge). The additional unknown costs will inevitably fall to Rate Payers.
The most important financial/economic consideration is that despite the recently established
comprehensive infrastructure South of Leamington; it is now proposed to develop North of
Leamington which will involve the construction of new roads and a whole new infrastructure to
cater specifically for the 1,980 houses intended. This is an extravagance which cannot be justified.
Infrastructure includes the major services, Water, Gas & Electricity, Sewers, Roads, Rail, Canal,
Recreational & Faith facilities, Schools, Supermarkets, Restaurants, Public Houses, etc. All are
successful and well established in South Leamington and in many cases lend themselves to
expansion and development. How can it be sensible to duplicate much of this North of the town,
only to exacerbate the existing traffic and parking congestion by encouraging unnecessary cross
town interaction ?
Access to major road and public transport networks seems to have been largely ignored in deciding
where to develop. Access to the M40 and Rail Network looms large in any sensible planning
decision. The Mainline Rail Stations and Coach Services have seemingly been ignored. Housing
and Workplaces (requiring large work forces) ought to have been considered for location within
walking/cycling distance of Leamington, Warwick, Warwick Parkway and Hatton Railway Stations.
All this emphasises the imperative to develop South, East and/or West of Leamington, even if solely
for the one consideration of access.
It will not have escaped notice that Windfall Development opportunities within the towns and
villages have been ignored. They appear to have been 'airbrushed' out of existence. There are
significant areas of Whitefield & Brownfield sites available. There are areas of prime redevelopment
opportunity constantly offered up. The old Fire Station, the old Ford Foundry,
redundant schools, the many empty shops constantly referred to in the local newspaper as a disgrace
and a blight on local communities. Past Planning decisions in this and other towns have resulted in
most town shopping centres becoming a ghost of a previous existence through the enabling of 'out
of town shopping centres'. So why not re-populate town centres, at basement, ground and above
ground level ? Flats over shops have long had an appeal for the young and those relying on public
transport. This way of living is accepted as 'normal' in London and other major towns and cities.
If it is seen as particularly desirable to have the major part of the new development largely in one
piece, for community identity, sharing infrastructure costs, services etc. The Prince Charles inspired
'Poundbury Development' urban extension to Dorchester offers a useful model. What is wrong with
building a 'Royal Poundbury' style extension' to Royal Leamington Spa ?
There are two natural sites for such a development. One to the East, between Radford Semele and
Cubbington; another to the West, between Warwick Parkway and Hatton Stations. Achieving this
requires the application of objective contemporary problem solving for planning decisions fit for the
longer term; and with the Environment, People & Communities, for once, given the consideration
they deserve, rather than pandering to the wishes of Developers, Architects, Planners and Politicians
who so rarely live in the houses they cause to be constructed for others to inhabit.

Please note my objections to the stated "Preferred Options" for the new Local Plan. How can the options be considered "preferred" when the document has only just gone out for public consultation?

I am extremely concerned that the options include development in the green belt land and that the Council have not demonstrated the "exceptional circumstances" required by national guidelines to permit such development.

The projected growth figures are based on modelling from the past. This has not been, or can ever be, a study in the true scientific sense. In the end it is largely a matter of opinion and herein lies an opportunity to re-work the figures. This is crucial because the whole plan could be based on flawed reasoning and methodology.

The Council appears to be "playing safe" and too mindful of the potential for challenge from those with vested interests. Why, for example, has the Council gone for the higher option when a lower option is available.

Providing new calculations and hence lower projected growth figures are at least as soundly based as the current study then there cannot be any greater fear of rejection at Ministry level. Objections to the preferred options are unlikely to be assuaged by anything less.

In the "Strategic Plan" which was abandoned due to the Government change and the changing requirements of the new Government, your Council were able to find land for such development without incursion into green belt land. Can you demonstrate why, despite the fact that it is deemed that fewer homes would be required in this new Local Plan, you now wish to build nearly 2,000 homes in the green belt and, in addition, provide employment opportunities and, possibly, a new major relief road.

Not enough credence has been placed on the fact that the green belt land required in North Leamington is highly valuable agricultural land and whilst, as I understand it, farm land was never included in the original Green Belt policy it should be recognised that the world has changed considerably and when taking into account climate change and the very real issue of a worldwide food shortage then this land should be protected for agricultural use. In addition to the land required for the proposed development, additional land would also be required for infrastructure thus further eroding this land, and indeed blight the remaining agricultural land.

As Developers have been involved in the drawing up of the new Local Plan their views will obviously be biased. The Council will undoubtedly have considered "trade-offs" with such developers in order to fulfil the requirements of the plan if it is to be approved and there is no doubt that developers will be much more interested in this highly desirable green belt land.

As we are living in a democratic country then democracy should be seen to be working and the local residents should be at the forefront of any decisions relating to this new Local Plan.

In conclusion, these plans are seriously flawed and I strongly object to the desecration of one of England's most beautiful areas. The Government National Policy Planning Framework should put powers to protect the local countryside and green spaces, which are so valuable and fast disappearing, in the hands of the local people and I urge Warwick District Council to listen to local residents who are united in their objection to the Council's "Preferred Options" in this new Local Plan.

The County Council, under the Localism Act 2012, has a "duty to co-operate". The duty to co-operate requires councils to 'engage constructively, actively and on an on-going basis' on issues relevant to statutory plans. Therefore, we will assist in the plan making process and infrastructure planning on an on-going basis.

We welcome the vision and direction of the local plan to create sustainable communities and a quality environment for all those who live and work in the District.

As well as our statutory duties our view is also set out in the context of the County Council's vision contained in the "Going for Growth" paper approved in April 2012. The purpose of this paper was to identify how the County will embrace the coalition government's twin primary aims of reducing deficit and securing growth in this challenging period of public sector austerity. The "Going for Growth" paper sets out how we will assist in stimulating and influencing the business and economic environment (with the necessary educational, skill development and community ambitions) to deliver 'growth' for Warwickshire.

In respect of indicating support for any particular development Option: our view is that there should be a right balance of sites that support growth. Therefore, it is a matter for the District Council, to satisfy itself and strike the right balance, in respect of deliverability, viability and sustainability and supporting infrastructure required to deliver each option.

The planning issues and policies contained in the "Preferred Options of the Local Plan" will impact at differing levels on the County council's corporate responsibilities, particularly economic, transport, support for the elderly and extra care housing, library services public health, gypsies and travellers and education. The Director of Public Health has already responded directly to you on the consultation and evidence.

The key values contained in the "Going for Growth" paper are stated below in emboldened text and their implications for planning and landuse policy is explained in the embolden text below:

* Our social investment will contribute to a county where the will compare well to other British communities.

We will look for planning policies that support technological Infrastructure and in particular in rural areas. We will support the strategic employment sites of the strategy.

* With a sense of mutual ownership of public services (the Warwickshire Shareholder).

We will support positive planning policies that embed co-location of services with the voluntary sector, private sector providers and other public bodies.

* We will achieve a discernible reduction in inequalities in social, economic, health and well-being regardless of age disability or culture.

This applies to access to goods and services for local residents including adequate provision for gypsies and travellers.

Planning policies on extra housing and affordable is provided with the necessary long term supporting services. We will support proposals and policies for co-location of services.

* A vibrant economy will produce high quality job offers in Warwickshire, raising the skill levels in the overall workforce so that we are as productive and competitive as the best in the Country.
* Warwickshire will be a place which looks actively at the best practice from other places - international as well as national - to develop innovative and entrepreneurial solutions. Our economic well-being will be measured by international comparison not simply against "West Midlands" regional standards. Our urban town centres will punch above their weight when compared with similar sized English town centres and our rural infrastructure will be amongst the best in the Country.

We will support planning policies that support a competitive economy for inward investment.

Warwick and Stratford upon Avon are international destinations and make a significant contribution to the economy of the region and sub region.

Therefore, we will support planning policies that support and sustain the key town centres.

* Our growth plan will attract people to live and work in Warwickshire as a specific choice. There will be a strong brand image, underpinned by a recognition that this as one of the best places in the Country to live and work.

Our strategic policies contained in the Local Transport Plan and Growth strategies support the improvement and the provision of strategic infrastructure such as junction improvements to strategic highway network and provision of new railways stations.

* There will be a strong Health and Well-being ethos about the quality of lifestyle we are encouraging.....where the brand "Warwickshire" will be directly associated with a health-focussed lifestyle supported by the health infrastructure to match.

The National Planning Framework requires Local Plans to include policies for health and well-being. The County Council is also responsible for Public Health and we would seek overarching planning policies in the Local Plan that support health and well-being as part of new developments in the District.

We are committed to delivering the best possible health and wellbeing outcomes for everyone, helping people to live Warwickshire.

Planning for health is important not only from a legislative perspective, but
also in relation to costs. Promoting healthy lifestyles, avoiding health impacts
and tackling health inequalities throughout the planning process could result
in major cost savings to society. There is significant evidence on the effect that spatial planning has on community health and well-being and spatial planning policies can address local health inequalities and social exclusion. Some local authorities have adopted planning policies to promote the health and well-being of residents through development management. The Local Plan can contribute to health and well-being in the following way:-

* The quality and opportunities of the local environment is a contributory factor in shaping health.
* Transport and traffic, access to public transport, lack of open space and where we shop for food are just a few examples of how the built environment influences our physical and mental health.
* Planning can positively affect the health of residents by shaping and influencing the layout and the open spaces in between developments and securing investment for the public realm.
* For example, planning policies can include; design requirements for housing layouts to encourage safe and pleasant walking short distances to amenities and services.
Developer obligations can be used to build infrastructure such as healthcare facilities, parks or cycling routes. There should be an overarching policy that promotes health and welling for communities in the District area. Spatial planning policies can promote and provide opportunities for healthier lifestyles.

It is against the above background that the comments are made to the specific questions. This letter contains an amalgamated response from various services. Whilst we have endeavoured to bring together as many responses as possible to assist you in the development of your Core Strategy, please be aware that there may be other services that may have comments to make at subsequent consultation periods as the process moves forward.

We wish to make detail comments on the Infrastructure Delivery Plan by mid-September. However, our general comments are set out below:

Comments in relation to adult social care and specialists housing needs.

Preferred Option 6 (PO6) Mixed Communities & Wide Choice of Homes

Para 7.5.3.
C. Homes for Older People should also include homes that include the needs of local older people, adults and children with disabilities and other local vulnerable people who need care and support. Therefore, this policy should include provision for; extra care housing and supported living accommodation suitable for adults/children with disabilities.

Para 7.5.8.
The Local Plan should provide clarity on the difference Use class C2 and C3 Usage Class. All too often we are seeing the C2 Usage Class applied to individual dwellings, which seem to become institutional if they are providing independent living solutions to vulnerable adults, e.g. McCarthy Stone development in Southbank Road, Kenilworth.

Extra care housing and use class C2 and C3

There is currently some uncertainty about the precise the definition of the different care market sub sectors, including that of 'Extra Care'. Extra Care may be defined as a scheme where occupiers have their own self-contained apartment or living space(s), and generally do not wish to live entirely by themselves without access to care, but do not require either, constant care. Such occupants would have the option of purchasing, as their needs require or are determined varying degrees of domiciliary care.
In terms of which use class order Extra Care falls within, its widely recognised definition, particularly regarding the varying degrees of care provided to residents, has led to debate over whether it comes under C2 Residential Institution or C3 Dwelling Houses.

The issue here is that care homes and extra care housing - both offer long term care solutions - but the preferred model (and this is the view of older people) is independent living (use class C3) with access to 24/7 care rather than admission to residential care (use classC2). We are seeing the market over providing ie residential care homes delivered ahead of extra care housing. If the number of residential care beds introduced to the market hits the predicted number of overall required care places (extra care housing and residential care), planners are likely to argue that there is little need for extra care if the residential care market has already delivered the required/reported numbers

Housing polices within the Local Plan should, therefore, clearly set the distinction between the class uses and also address how those needs will be met.

Demand for Extra Care housing
Based on the 2001 census Warwick District Council will need to provide 1197 units of extra care housing of which 299 should be "social rented" extra care housing. The latter figure should be form about 10-15% of the affordable housing numbers for the District.

Draft Infrastructure Plan
4.4.1.
The first sentence could be re-written to read as "Adult Social Services are mainly concerned with adults and older people with physical and/or learning disabilities and/or mental health problems"

4.4.4.
The last sentence should read as "Residential care accommodation is..."

4.4.5.
May be better to refer to "older people and adults" rather than "...elderly and non-elderly people..."

4.4.6.
This needs to reflect the current 50/50 service model promoted by the County Council, i.e. a model where 50% of people who would normally go into residential care are diverted into extra care housing.

4.4.13.
The suggestion that "Housing accommodation...for people with learning or physical disabilities will be met as the need arises" needs to be clearer.

At present only a limited number of people with learning disabilities are afforded the opportunity to live independent and meaningful lives with choice and control over where and who they live with. Instead, many have their lives constrained by having to live in residential care where individual outcomes do not generally improve. With approx. 300 people with learning disabilities currently living in residential care in Warwickshire, the overall programme intention is to deliver no less than 200, 1 and 2-bedroomed apartments that are suitable for adults with learning disabilities, including an initial short term target of an average of 25 apartments per annum between 2011 and 2015 in line with the County Council's Transformation agenda.

There are about 227 people with learning disabilities in the Warwick District, some are living in extra care accommodation and the others with their main carer (this could be parents or partner). Some residents are living in "hard to let" properties and can be victims of abuse and hate crime. These specialists accommodation would provide suitable and safe accommodation for these vulnerable residents.

General comments:
The District Council needs to include both anecdotal and specific needs analyses from a range of partners, such as local GPs, CCG, NHS Warwickshire and WCC. All these partners directly support and commission services for vulnerable people with a range of health and social care requirements, and these factors need to be considered when looking at overall housing provision.

Development Management and the consideration of planning applications for Care homes.

It is the joint view of the South Warwickshire Clinical Commissioning Group and the County Council as the Public Health and Adult social care providers that the District Council should consider bringing forward a Supplementary Planning Documents ( SPD) to secure the proper distribution of housing and the implications the potential residents have for supporting care and clinical services.

We are therefore request that a moratorium on C2 applications placed. We also recommend that there should be an introduction of a two-stage process to assess planning application on behalf, i.e. a preliminary panel at Pre-Application stage. This could be made up of WDC, WCC, CCG (inc. local GPs) and NHS to consider any specialised accommodation, particularly as the District continues to attract interest from private developers who are seeking to provide specialised accommodation clearly geared to attracting the private pound and/or an imported population. This has implications for both Health and Social Care as follows:

1. NHS Continuing Health Care budgets are being used to fund services for an imported population rather than local residents. These new (and expensive) care homes or housing developments provide an attractive solution to meeting the needs of the private funder, however, we are still seeing those who cannot afford these prices being moved away from their local communities to where services are available. There will also be a drain on local GP and Nursing resources as these new and sizeable care homes come on stream.
2. Extra Care Housing delivery is complex and continues to struggle when reaching planning and enabling stages as it becomes embroiled in local policies. Therefore there should be planning policy guidance to create the proper balance of C2 and C3 housing for the District.

Subject to the input from the "specialist care and clinical services" panel, a development proposal could then progress to formal application for planning consent.

Heritage and Culture matters

We support the District Councils Local Plan direction in safeguarding and enjoyment of our natural and historic environment together with the district's rich heritage and visitor economy. Our specific comments are:-

Section 4, we would welcome specific reference to the interdependency between the district's tourist offer and the safeguarding of its natural and historic environment, and the provision of heritage and cultural activities and venues.

Section 7, we welcome reference to the need to maintain and develop the heritage and cultural infrastructure to support the needs of new residents and to support new communities in developing a sense of identity and social cohesion.

Section 10 tourism and the quality of the built and natural environment are linked, therefore, the contribution of the high quality of the environment should be specifically stated in any policy to maintain the role of towns as visitor destinations.

Section 17, we feel that the introductory list of cultural venues should include museums and archives. The paragraph on "Seeking contributions" should include heritage and cultural facilities; as communities grow, the cultural infrastructure and activities programme needs the opportunity and financial framework to grow accordingly.

Archaeology
We welcome the acknowledgement given to the importance of the District's historic environment in para. 11.1. However, archaeology and the historic environment in some cases should be joined up.

The document refers to the 'built and natural environment', (e.g. para. 4.11.7, 4.12.14, 10.4, 10.6, 11.2). 'historic areas' or the protection of 'historic assets', these terms appear to be used interchangeably. We recommend that the references to 'built and natural environment' throughout the document be re-worded to reflect that the historic environment is made up of a wide range of different types of heritage assets (including archaeological features, historic landscapes etc), rather than just historic structures.

Para. 11.1 describes the historic environment in terms of statutory protected, designated sites, such as Listed Buildings, Scheduled Monuments etc, and locally important historic assets. There are also a number of archaeological sites across the District that are of national or regional significance but may be undesignated and the local plan should also recognise this
There are also several instances where references to the protection of historic structures (such as the references in PO11 to the submission of nationally important historic assets for listing, and the bringing back of Listed buildings into use), could be expanded to take into account other, non-built, heritage assets. For example, PO11 could be expanded to include the putting forward of nationally important archaeological sites for protection as Scheduled Monuments, not just historic structures for listing.

Further clarification is needed in PO11 by "support the understanding of the significance of Heritage Assets, by: There should be provision for appropriate research for all applications relating to the historic environment".

Further clarification is needed about the reference to the Planning Authority undertaking research for all applications relating to the historic environment, or reference to requiring any planning applications relating to the historic environment to be accompanied by an appropriate assessment of the likely impact that the proposal will have upon the historic environment, as per para. 128, of the National Planning Policy Framework (NPPF). We recommend the re-wording of this section of the document and assistance from the County's specialists can be provided.

Further clarification is needed about the term 'locally designated historic assets' in PO11. It is not clear whether this is referring solely to designated historic assets such as those included on 'Local Lists', or whether this is also referring to historic assets recorded on the Warwickshire Historic Environment Record (HER). We would recommend that reference is made to appropriately considering (and protecting if appropriate) all heritage assets as part of the planning process, whether designated or not, and that reference also be made to heritage assets recorded on the Warwickshire HER. We would also recommend that this policy acknowledge that there may be as yet unidentified heritage assets across the District which may be worthy of conservation, and which may also require protecting during the planning process.

The terms 'heritage assets' and 'historic assets' are used interchangeably throughout the document. We would recommend that the term 'heritage assets' be used in preference to 'historic assets' as this is the term used throughout the NPPF and other policy documents.

We support the reference in PO11 to the use of Article 4 directions to help protect the historic environment.

PO11 proposes protecting the historic through the submission of nationally important historic assets for listing. Not all heritage assets of national importance are listable, some may be better protected by being statutorily protected as Scheduled Monuments or included on the English Heritage 'Register of Historic Parks and Gardens of special historic interest in England'. This policy should reflect this.

We also suggest that indirect impacts of development on heritage assets should also be added to any criteria based policy, for example, the impact that a proposed development may have upon the setting of a heritage asset which may be outside of the planning application site. Whilst there is reference to setting in para. 11.9, this is only referring to the setting of Conservation Areas.

Chapter 11, Para. 11.6 should read 'putting them to viable uses consistent with their conservation'

We also note the intention to draw up Local Lists of heritage assets (PO11); There should be clear methodology for identification of appropriate sites on the basis of our Historic Environment Records data. There should be acknowledgement throughout the Local Plan that open space can support conservation of the historic environment as well as the natural environment.

The list of areas of historic or environmental importance in the District should include reference to "41 Scheduled Monuments". We would also recommend that reference be made to the significant number of undesignated heritage assets within the District which are recorded on the Warwickshire Historic Environment Record.

We welcome that Chapter 15: Green Infrastructure makes reference to the Warwickshire Historic Environment Record (including the Historic Landscape Characterisation and Historic Farmsteads studies) (para. 15.21), however, it is disappointing that no reference is made to these within chapter 11, which specifically deals with the Historic Environment. It should be noted that whilst para. 15.21 states that the District Council has the Historic Environment Record

Proposed development sites
The Strategic Housing Land Availability Assessment (which has informed the choice of preferred development sites included in the proposed Local Plan) should also assessed the impact that the proposed development of these sites could have upon the historic environment.

Whilst the assessment has identified statutorily protected sites on and within the vicinity of the potential development sites, however these have not considered a number of known un-designated heritage assets which the Council may also wish to consider. . These undesignated, heritage assets are of national significance and worthy of conservation. The assessment should also consider the historic landscape character of these areas.

In addition, as noted in our previous responses to the earlier Options paper of July 2008 and the 2009 "Proposed Submission Core Strategy" consultation, there will also be archaeological sites as yet undiscovered which will not be recorded on the HER, and even in areas where no archaeology has been recorded, evaluation may be required to confirm the presence/absence of remains. Consultation on a site by site basis will remain the best means of identifying archaeologically sensitive areas on the basis of current knowledge, as well as areas where archaeological potential will need to be assessed through more detailed work.

Since the individual allocations will need to take account of the impact upon historic environment we recommend that further work be undertaken to identify the issues in respect of the historic environment.

The selection criteria for the major development sites should also include for a thorough consideration of Historic Environment, and proper appraisal is undertaken and allowance made where necessary for preservation of sites of national Importance (in the sense of the 1979 Ancient Monuments and Archaeological Areas Act and the National Planning Policy Framework). We perhaps need a separate meetings to work on a systematic assessment of potential sites being put forward.

Tourism policy - general comments
We support the tourism policy of the Local Plan. Tourism is a significant sector of the overall economy within Warwick District and is recognised as a strategic priority within WDC's emerging Economic Development and Regeneration Strategy, it is recommended that Local Plan polices. Therefore, the District Council should also consider to referencing tourism as part of policy no P0 8 Economy and vica versa.

PO 8 Economy
We support the preparation of the Economic Development and Regeneration Strategy to provide a clear direction for growing and sustaining the economic position of the District Council area.

PO 17 Culture & Tourism
Rural broadband policies and policies for Culture and tourism should be cross referenced to promote the quality of the offer in the District.

It is therefore recommended that an introductory statement along the lines of Weston-Super-Mare might be more suitable:

"The Council will work with partners to support the development and retention of new and existing tourism facilities, for both business and leisure markets and promote their sustainable expansion across the District, whilst maximising their co-locational and cumulative benefits to:

* assist in regenerating our town centres by supporting growth of their retail, evening and night time economies by offering facilities and functions that could encourage spending within the wider areas;
* assist with development of green infrastructure corridors linking destinations and attractions for the benefit of both residents and visitors;
* improve the range, quality and distinctiveness of the District's tourism destination;
* provide high quality hotels and serviced and non-serviced accommodation formats and conferencing facilities;
promote the image and reputation of the District to attract visitors and secure investment."
Town centre tourist accommodation
We support the "town centre first" sequential approach for the further hotel accommodation. To support this and as an alternative, it is recommended that the Council consider the following policy wording:

Within the existing urban settlements of Warwick, Kenilworth and Leamington Spa, proposals that would result in the change of use hotels and tourist accommodation will be permitted unless:
* the proposed use or uses would reduce the overall capacity and attractiveness of Warwick, Kenilworth and Leamington Spa as tourism hubs and result in the loss of an otherwise viable hotel or tourist facility which would consequently harm the provision of tourist accommodation;
* the proposed use or uses would be incompatible with the surrounding area and businesses and would harm the character of the town centre;
* there would be no clear, additional benefits from the proposal in terms of improving the character of the area, the vitality and viability of the town centre and the economic and, cultural and environmental impact on the town as a whole.
Applicants seeking change of use away from existing hotel or tourist accommodation use will need to submit detailed evidence relating to the viability of the business and details of how the business has been marketed.

Rural accommodation

We support tourism in rural areas and we recommend that the Local Plan should have a specific policy to address expansion and re-development of existing tourism accommodation and tourism facilities within the Green Belt.

Accommodation not in permanent buildings
The District Council may wish to consider an additional policy to cover accommodation not in permanent buildings (i.e. camping, caravan and chalet parks). This type of accommodation can be damaging to the character of landscapes, and in rural areas the added light pollution can be intrusive. It is recommended that small scale developments should be supported in areas of open countryside or next to small settlements provided they are not prominent in the landscape and have high quality landscaping. The policy may choose to exclude locations in sensitive landscapes and areas prone to flooding.

Ecological & Geological
We welcome and support the strategic direction outlined in the Preferred Options document in relation to the Natural Environment and would like to make the following suggestions:

4. Spatial Portrait, Issues and Objectives
4.7 - Sites of Importance for Nature Conservation are now referred to Local Wildlife Sites. It is suggested that Local Geological Sites are also listed. You may wish also to consider using the Habitat Biodiversity Audit and the State of Biodiversity Report to provide a Spatial Portrait of the District's Biodiversity.
4.8 - You may wish to add climate change as a pressure in bullet point 9

7. Housing
7.5 - You may wish to add within the important issues a reference to the natural environment such as "Maintain access to the natural environment in both urban and rural settings to reap social, economic and well-being benefits".
PO4 Distribution of Sites for Housing: (A) Allocated Sites - we are aware of the habitat evidence submitted for the previous work on the local plan, but would suggest that a new model has been produced to measure Habitat Distinctiveness and Connectivity throughout Warwickshire, Coventry and Solihull. This approach is placed at the heart of the National Planning Policy Framework as a way to indicate 'sensitivity' of habitats within potential allocated sites and how the site acts within the ecological corridors. We would recommend that this approach is investigated as partners to the Habitat Biodiversity Audit with the knowledge that the habitat data is current and sound.

PO4 Distribution of Sites for Housing: (C) Development of Brownfield Sites - we welcome the comment relating the development having 'no serious impact on the amenity and environment of their surroundings'. However, brownfield sites can be e very important ecological sites in their own right so suggest that this aspect is noted in the future policy.

8. Economy
There is no reference to the relationship between a healthy environment and the economy. It is suggested that this link is made in the introduction to add weight and substance to subsequent paragraphs within the policy such as 8.15. For example a statement could be, "There are proven links between the natural environment and economics (National Ecosystem Assessment, 2010) through an Ecosystem Services approach. It is essential that these links are maintained and enhanced through both the placement and setting of commercial activities coupled with the retention of agricultural and silvicultural practices." Further pictorial reference to explain Ecosystems Service can be found in the National Ecosystem Assessment documentation.

9. Built Environment
We support the 'Sustainable Garden towns, suburbs and village' design guide as well as the Relevant Issues and Strategic Objectives.

10. Climate Change
It is recommended that more be added in relation to Climate Change Adaptation within the introduction to support the last bullet within the box titled PO12 Climate Change.
12.25 - 12.26 These paragraphs outline the impacts and issues relating to Climate Change Adaptation, however, it is felt that this topic could be expanded upon within future documents, e.g. an addition Supplementary Planning Document or equivalent. This additional document could promote green roofs, green walls and other ways to promote urban cooling etc. WCC Ecological Services is able to signpost you to a couple of other Local Authority documentation on this topic.

11. Transport
It is recommended that reference be made to the Natural Environment White Paper (2011) and the importance of transport networks and ecological connectivity assets.

12. Green Infrastructure
In our opinion we suggest that this chapter is well balanced and support its approach. It is suggested that additional references to Ecosystem Services, the Warwickshire Biological Record Centre and the importance of using up-to-date ecological and geological / geomorphological data is used is the assessment of development proposals. These should be added to the future policy and the Ecological Services are able to assist you with this advice, subject to resources.
By the time the future policy is formed the Sub-regional Green Infrastructure Strategy will have been produced for consultation and can be more fully referenced as a mechanism to deliver your objectives outlined in this chapter.

18. Flooding and Water
In relation to ecology it is recommended that there is future referenced to the safeguarding or promotion of natural flood alleviation areas at strategic sites within the district as short, medium and long term aspirations to assist with flood risk measure. We are aware that this may form part of the Catchment Flood Risk Management Plan (18.9) or fall within the Sustainable Urban Drainage Approving Body's remit, but would suggest that these strategic potentials should be particularly noted within the future policy. These sites could then be potential delivered through the biodiversity offsetting metrics (15.16).

It is also recommended that a further discussion be held regarding the assessment of allocated sites using latest modelling of habitat data.

Comments regarding minerals safeguarding
Para. 143 of the National Planning Policy Framework (NPPF) requires that in preparing Local Plans, local planning authorities should define Minerals Safeguarding Areas and adopt appropriate policies in order that known locations of specific mineral resources of local and national importance are not needlessly sterilised by non-mineral development, whilst not creating a presumption that resources defined will be worked; and define Minerals Consultation Areas based on these Minerals Safeguard Areas.

The British Geological Survey's 'Guide to Minerals Safeguarding in England' (October 2007) provides the following advice:

"A district DPD could include policies that set out the general approach the district will take when determining proposals for non minerals development within or close to MSAs or existing mineral workings. Such policies should acknowledge the procedures for consulting the MPA on the existence and extent of mineral resources present and considering the case for prior extraction of mineral where appropriate."

In June 2009, the British Geological Survey (BGS) completed a piece of work to delineate Warwickshire County Council's Mineral Safeguarding Areas (MSAs)/Minerals Consultation Areas (MCAs). The BGS identified the extent of individual mineral resources in Warwickshire and these, in turn, were used to develop safeguard areas for each mineral. WCC would suggest that these MSAs/MCAs are either identified on WDC proposals maps and/or a link is provided in the Local Plan to Warwickshire's Minerals Safeguarding webpages. This will help to ensure that minerals implications are taken into account as part of decision making for District planning applications.

We would request that where certain applications may potentially sterilise minerals deposits within an MSA, the District Council consults the County Council. If the County Council concludes that minerals reserves may be sterilised, the applicant may be required to submit a Minerals Survey to establish whether the reserve is economically viable. In some cases, the County Council may insist that prior extraction of the minerals is undertaken prior to the non-mineral development being carried out. It is considered that the inclusion of this procedural information will improve the effectiveness and deliverability of the policy.

In assessing the Preferred Options, it is noted that there appear to be sand and gravel deposits under the 'Whitnash East', 'West of Europa Way' and 'South of Gallows Hill' sites - see attached map (appendix A). It would be beneficial if a minerals survey was undertaken by the developer to determine the quality and depth of the resource and to establish the feasibility of prior extraction.

Waste
Policies for the development of major residential development sites should include waste management issues as part of the overall design of larger residential/retail developments. For example, provision for waste recycling/composting on site will ensure that waste is managed in accordance with the principles of proximity, self-sufficiency and the Waste Hierarchy. Furthermore, there is a need to provide adequate waste facilities for flats and apartments - see WRAP's 'Good Practice Guidance - recycling for flats' WRAP, available at http://www.wrap.org.uk/content/recycling-collections-flats.

It should also be noted that policy CS8 of the Warwickshire Waste Core Strategy (due for Submission in September 2012) seeks to safeguard existing waste management sites. At this stage, it is considered that none of the preferred option sites are likely to prevent or unreasonably restrict any waste sites. However, if necessary the Council may object to other proposals which may sterilise important waste facilities (e.g. those delivering significant waste management capacity to meet the County's landfill diversion targets). To prevent this, WCC intends to supply each District/Borough Council with its latest waste site information, possibly in GIS format, so that the County Council can be consulted on any proposals within reasonable proximity (e.g. 250m) of existing waste management facilities.

Customer Services/One Front Door/services that support communities and families.

The County Council is open to co-location, co-access, and co-servicing of support services including support for the elderly, vulnerable adults, and families , however, these services should be located or are accessible to communities they serve. Further for new development these key services should evolve with the phasing for large developments. One solution could be providing lay-bys with " electric hook up points" for mobile services (including a mobile shops) this would build up sufficient demand before most of the dwellings are built. Consequently, make communities and developments sustainable.

Transport and Planning matters
The key transport strategies are contained in Warwickshire Local Transport Plan 2011-2016. The County Council is already working with the District Council to assess the transport impacts of various development scenarios as part of our Strategic Transport Assessment work and will be responding directly on this and other relevant transport matters. The key matters are access and sustainability of the pattern of development for homes and jobs.

We support the direction and economic strategy of the Local Plan and we need to undertake further work on some key matters ie transport, archaeology and ecology matters.

Thank you for consulting with the Home Builders Federation (HBF) on Warwick's local plan preferred option.

The HBF is the principle representative body of the housebuilding industry in England and Wales and our representations reflect the views of our membership of multinational PLCs, through regional developers to small, local builders. Our members account for over 80% of all new housing built in England and Wales in any one year including a large proportion of the new affordable housing stock.

We would like to submit the following representations on the draft Local Plan.

Plan period

It would be helpful if the local plan clearly stated the period of time over which it is intended to operate. This should be stated on the front cover and in the first paragraph of the introduction, as well as elsewhere in the document, including the section that addresses the housing need over the plan period. We assume that the plan period proposed is 2011 to 2029 although this is not altogether clear.

Section 5: Preferred Level of Growth

It is encouraging to see the Council taking the correct approach to establishing a housing requirement that is in conformity with the NPPF (hereafter referred to as the Framework). It is the function of the SHMA to assess the full housing needs of the district over the proposed plan period.

We note the three scenarios for setting a future housing requirement. Inevitably, given the uncertainties regarding the economy, relying on any one employment-based scenario as the basis for setting a housing requirement could prove too inflexible in the event that the district (or adjoining districts) experience higher levels of employment growth than projected by a particular scenario. We note that option 1 allows for 600 homes a year, while option 2 allows for 700 homes a year. Option 3 has been discounted because the projected increase in jobs would not be matched by the increase in homes (paragraph 5.19).

We do have some qualms about assuming that there is a direct relationship between new jobs in the district and the demand for new homes. The relationship may not be as strong as the Council thinks, and to some extent, the demand for housing in the district will come from people who work elsewhere, typically in the larger employment centres of Solihull, Coventry, Birmingham etc.

We note that the Council's preferred level of housing growth is for 10,800 homes over the plan (PO1: preferred level of growth). This is inadequate since it is lower than the most recent household projections and the evidence from the most recent SHMA (2012). It also fails to take into account the decisions of adjacent local authorities.

SHMA (2012)

The SHMA indicates that the annual need for affordable housing will be 698 homes per year (paragraph 7.50). This exceeds the proposed option, and, significantly, only addresses the affordable housing need, not the demand for market housing. The report does not appear to have assessed what the market need will be in the district in addition to this affordable need. As such, the SHMA does not satisfy the requirements of the Framework, paragraph 159.

It is unclear how the three modelled housing scenarios relate to the requirement of the Framework for the SHMA to identify the scale of housing needed over the range of tenures, including housing demand (paragraphs 47 and 159). It is unclear whether the figure of 698 affordable homes per year relates to the three scenarios since it exceeds two of them and is almost comparable to the third. The SHMA needs to set out what the quantity of need is for market housing and affordable housing over the plan period.

The Council has not explained in its Preferred Option why it is choosing to discount the evidence of need identified by the SHMA. It would appear that the Council is relying upon the argument that because the SHLAA can only identify land for 11,410 homes (paragraph 5.18). This, however, would be to pursue an capacity-based approach to determining the future housing requirement of the district, rather than using the new plan as an opportunity to review the efficacy of existing policies and constraints and consider the possibility of removing these in order to meet the level of housing need identified in the SHMA. A capacity-based approach would be contrary to the Framework, as the expectation is that the Council will do all it can to meet objectively assessed needs (see paragraphs 14, 17, 47, 179 and 182).

Household projections

The 2008 based household projections indicate an increase of 13,000 households over the period from 64,000 in 2013 to 77,000 in 2028 - a period that is approximately comparable to the proposed plan period of 2011 to 2029. This is a figure that approximates to option 2 - the projected employment rate scenario of 12,888 homes. The Council suggests that this employment projection is likely to be optimistic (paragraph 5.22) owing to the most recent ONS GDP forecasts. Nevertheless, the Council may be surprised, and economic growth, and consequently housing demand, may be stronger than it expects. If this is the case the plan will need to have the capacity to respond to rising demand. This would be in accordance with the Framework which expects local plans to meet objectively assessed needs and have sufficient flexibility to adapt to rapid change.

Furthermore, while we would not dispute the Council's current pessimistic economic prognosis, it is important to remember that housing demand is not solely related to employment. Warwick will continue to experience many more affluent households moving into the district who may work elsewhere and non-economically actives households will continue to consume housing in the more desirable locations. The Council will need to cater for these tastes, but also increase the overall level of supply in order that those on low to medium incomes are not priced out of the district by affluent incomers. Citing the recession as a reason to scale-back plans to accommodate more housing would also be contrary to the Government's new, more positive, planning agenda, as set out in the Ministerial Statement Planning for Growth which sees planning has playing a pivotal role in facilitating greater levels of growth.

Duty to cooperate

There is also the matter of the duty to cooperate to consider and how Warwick's plan will provide for its own unmet needs that cannot be addressed through the plan (paragraph 179 of the Framework) as well as potentially the unmet needs of adjoining councils (paragraph 182). If the council is unable to meet its objectively assessed housing need through its plan (once it has properly identified this, and once it has reviewed existing policy constraints) it will need to plan to ensure that these needs can be met elsewhere without the district. To do so, it will need to plan in concert with adjoining councils.

The draft plan appears to be silent on this question. We note that at least two of Warwick's neighbours - Solihull and Stratford Upon Avon - are advancing plans that will not meet their own 'objectively' assessed housing needs (although there is an issue with the soundness of their own SHMA assessments when judged against the NPPF). Solihull is proposing only 525 homes per year when its SHMA indicates a need for 904 affordable homes. Stratford is proposing a plan requirement of 7,500 homes yet its own housing requirements study recommends between 11 and 12,000 homes over the plan period. Clearly if Solihull and Stratford are not proposing to meet their own requirements then it is very unlikely that they will be willing to accommodate any of Warwick's unmet needs. This suggests that Warwick will need to fully accommodate it own housing requirement since it cannot rely on anyone else to pick up the tab.

The location of new housing

It is unclear why the Council feels it needs to phase the delivery of sites (paragraph 7.20). Surely, if all the sites have been assessed as being suitable for housing, and thus sustainable in terms of the Framework, it should be immaterial when these sites come forward for delivery.

PO5: Affordable housing

I am concerned that the Council is disregarding the evidence of its own viability study in setting an affordable housing target of 40% when the study would appear to indicate that a figure of 35% may be more appropriate. The Council maintains that it can ignore the evidence since it will be flexible in how it applies its policy to ensure viability. This would be contrary to the approach of the Framework which now requires that the cost of affordable housing policy and other policy requirements of the plan are deliverable and to ensure that these do not render developments unviable and thus the plan undeliverable.

This will require the Council to ensure that all its policies applied to be applied to sites, especially those earmarked to contribute in the first five years from the date of adoption of the plan are subject to a reasonable level of policy demands and planning obligations. The onus should not be placed on the developer to demonstrate viability but for the Council to ensure that the cumulative impact of all its policies and demands will ensure that the majority of sites, and especially all those earmarked for the first five years, are viable (see the footnote to paragraph 47 of the NPPF and pages 26 and 27 of the Viability Testing of Local Plans report).

We are also concerned that the study has not modelled-in properly the true costs of development, including those costs to be added to development by the proposed local plan. We note that the study has only factored-in the cost of building to Code 3 and Code 4, but building to the Part L Building Regulations (equivalent to Code 5) will be a requirement from 2016 onwards. This will represent a significant additional cost. The Council should refer to the most recent DCLG report: Cost of Building to the Code for Sustainable Homes: An update cost review, August 2011. This is a significant future but known cost that will impinge upon the viability of sites over the plan period but also in first five years, and must be factored into a new viability assessment (see page 26 of the Viability Testing of Local Plans report).

The viability assessment has also not taken into account the cost of building Lifetimes Homes which is a requirement of policy PO6. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of the requirement of policy PO12 for developments to provide on-site renewable energy plant to provide a 20% reduction in carbon emissions. A revised viability assessment will need to take account of the costs of doing so.

The viability assessment has not accounted for the cost of biodiversity offsetting which is a requirement of policy PO15. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of flood mitigation measures as stipulated by policy PO18. A revised viability assessment will need to take account of this.

The report uses BCIS costs, but this is based on Gross Internal Area and does not account for external and landscaping costs and local site works (see page 34 of the Viability Testing of Local Plans). A revised viability assessment will need to take account of this.

The figure for site acquisition costs is rather low at 5.75%. This is more likely to be between 6.5 to 7.5%. We would refer the Council to page 35 of the Viability Testing of Local Plans report.

The viability assessment also assumes a total planning gain package (S106 and/or CIL) of £6,650 per unit. This seems modest. I have commented previously on this in my letter to the council dated 20 September 2010 in which I recommended an average of £15k per dwelling is applied as a more realistic figure. Ideally the Council should prepare a CIL Charging Schedule alongside the Local Plan to ensure an integrated viability assessment and avoids the risk of the CIL setting an unrealistically high charge that has not been reflected in the viability assessment for the local plan. Under the current arrangement, if the plan was adopted, then the Council would need to ensure the levy of any CIL introduced after the plan, in combination with S106, exceeded no more than £6,650 per dwelling otherwise the plan would immediately be rendered undeliverable.

We are also unconvinced by the interpretation of the evidence. We do not feel that the council's conclusions are legitimate ones to reach since the evidence does not support the assertion that either 35% or 40% affordable housing is viable. However, this is really a matter of secondary importance compared to the need for the Council to undertake a Framework compliant viability assessment that takes into account the costs of development, local policies and plan requirements.

Further to my objection, already sent by email, to the preferred options in the Council's new local plan. I hope you won't mind if I send some further observations after the packed meeting at Old Milverton Church last evening.

In the long presentation residents listened to from the planning officer, although he talked regularly of having to base decisions on "evidence", there was no evidence-based justification offered for why the parcels of land in South Leamington which had been identified for development in 2010, had been removed from this new set of preferred options. What we got was a lot of supposition, "we think," and "it might reach a tipping point." And "if the government didn't accept;" (though why they shouldn't accept building on non green belt land in preference to green belt land was never made clear.) None of these arguments, in the minds of the numerous residents there, added up to "exceptional circumstances" to justify building on green belt land before non green belt land.

The mention of the three gas pipes as a barrier to development in the South seemed a minor obstacle that could easily be got around. Professional planners and architects in the audience attested they could be used as cycle paths or green pathways in the sort of mixed development the council says it favours. They certainly didn't add up to a justification to completely remove a major prime development site which isn't designated as green belt, from the list of options.

The excuse that there would be too many sites being worked on at once really doesn't hold water when the council has explained that the development will be going on over a period of 15 to 20 years. The infra-structure costs are more cost efficient in the South of the town and should be concentrated there to make a real difference to the lives of residents who live close to where their employment is most likely to be.

To spend tax-payers money on an extremely expensive relief road over valuable green belt land in the North just doesn't make any sense at all. There should be no need for it.

It became quite clear that the number of houses being planned was by the Council's own admission, far higher than their own (questionably arrived at ) projections demonstrate a need for. Again we weren't given any evidence based calculation for the final number of houses arrived at but the rather vague argument "if in the future we decided we needed some more." Is this an exceptional circumstance which justifies building on highly rated green belt land?

Councillor Doody suggested we write to make suggestions of where else the development should go. Well of course the first answer is on the non green belt land the council has itself identified. The next answer is that the place you absolutely don't start your development is on the green belt land that your own Joint Study has identified as meeting all the purposes of green belt land, of being of high value, and has recommended, "should be wholly retained within the green belt." I am referring here to the parcel of land WL7 at Blackdown/Westhill.

If you absolutely have to encroach on green belt land, which I don't believe you have demonstrated that you do, you should start on parcels of land with a lower value and you have already identified these in the Joint Study.

In terms of being a prime example of Arden character parkland, the Joint study was so impressed by the land at Blackdown that they included a photograph of it as an exemplar of the type. This land is enjoyed not just by the local residents who overlook it but thanks to a public footpath, by the very many residents of Leamington, Lillington, Blackdown and Cubbington who regularly walk over it. Furthermore the Joint Study stressed that there was already a very well defined boundary along Leicester land. To develop this land would be to subsume the hamlet of Blackdown in the sprawl of Cubbington, Lillington and Leamington which is totally contrary to Nation Planning Policy guidelines.

I would like to finish by agreeing with the speaker last night who complained that the "Preferred Options" could not be seen by any of us as "options" when there were no alternatives offered. The consultation that went on before the 2010 plan was released was a far fairer and more extensive exercise than this one has been, and it arrived at conclusions that were based on a majority view of residents based over a wide area not just in the areas affected. On this occasion residents feel they have been bounced into a totally unfair and rather speedy process and that they are faced with trying to get the Council to back down when they have already made their minds up.

My one glimmer of hope is that there were local councillors present last night who listened to the residents objections. I was hugely disappointed that as a Councillor of many years standing and as one of my representative on the council, Councillor Doody appeared to have very much made his mind up before he came. His comments as he left the meeting were disgracefully partisan and not at all in the spirit of consultation, but I trust that the others truly understand the nature of consultation and hope that they will feel able to support us in opposing the preferred options that have been put forward.

Thank you for your email of 1st June 2012 re the above subject. The Councillors of Baginton Parish Council
have considered the Preferred Options documentation. We have also attended the WRECF meeting of
28.6.12 and the WDC Proposed Development Forum of 2.7.12. We have debated these issues at various
meetings. We have also attended the Gateway Developers presentation at Baginton Village Hall of 19.6.12
where we gained written feedback from many concerned residents.
This letter sets out our opposition to the Gateway proposals, as presented to residents on 19.6.12, being
included in the Local Plan Preferred Options. It also puts forward our preferences regarding housing need for
the area based, on our current Parish Plan. Whilst the majority of the proposals are satisfactory, in our view,
we are alarmed and concerned by tentative proposals to include the "Gateway" in the proposals, as
illustrated in the Preferred Options documents. We write asking you to consider all our comments below
when making your judgement:-
1. BPC oppose Preferred Options 8.15, 8.18 and 8.42 abstracts of which are in Appendix 1 of this
letter. BPC opposes the inclusion of the Gateway shown in Map 3, an abstract of which is shown in
Appendix 2 of this letter. The Gateway proposals are not appropriate development and should not
be included, for reasons as set out below.
2. The NPPF calls for Protecting the Green Belt in section 9. See abstracts of section 9 in Appendix 3
of this letter. Baginton Parish borders with Coventry City. There is a vital need to prevent the
unrestricted sprawl of Coventry into Rural Warwickshire, safeguard the countryside from
encroachment and preserve the setting and special character of our village, with its Roman Fort,
Castle and Grade 1 listed church amongst other things. The gateway proposal is contrary to these
fundamental requirements of the NPPF. The development encroaches on previously undeveloped
Green Belt fields which provide a vital buffer between rural Warwickshire and Coventry City. It is
essential that this buffer remains. BPC believes that WDC have an ideal opportunity to prevent the
urban sprawl of urban Coventry into rural Warwickshire. WDC should not therefore support the
Gateway project, which must be removed from the Preferred Options and local plan. The
development is in the protected Green Belt with no very special circumstances to justify its
existence. The openness of this Green Belt land must be maintained.
3. The environmental effects of the Gateway proposal have not yet been considered and there are
many reasons why such a proposal is unsustainable development adversely affecting the
environment and contrary to the requirements of the NPPF. There is no need for such a
development, which should be omitted from the local plan.
4. The proposal significantly affects the nationally significant Highways Agency Tollbar improvement
scheme; the affects which need to be clearly annotated in the local plan.
5. The Gateway includes a "smart card" system for allowing Baginton residents access to Rowley
road, but with no details of how this would be run.
6. It is noted the large industrial units are envisaged to have 24/7 operations, yet the environmental
effects of 24/7 HGV operations on local rural and other communities has not been considered.
7. The proposals are unsustainable as they fail to comply with fundamental tests in the NPPF. The
proposals are to develop Green Belt land but with no very special circumstances to warrant such
development. It is both necessary and essential for WDC to consider all other developments with
extant planning permission in the wider area. There are many such developments in the locality and
which are suited to developments of this nature, e.g. (but not limited to) the huge sites at Ansty and
Ryton, both with infrastructure already in place. Preferred Options, section 8.42 (Section 8.33 of the
draft Local Plan) specially refers to the Coventry Gateway project, it specifically states 'To
demonstrate that there are not any other preferable and suitable sites'. The above clearly
shows that there are alternative sites available with extant planning permission within the subregion,
and further afield, which provide more than adequate development opportunity, so there is
no need for this development. It is essential that the Local plan includes a requirement to review all
existing developable land in the sub-region and further afield, to ensure the proposals are robust.
BPC demonstrates that there ARE other preferable and suitable sites, so the Gateway should be
excluded.
8. There is no need, either economic or otherwise, for the Gateway proposals to be included in the
local plan. There is no case for releasing land in the Green belt for the Gateway development.
9. The development to the north of the A45, in Coventry, can be developed without destroying the
Green Belt to the south of the A45, providing 4000 jobs for the benefit of the region. There is no
need for the Gateway development south of the A45.
10. The provision of "up to" 14000 jobs is inaccurate and misleading. Given that 4000 of the 14000 jobs
quoted are for development north of the A45, within boundary of Coventry, already with planning
permission granted to another developer (Whitley Business Park), it is wholly inaccurate for the
Local Plan to headline up to 14000 jobs. Of the remaining 10,000 jobs, it is highly likely that these
will not be newly created jobs, but in the main taking jobs form elsewhere in the sub region and
further afield. These jobs can and should be created using the vast acreage of sites in the sub
region, and nearby, which are already available, or have infrastructure already in place, or have
extant planning permission, or which are otherwise far more suitable to gain planning permission.
The local plan should quote a realistic level of job creation, within WDC only, accounting for all
other sites.
11. The closing of the Bubbenhall Road and Rowley Road to the general public will destroy the many
local rural businesses which thrive in Baginton Parish, e.g. Baginton Village Store, Hong Kong
House, Smiths Nurseries, Russell's Nurseries, Oak Farm, The Old Mill, The Oak Pub, British
Legion Club and many others. Each would be adversely affected and forced to close with the loss
of jobs, adversely affecting the local sustainable community, contrary to the NPPF. It is absolutely
essential that the Bubbenhall and Rowley Roads be maintained as a pubic right of way with the
present alignment between Baginton and Bubbenhall, to maintain the sustainability of local rural
businesses hence comply with a fundamental aspect of the NPPF.
12. BPC are also concerned that the provision of a new road west of the runway could be put into a
deep cutting which would pave the way for future runway expansion. It is absolutely essential that
the Bubbenhall Road be maintained as a pubic right of way with the present alignment between
Baginton and Bubbenhall, to prevent the Airport from runway expansion in the long term. See old
proposals from September 2002 in Appendix 4 of this letter. BPC acknowledges this is not part of
current proposals but BPC are most concerned that the proposed Bubbenhall Road alterations
could facilitate the opportunity to allow such development in the future. This must not be allowed to
be facilitated, by ensuring the Bubbenhall Road stays as it is and the proposed alterations shown
on the Preferred Options are omitted from the emerging Local Plan.
13. The documents presented do not adequately correlate the requirements of the NPPF with the
proposals for the Gateway. The proposals are not therefore robust in the view of BPC, so the
proposals should be omitted.
14. There is an excellent "Green Infrastructure" opportunity to maintain the undeveloped green belt
green fields which lie to the South of the A45 and which will be adversely affected by the Gateway
project. Instead of the Gateway WDC should give consideration to developing this area under the
Green infrastructure scheme. This will have the advantage of ensuring that the surrounding areas,
such as Baginton Parish, do not suffer from urban sprawl and maintain important opportunities for
Flora and Fauna to flourish. The planted buffer zone to the urban sprawl proposed for the Gateway
is insufficient compensation for the loss of the undeveloped green belt green fields which presently
act as a natural buffer between urban Coventry and rural Warwickshire. It is also far to close to the
Lunt Roman Fort. The Gateway should be omitted from the Local Plan.
15. BPC are very concerned that the Preferred Options summary leaflet makes no mention of the
Gateway development, only showing "highway improvements as per abstract from the summary in
Appendix 5 of this letter, which are as per Map 5 of the preferred options.... This is
misrepresentative of the developer's intentions. The public are not therefore being afforded the
opportunity to see the true extent of the proposals in the summary leaflet, so are not being afforded
the opportunity to comment. This must be rectified by modifying the summary document to include
the developer's true intentions. These are not highway improvements but will destroy public
highway rights of way which are essential for the prosperity of the many rural businesses which
thrive in this area and which will be destroyed by the Gateway development. These are not
improvements but will serve to develop a huge area of green belt land and create urban sprawl,
contrary to the principles in the NPPF. It is essential that these proposals be omitted from the
Local Plan
16. The 12.3.12 WDC map entitled "unrestricted natural and green corridor greater than 2Ha" doesn't
show the green space south of the A45 which forms a natural barrier between Coventry and
Warwickshire, and is undeveloped Greenfield Greenbelt land protecting Baginton from urban
sprawl. The map should be amended, the area recognised as such and the area not allowed to be
developed.
17. Councilors believe that the Gateway proposals, by a private developer who also owns the Airport
and who is also past and proposed Chairman of the Local Enterprise Partnership promoting the
development, are foisting an unwanted and unnecessary development on Baginton village which
will ruin this rural village community, destroy essential Green Belt and destroy its local amenities
and businesses. The quality of life of Baginton and Bubbenhall residents will be significantly
adversely affected by the Gateway proposals. The proposal is against resident's basic human rights
under the Human Rights Act, due to the traffic and operations noise from huge warehouse logistics
development which will run 24 hours per day, seven days per week, with especially adverse effects
at night and weekends. Cllrs anticipate significant HGV traffic movements all night which will be
particularly disturbing to residents.
18. The Gateway development in not sustainable compared with other nearby developments with
extant planning permission, which are sustainable.
19. The proposed smart card access system for local residents and businesses is impracticable and
unworkable, with no one willing to operate it, certainly not Baginton PC. It is understood alternatives
are under consideration but based on what BPC are aware of at this time these proposals are
damaging to the village and must not be allowed to proceed.
20. The proposals put into jeopardy the construction of the Highways Agency Tollbar Island proposals
due to commence early next year. The proposals will not facilitate major improvements to the road
network not already covered by the HA proposals, but will only add to the traffic in this area.. In
addition, the proposals will only add to the traffic in this area, so will not facilitate improvements
over and above what is already proposed by the HA, so the statement must be removed from Para
8.33 of the draft.
21. It is noted from the presentation on the Local Plan by WDC of 28.6.12, at Baginton Village Hall, that
there is 23 hectares of business development land proposed within WDC boundaries separate to
that of the Gateway. Noting that many commercial premises within the sub region, and slightly
further afield in Solihull, lie empty and unused at this time, the additional 23 hectares of business
development land is more than sufficient to satisfy the need for economic growth without the
Gateway project. There is no need for the Gateway project and this must be omitted from the
proposals
22. BPC believes it is entirely inappropriate for WDC to support the C&W Gateway proposals, which
are against the fundamental principles of the NPPF, adversely affects the environment, adversely
affects Parish residents human rights to peace and quiet, will destroy rural businesses based in
Warwickshire, will develop on high quality green field Green Belt with no very special
circumstances, will create urban sprawl and which will jeopardise industrial development elsewhere
in the local area which already has planning permission or has been previously developed and will
destroy the openness of the area, amongst other things. The Gateway should be removed from the
Local Plan
23. Councillors believe there is a clear conflict of interest between the LEP, which we understand is to
be once again chaired by the Owner of both development companies, Sir Peter Rigby, and the
broader requirements of the residents of WDC. BPC Cllrs reinforce the need for WDC to be
independent and not compromise its integrity through the forced will of a developer who is intent on
ruining our unspoiled corner of rural Warwickshire for financial gain. It is wrong therefore to refer to
the LEP within the Local Plan.
24. WDC should modify the proposals to state that its preferred option is to utilise to the maximum
capacity all sites in the sub region with extant planning permission prior to developing any further
site on Green Belt Land. WDC should review all existing developed land within the sub-region. It is
vital that WDC explores and justifies the case for releasing land within the Green Belt when existing
Brownfield and other sites with extant planning permission exist within the sub region remain underutilised
and unoccupied.
25. BPC observes that the Gateway proposals do not protect the character and scale of the village, nor
the openness of the rural countryside around the village, so should be omitted.
26. BPC has already gained written feedback from almost one hundred residents, all of whom believe
the Gateway proposal is damaging to Baginton and there is no justification for ruining the Green
Belt. All wish to see the Green Belt protected. It is essential that WDC takes account of the wishes
of all local residents and excludes this development from the local plan.
27. All the above demonstrates that the Gateway site, which is stated in 8.18 as being "identified as a
site of regional importance for employment to serve the regeneration needs of the Coventry and
Warwickshire sub region" is fundamentally incorrect, fundamentally unnecessary and fundamentally
against most requirements of the NPPF, so should be omitted from the local plan.
Regarding housing policy, Baginton has a Parish Plan and requests that the deliverables in this document be
accounted for by WDC in formulating the Local Plan. In particular please note the below comments:-
28. BPC supports modest sustainable increases to housing in accordance with our letter L075A to
WDC of 8.1.12, a copy of which is enclosed as Appendix 6. This is based on the output from the
Baginton Parish Plan. The Local Plan should include opportunity related to small scale sustainable
development of this nature, to retain the nature and character of the village and help to support the
many local rural businesses in the village. Please note in particular that in all cases any housing
shall be wholly in character with the village, be sympathetic to the amenity of existing
properties/people and shall not interfere with the Green Belt. BPC opposes the Gateway
development on the Green Belt to protect the rural nature of our village, to protect the openness of
the area and to protect the surrounding area from urban sprawl.
29. BPC objects to the classification of villages generally. The Local Plan must not dictate the type of
housing development to villages, but rather should take into account village desires under the
Localism act and in the case of Baginton, our Parish Plan. In this respect we again ask WDC to
account for our letter L075A as point Nr 28 above.
In conclusion, BPC consider that the proposed gateway is entirely inappropriate and ill considered
unsustainable development, contrary to fundamental requirements of the NPPF, with no need given the
significant size and number of underutilised employment creating developments which already exist with full
planning permission in the Coventry and Warwickshire sub region area and further afield. There are no very
special circumstances to develop on the Green Belt, rural businesses need to be protected, urban sprawl
must be prevented and the openness of this Green Belt land must be maintained.
BPC oppose all Gateway development south of the A45 and recommend that the Gateway be omitted from
the Preferred Options and excluded from the Local Plan, with any development limited only to that shown to
the north of the A45, which is within the boundary of Coventry City Council, utilising Ansty, Ryton and other
existing suitable sites for any economic development over and above the 23 hectares already allowed for
within the Preferred Options and emerging Local Plan. Housing policy should follow our recommendations in
Appendix 6 herein.
Please confirm you will consider all the above and confirm you will omit all aspects of the damaging and
unsustainable Gateway development from the emerging Local Plan, within the boundary of WDC.

Please refer to the following as my OBJECTIONS to the Specific Section of the Preferred Options Booklet
Part of the document which I am responding to: - PO4 Location 11
Heading: - Woodside Farm, Tachbrook Road.
I OBJECT FOR THE FOLLOWING REASONS:-
The way that WDC have presented the Preferred Options Plan is designed to persuade the public from easily objecting.
We are only permitted to object to small segments of the plan depending on our own (sometimes selfish) reasons.
If we object to the WHOLE plan based on the gross number of housing in the very vague guestimate then we are faced with submitting a raft of objections.
Clearly WDC have got this all wrong. As members of the whole community affected by the proposals we have an interest in every aspect and area of the plan and not just the parochial issues.
This looks like a repeat of the WDC method of limiting the objections to their intentions, which is aimed at allowing individuals to vote for the things they dislike the least.
The truth is I object to the whole of the plan because it has not been thought through intelligently. Some individual/s have made wild predictions based on unfound evidence. They have then used this to make it appear as realistic requirements.
Only time will tell us of the needs for housing in future years. It is not good enough to make these wild predictions then turn them into a developers dream.
We need a flexible plan that allows small numbers of houses to be built as and when they are required, and not mass housing schemes that rip out the heart of communities.
These plans are totally unrealistic and would have serious consequences if they are allowed to proceed.
They will not provide employment. Rather, they will take employment away as developers bring in their own lablur force.
They will put demands on our schools, doctors and hospitals that are already overstretched.
I am now talking of the proposals as a whole so would like this to be a general objection that should be seen by all visitors to the WDC website and not just a specific area.
We do not wish to see masses of houses built largely as investments for rich people who wish to rent.
Changes to Plan:
Scrap the plan to construct mass housing and only allow small developments by local builders.
To support this we have an army of local builders who are engaged in providing a service to house owners in extending rather than new build. There is a good reason for this in that they cannot afford a new larger houses.
These local builders can fill any requirements for the number of new homes that will be truly required.

I wrote to the Development Officer earlier, 14 July 2012. In the meantime I have consulted with others and as a result of this have additional concerns which I wish to draw to your attention. Please see letter in pdf format as an attachment which refers.

At the Parish Council Meeting held in Old Milverton Church on Monday 16 July it became apparent that the Preferred Options Plans, nominally open for consultation and discussion were nothing of the sort. The strong impression given in the presentation was that in the minds of the presenters, the 'only option' open is the one presented, even though the key argument for what constituted the justification for the Green Belt Land Grab was not made. Insult has been added to injury in freely admitting that the 2009 consultation, presumably based on sound 'Planning Criteria' is replaced by the 2012 consultation which clearly is not. The principle of 'Equalising the Misery' is scarcely a sound basis for planning.

This meeting has prompted me to make further comment, particularly when at the end of the meeting the Chairman Jonathan Lander encouraged those attending to make written submissions to WDC and copy their MPs if they felt there was merit in this course of action.

This was made the more poignant when Michael Doody immediately stood up and stated it was in no one's interest to copy the MPs, as there was a risk of repercussions and Local Government loosing control of planning decisions. He elaborated on this theme but found no support for his assertions.

Bill Hunt (Deputy CEO Warwick District Council) gave the WDC presentation at the Church meeting and also present were :

Councillors J.M.Lander (in the Chair), Mrs.A.Kelsey, J.McDonagh, L.J.Sant-Cassia and M.A.L.Tansey; County and District Councillor M.Doody; District Councillors J.S.Hammon and N.Pratt; and Mr. Bill Hunt, Deputy Chief Executive of Warwick District Council; together with some 150 members of the public, including Councillors Margaret Cashmore, David Cox and Peter Delow of Cubbington Parish Council.

There is also the matter of the WDC website, where 'contributors' are encouraged to force their submissions into 'boxes'. This looses the personal touch and is in danger of a total loss of context; the practise is certainly inhibitive. There is no satisfactory substitute for free form written letters ! To give an example of the anger and frustration this sort of thing can cause I refer you to the decision to ask for questions to be submitted in writing at Trinity School 'consultation' meeting, failing to address those questions at the meeting and providing only a summary of responses to 'subject areas raised' did not endear WDC to those taking the trouble to attend the meeting and try put a stop to this apparently politically motivated charade.

The handling of the change of plans to the newly 'Preferred Options' is certainly not in the public interest; and all those I have spoken to, have been greatly irritated by this lack of courtesy and consideration. A significant lack of trust certainly appears to have been generated.

This poses the question When and How do WDC propose to make available copy of letters of comment, objection and support in order to assure the public that letters/submissions are being properly addressed and the content properly taken into consideration; and enable interested parties to see the nature of submissions just as WDC do routinely for the more private and delicate subject of Planning Applications. I should be grateful for your written reply.

Letter detail

When I came to Old Milverton 35 years ago, L.Spa enjoyed an enviable reputation as a
Shopping Centre and was recognised as having a thriving 'community spirit'. Latterly,
much of this has been lost. Independent retailers appear to have lost confidence in
trading in the town. In places empty shops and offices show a town in decline.
By implementing the plans now proposed, the two plots of sequestered Green Belt land in
the Parishes of Blackdown and Old Milverton are set to become 'housing in isolation',
which will result in a 'Dormitory Development'; some say a 'ghetto'. The outcome can only
be a feeling of isolation and a huge increase in unnecessary commuting across L.Spa,
adding to the existing congestion at well known bottlenecks which so far WDC have found
impossible to resolve.
This is particularly pertinent as there is no detail admitted of the proposed infrastructure
intended to service this development. It might not even materialise - for example, if the
sale of the housing proposed founders; a not unlikely outcome in view of the land value
and expected high market value of the new housing in this area. If on the contrary, a
major and inspired infrastructure component is built in and it is successful, it can only be to
the detriment of L.Spa town Centre as shops, offices, services and places of work are
dispersed away from the Town Centre.
By developing a transport hub based on the Railway Station and the commercial/
recreation and services already in place to the south of the town; and locating new
housing development as laid out in the 2009 plan south of the town, it may still be possible
to retrieve much of what has been lost. To develop at Old Milverton & Blackdown can only
have the reverse effect. Our political representation appears to have completely lost sight
of this important consideration.
Why has it not been possible for Warwick District Council to take a grip and reverse the
deterioration experienced in Leamington Spa and exploit the many assets and advantages
associated with the existing infrastructure, services and trading opportunities south of the
town. Significantly, in the first instance, build Affordable Housing where they are needed,
upgrading the empty/derelict buildings and return the many houses originally built for
families to live in but no longer in family occupation.
In summary, It seems the social and cultural life of L.Spa is about to be finally
ripped out of the town and be dispersed into isolated units on the northern
periphery. WDC should be regenerating L.Spa by concentrating its development
from the town centre to the south and not fragmenting it by developing to the north
of the town. What a prospect for legacy !
At the Parish Council Meeting held in Old Milverton Church on Monday 16 July it became
apparent that the Preferred Options Plans, nominally open for consultation and discussion
were nothing of the sort. The new plans have been presented as the 'only option' even
though the key component of what constituted, 'Very Special Circumstances' for the
justification of the Green Belt Grab, was not made. It was agreed even by the DCEO that
the plans lack this very necessary robust argument.
Robert Solt demonstrated further weaknesses in the case for the Preferred Options Plans
by explaining that the numbers did not add up, on several counts. Mainly that the model
used was outdated and most of all, the input data was flawed being based on earlier
projections which are no longer valid, resulting in a very considerable overestimate of
housing need. No allowance appeared to have been made for the recent changes in the
nature of the local work force from manual to blue and white collar and a very significant
increase in numbers of professionals and academics.
It follows that a contemporary detailed audit is outstanding and is required to quantify
housing need, specifically to include the changes outlined above. An audit of similar rigor
is required to establish the total availability of development options to include all sites
Whitefield, Brownfield and Windfall (for which a particularly rigorous assessment is
needed and with inducements offered up to encourage this process). An explanation for
the 'apparent loss' of development sites since the previous assessment (see 2009 plans)
would not go amiss.
Missing from the report is a statement covering the impact of changes which must be
taken far more seriously such as the austerity measures and other significant events in
process, including the fate of the Euro and our EU member States and our Trading Status
as a nation committed to the practice of a disproportionately large scale Food Importation
Policy. Food Security has simply not been considered. In large conurbations this could
become the single most important consideration for Local Government.
If Climate Change and an increasing demand for western living standards are to be
aggressively pursued by Indians Chinese and Africans etc., we have the makings of 'the
perfect storm' in the ability of these countries to feed their own people, let alone export.
The UK is one of the more densely populated countries, at least in the EU and perhaps the
one at greatest risk from global food shortages. A consideration not to be taken lightly
when seeking to destroy Green Belt and good quality Agricultural Land.

See Attachments

On behalf of Barwood Strategic Land LLP and the landowners we write in support of their
respective interests at land 'south of Gallows Hill/ west of Europa Way, Warwick'. This site is
identified in the Local Plan Preferred Options as a location for growth delivering 1,600 dwellings
in phases 2 and 3 of the plan period along with employment land, open space and community
facilities.
Land interests within the proposed allocation are also held by William Davies and Hallam Land;
it is intended that all developers and landowners will work together to secure a comprehensive
masterplanning approach to the development of this site.
We respond to the respective policy areas and chapters below:
1. Part 1: Setting the Scene and Summary
- In setting the strategy, it should be made clear the time period that the plan is proposed
to cover. For example, at 1.2, there is reference to the next 15 years and only later in
the document is confirmed that that the plan period covers 2011 to 2029.
- It is noted that paragraph 4.2 makes reference to the fact that the District could grow by
as much as 15% over the next 15 years (from a current population of 138,800) - this
represents an increase of some 20,820 residents. We highlight that the 2008 based
household projections shows growth from 62,938 households in 2011 to 77,955
households in 2029. This represents an increase of 15,557 households. The 2006
based projections showed 17,110 households over the same period. The 2010 based
population projections show very similar population growth to the 2008 based projections
and although the latter remain the most up to date, it is expected that the 2010 based
CLG household projections will be very similar.
- Paragraph 4.10 should be revised to make reference to the need to ensure that Local
Plan meets the full, objectively assessed needs for market and affordable housing as
required by the NPPF.
2. Delivering Growth - Housing / PO1: Preferred Level of Growth
- The preferred level of housing growth is proposed to be 600 dwellings per annum
(totalling 10,800 dwellings) over the plan period, which when deducting commitments,
small SHLAA sites and windfalls results in a need to identify and allocate land for 6,986
dwellings. The Council have disregarded Option 2 (employment led growth and 700
dwellings per annum) seemingly solely on the basis that there is a lack of certainty that a
sufficient number of homes on strategic sites could be delivered within the plan period.
Using the Council's own calculations, delivering 700 dwellings per annum would result in
the need for an additional 1,800 dwellings to be found on allocated sites. Part of the
justification relates to the perceived lead in times for the delivery of the larger sites;
however the Council's own phasing programme is a self-fulfilling prophecy in this regard.
Phasing the larger allocations in Phases 2 and 3 (i.e. post 2019) could result in a
significant number of dwellings coming to the market at the same time and making it
difficult to therefore deliver an additional 1,800 dwellings in full within the plan period.
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We would suggest that the Council allows the market and the development industry to
regulate itself in respect of the phasing and the timing of the delivery of development.
To allow the larger allocations to make a start earlier in the plan period will ensure
steady delivery of housing over the life of the plan. It is not in a developer's own interest
to saturate the market however steady delivery on a number of sites over a number of
years will promote healthy competition and ensure sufficient time to allow such sites to
be built out in full. Furthermore, in doing this, there would exist the opportunity to
allocate land for the 'missing' 1,800 dwellings which would make a bigger step towards
meeting the Council's housing need.
- In addition, we highlight that the NPPF makes reference to development which is
sustainable going ahead without delay. It follows that in order for a site to have secured
an allocation in what will be an adopted Local Plan, that site must be sustainable and
therefore in accordance with the NPPF, there is no need for that site to be held back by
an arbitrary phasing policy.
- The Localism Act enshrines a Duty to Cooperate on Local Authorities when preparing
plans. In the event that Warwick District does not meet its own housing need in full, we
see no evidence of adjoining LPA's being prepared to take on and meet that need. The
District is bounded by the following LPA's:
- Stratford District: Latest draft Core Strategy did not propose to accommodate sufficient
growth to meet its own needs. No proposals to meet unmet need from Warwick District.
- Coventry: Latest draft Local Plan does not propose to accommodate sufficient growth to
meet its own needs. No proposals to meet unmet need from Warwick District.
- Rugby Borough: Adopted Core Strategy does not include any proposals to accommodate
unmet need from Warwick District.
- It is not therefore clear the way in which the Duty to Cooperate has been carried forward
or the way in which the District's housing need will be met in full, particularly given that
the household increase is projected to be closer to 15,557 households rather than the
10,800 households currently being planned for.
- Further justification for using lower housing targets is provided in paragraph 5.22 where
it is stated that using Option 2 would meet the projected change in employment between
2011 and 2031 as identified in the West Midlands Integrated Policy Model. However the
Council consider this to now be optimistic as it was carried out in 2010 and forecast an
increase in employment growth from 2011. We highlight however that throughout the
NPPF there is reference to the need to 'plan positively' and the need to stimulate and
secure economic growth. It would appear that the Council are revising their growth for
the period to 2029 (i.e. the long term) because short term growth has failed to
materialise. This cannot be said to be planning positively or assisting in securing
economic growth.
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3. PO3: Location of Growth
- The components of growth are reviewed below:
- Committed Housing Sites (1,224 dwellings): whilst clearly committed sites, we question
whether it is appropriate to include all of these sites and not include any allowance for
non-implementation. A 10% non-implementation rate is the industry 'norm' which we
consider should be applied here, thus reducing the commitments to 1,102 dwellings.
- Small Urban SHLAA sites (290): We seek clarification as to where these sites fall within
Table 7.2 of the Draft Local Plan (DLP).
- Other Windfall Housing Sites (2,300): Paragraph 7.25 of the DLP confirms that the
Council consider there to be a limited supply of land within the existing built up areas of
the towns. Windfalls can be included if the Council can demonstrate that such sites have
consistently become available in the local area and will continue to form a reliable source
of supply having regard to the SHLAA. The Council's SHLAA methodology confirms that
a minimum site size of 5 dwellings was used and that Officer's did not rely solely on sites
which supplied to them by developers or landowners but also conducted their own
research including reviewing areas currently in non residential use and looking at small
scale developments such as change of use of existing buildings. It would therefore
appear that the Council have had every opportunity to identify suitable residential sites
and include them in the SHLAA. With the removal of rear garden land from the definition
of previously developed land, we consider that the scope for new windfall development is
much reduced and that windfalls will no longer continue to make up a significant element
of future supply. Furthermore, under the banner of the NPPF and the requirement to
plan positively, windfalls should be seen as a 'bonus' rather than forming approximately
20% of the overall supply.
Land South of Gallows Hill
- The distribution of housing growth across the District is supported with particular
reference to Land South of Gallows Hill. It is noted that within the Council's Landscape
Character Assessment (February 2009), it is concluded that the study area is not suitable
and the rural character should be safeguarded from development. It is however clear
that this study has considered landscape character in isolation and this study should be
considered 'in the round' as is only one part of the evidence base underpinning the Local
Plan. The NPPF is clear that economic growth is a priority and that economic, social and
environmental factors have to be balanced against each other.
- The developers of this site will be commissioning technical and environmental work to
underpin the draft allocations; this will include detailed landscape and visual work to
demonstrate ways in which the site can be developed without adverse landscape impact.
- Whilst the developers will be working together to ensure a comprehensive approach to
the delivery of the site, we consider it important to recognise that within this should exist
the flexibility to ensure that each developer can bring parts of the site forward at their
own pace within an overall masterplanned approach. The delivery of large sites is often
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hampered by requirements to submit a single planning application which can cause
significant delays and is often to the detriment of the site itself.
4. PO5: Affordable Housing
- Whilst we do not object to the provision of affordable housing in principle, we do not see
any up to date evidence of the way in which the appropriateness of the target as been
assessed in terms of the financial viability of development in accordance with paragraphs
173 and 174 of the NPPF. Paragraph 7.43 of the DLP makes reference to a November
2011 document and an Addendum dated May 2012. The May 2012 document does not
feature in the Evidence Base on the Council's web-site and therefore we reserve the
right to make further representations in this respect upon publication of this document.
5. PO6: Mixed Communities and a Wide Choice of Housing
- We consider that sufficient flexibility should be included within any policy to ensure that
account is taken of up to date market demand in addition to the SHMA's. The latter can
become obsolete very quickly and clearly, if developers feel there is no demand for a
particular type of property then they will not build it, which can result in stalled sites and
lower rates of housing delivery.
- Lifetime Homes: there is no national policy which requires the provision of Lifetime
Homes and we see no justification which supports 25% provision.
- Homes for Older People: whilst the provision of extra care housing is supported, these
have very site specific criteria with operators having specific requirements in respect of
site location and suitability. A site which is suitable for market housing may not be
suitable for extra care housing and it is important to ensure that this policy is not applied
so rigidly so as to sterilise areas of land or stall sites.
6. PO8: Economy
- It is noted that the Council propose to consider allocating a 'proportion' of the site south
of Gallows Hill for employment. The provision of mixed use development is supported
although clearly further clarification is required on the definition of 'a proportion'.
7. PO10: Built Environment
- The Council's Garden Towns, Suburbs and Villages prospectus is supported.
8. PO12: Climate Change
- We have reviewed the Council's evidence base and do not see any case for the
introduction of a 20% climate change policy. We are also disappointed to see a
continued emphasis on renewable energy provision within new developments (when the
Council themselves acknowledge the disadvantages with some renewable technologies)
as opposed to the emphasis being placed on energy efficiency. If the overall aim is seek
a reduction in carbon emissions, we fail to see why this should be achieved through
renewable energy rather than energy efficiency measures.
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9. PO18: Flooding and Water
- Whilst the policy as a whole is supported it is noted that much of this replicates national
guidance and is therefore superfluous. Furthermore, the requirement that all new
developments include SUDS is unfeasible. There are some instances where SUDS
schemes are not feasible or viable and this should be recognised within the policy.
10. Draft Infrastructure Planning
- Whilst the provision of a draft Infrastructure Plan is supported to assist in providing
certainty to developers when bringing forward new sites, particularly in respect of the
larger strategic sites. We consider that further refinement of this plan may be needed.
For example, within Warwick and Leamington Spa, 6 new primary schools are currently
being considered at the same time as capacity in a number of existing schools is also
identified. It is noted that the NPPF advocates a CIL charging schedule being prepared
in tandem with a Local Plan if possible and we consider this may be appropriate in this
case to assist in determining the total cost of items identified in the Draft Infrastructure
Plan. This is of particular importance when reviewing the Strategic Transport
Assessment Overview Report which identifies a requirement of up to circa £5,000 per
property for transport infrastructure without taking into account any other infrastructure
requirements or planning obligations.

Please read below objections I wish to raise as part of the consultation period concerning the proposed development in old Milverton and Blackdown as detailed in Warwick District Council's 'Preferred Options' for the New Local plan.

a) Amount of new homes proposed:

Whereas I understand the need for the district council to have a plan in place for future growth and development in the warwick and leamington district, I have concerns about the number of new homes proposed in the 'preferred options' plan.

It seems that the plan accounts for nearly 1400 extra homes above the number estimated to be necessary to meet towns population growth.

This over-calculation may be a 'safety net' on behalf of WDC but seems over cautious and would cause more building works, expense, disruption and needless use of land.

In particular, without the extra 1400 homes there would be no need to even contemplate building on presently designated Green Belt land north of Leamington in Old Milverton and Blackdown areas.

I also object to the term and title of 'preferred options' - this makes members of the general public feel that the only options for development open to them 9and WDC) are those shown in the 'preferred options' plan and maps - there are other options not detailed fully although there seem to be other options mentioned briefly in the main report. there were also other areas of non-Green Belt land identified as suitable for development in the WDC's 2009 Core Strategy plan. these non-Green belt areas are still available for development - and even if not in the WDC's final plan, the non- Green Belt areas could still be ear marked for planning consent. The public need to clearly know ALL options and areas available for development.

Change to plan: Remove the extra 'safety net' of nearly 1400 homes from the plan.
Omit designated Green Belt sites from development plan.
Make all options more clear - highlighting ALL areas suitable for development to the public


b) Save our Green Belt land:

Although it is clear that WDC need to plan for housing developments for the future, I strongly object to proposed sites in the 'preferred options' in the areas of Old Milverton and Blackdown, north to and on the edge of the existing boundaries of Leamington Spa which is clearly presently designated Green Belt land. the Green belt areas north of Leamington have been identified by WDC in previous study as areas of high Green Belt value.

The National Planning policy framework (NPPF) identifies the Government's commitment to preserving our country's Green Belt areas. It states that the NPPF aims to protect communities and Green Belt and to help local people 'to protect local countryside and green space they value'. It is the responsibility of WDC to follow the guidelines set out by the NPPF; the 'preferred options' proposals do not do this.

As WDC must be fully aware, the main aims of Green Belt is to prevent urban sprawl by keeping designated areas open and clear from development.

The NPPF lists five purposes of Green Belt land and the Old Milverton and Blackdown Green Belt fits the purposes of at least four, if not all five, of these:
* To prevent unrestricted sprawl of Leamington to the north
* By preventing the merging of the towns of Leamington and Kenilworth; and keeping Old Milverton as a separate village community
* Safegurading the countryside from encroachment
* Preserving the historic and picturesque setting and character of Leamington and Kenilworth amongst scenic, protected countryside
* Helping urban regeneration, by encouraging the recycling of derelict and other urban land (this last bullet point would definitely be better addressed by WDC if the Green Belt is NOT built upon and other 'White land' is used and renovation of empty buildings in town)
If the Green Belt land north of Leamington is developed then it is likely that eventually the towns of Kenilworth and Leamington would meet and emerge; both losing their separate and individual characters.

My objection is valid as there are other sites for development available which are not green Belt land which would fulfil the needs of the planning proposals in regards to numbers of houses needed - these White land areas should all be utilised before development of Green belt land is ever considered. Non- Green Belt sites, many being south of Leamington, were clearly identified by WDC in their '2009 Core Strategy'.

As made clear by the NPPF, development of Green Belt land should only be proposed by a council under 'very special circumstances'. As WDC have already identified other non-Green Belt sites (although not all clearly publicised in this 'Preferred Option' plan) that are suitable for development, WDC do NOT have not given sufficient reasons or detailed 'exceptional circumstances' to validate their proposal to develop Green Belt land. WDC do not provide evidence that shows any superior benefit to the existing community of north Leamington should the Green Belt be developed. Therefore, WDC have not fulfilled the NPPF guidelines.

It is a matter of principle that WDC develops White land and preserves our Green Belt.

Change to plan: WDC to clearly identify ALL White land (non- green Belt) sites suitable for development (as in 2009 Core Strategy)
Development of south Leamington areas that are NOT Green Belt land and are suitable for development
Remove all proposals and suggestions to develop Green Belt land north of Leamington (Old Milverton and Blackdown areas)

c) Use of green Belt land:

The Green Belt land north of leamington in Old Milverton and Blackdown areas provide Leamington and Warwick residents with easy access to the countryside environment.

The Green Belt land is highly valued by local residents and visitors to the area who regularly use the pathways on the Green Belt land for recreational purposes; such as, walking, running, dog walking, bird watching, general relaxation. As a north Leamington resident for many years, i have often enjoyed using this land and strongly object to it being developed and destroyed.

The land is used regularly by many groups of the community of all ages. It is important to the health and well-being of residents, visitors and their dogs who are exercised there. It is a social place where people greet and talk to each other. To develop and destroy such areas would be a catastrophe.

The walks across the Green belt land are well known and well used by locals and visitors. If this land is destroyed then Leamington would lose an attractive asset which must only serve to encourage residents to stay living in the area, and new people to move to it. There is a lack of established open green space as it is - we should not destroy what we have.

Change to plan: Do NOT develop the Green belt land north of Leamington in Old Milverton and Blackdown areas as they are valued areas for recreation
WDC to protect our designated Green Belt land; ensuring provision for recreation on established Green Belt land

d) Conservation:

Linked to the above point, I strongly object to propsals in the 'Preferred options' plan to build on the Green Belt land north of Leamington as it is home to a wealth of wildlife and should therefore continue to be protected.

Development of green belt land would cause distruction of habitats and the environment for an abundance of wildlife and a wide variety of trees, wild flowers and plants. Development of this land would ruin this established natural environment. Even if green areas are left amongst new homes much of the wildlife (such as, bats, newts, herons and foxes) will leave the area because of noise and light pollution, lack of established habitat, dangers of changes in water availability, etc. Reduced Green Belt area will affect the movement of species across the land as they travel from place to place.

WDC is accountable for protecting the environment and habitats within the Green Belt land north of Leamington.

Change to plan: Omit proposals to develop Green belt land north of Leamington from the plan
WDC to protect and conserve Green Belt land as it is for future generations

e) Other available areas for development:

There are areas of land that are not Green belt which WDC has already identified as suitable for development - many sites are south of Leamington Spa as identified in the 2009 core strategy, and some (but not all) seen in plans in the current 'preferred proposals'

I object to proposals to build on green belt land in the old Milverton and Blackdown areas as I strongly feel that areas south of Leamington would be more suitable for development because:
* the areas south of Leamington are NOT Green Belt land
* they already have easy access to main roads and routes (such as, the M40 and A46) - infrastructure links that are capable of taking more traffic and space to develop further if needs be
* SHLAA identified that there is enough land in the south of town to devlop and suit the requirements for growth without having to develop Green belt areas north of the town
* there is a lot of existing employment areas and opportunities south of Leamington (business park, large shops, etc)
* there are large shops and supermarkets in that area which, if development was made north of Leamington, people would travel through town to get to causing lots of congestion - plans for growth in the retail area seem to be south of leamington - there is already a large shopping area south of Leamington which would not need as much development as building a new shopping area north of Leamington. if another out of town shopping area is built then more local and independent retailers within the town centre may suffer; shops close; leaving empty shop premises as an eye sore and so stop residents and visitors from wanting to shop in town or move to live in Leamington.
* developing key areas south of Leamington would reduce the need to spend millions of pounds developing infrastructure (roads, public transport, etc) north of town
* there are already established routes and public transport access south of Leamington which would be more easily revised and developed rather than creating brand new transport systems north of the town - development of the A452 between Leamington and Kenilworth would be costly and cause major disruption; traffic would still try to get through Leamington town centre in order for people to access the shops and amenities south of town.
* there are large open spaces in south area that are suitable for development of housing areas; land which is not Green belt
Although WDC has suggested that land south of Leamington may not be as attractive to developers as they might feel they'd make less profit - i strongly feel that this is an invalid reason to make proposals to build on green belt land because the profit made by developers should NOT be WDC's priority.

Change to plan: Concentrate on developing non- Green belt land south of Leamington and other non- green belt areas
WDC to stick to plans and areas identified in 2009 plan
Remove plans to develop Green Belt land north of Leamington in Old Milverton and Blackdown
WDC to include plans to enhance public transport south of Leamington

f) Affordable housing:

I am aware and agree that the WDC has to provide for the building of some homes that are 'affordable'. However, it is unclear in the documents why exactly WDC have proposed a 40% affordable housing plan. There needs to be consultation with the public about the need for 'affordable' housing.

Change to plan: consult with public in more detail about affordable housing needs.

Please accept the above points and opinions as my valid and firm objection to the proposal to develop the Green belt areas in Old Milverton and Blackdown, north of Leamington Spa; particularly as WDC has not produced sufficient evidence for 'very special circumstances' to develop and so erase those Green Belt sites. The WDC also needs to reconsider the planned numbers of houses and reduce their proposals by the extra nearly 1400 homes that have been added as a 'safety net' in their 'preferred option' plan.

We are writing to object to the proposal for 3,330 new houses in Warwick. In objecting we refer to the National Planning Policy Framework which "aims to strengthen local decision making and reinforce the importance of up-to-date plans".

Population Growth

The NPPF states that there should be a clear strategy "taking account of the needs of the residential and business communities".

Why has the number of 10,800 new homes (up to 25,000 more people) been proposed which is the same number as proposed in the Core Strategy and was strongly resisted by Warwick District Council at that time? The West Midlands Regional Office was vehemently criticised by WDC for producing these flawed and untenable figures. Your figures do not comply with WCC population figures and are therefore unreliable. A 40% increase in Warwick's population over 15 years is clearly unsustainable and will cause immense damage to the character of the County Town. Migration from other areas into Warwick's more attractive green environment has produced most of the population growth. The provision of more houses will encourage more migration and Warwick will no longer be an attractive area. The new Plan should cater for LOCAL needs not migration into the area. You have included figures to cover an increase in students but they should be housed near the Universities not in the District, especially in south Leamington. Increasingly high concentrations of students in certain areas is an issue of concern.

Regarding your assumptions on the demand for housing, given that more than 50% of national population growth has been from immigration over the last two decades, and the government has publicly stated it wishes to greatly reduce this future net immigration, why is Warwick District planning for an even greater level of growth over the next 15 years, than has been experienced in the recent past? Warwick District population has increased by 12% since 2000, which is approximately twice the rate of increase for Warwickshire, twice the national average increase, and over three times the increase for West Midlands. Warwick has had its fair share of development over the years with major estates at Warwick Gates and Chase Meadow (with further development allocated), Hatton Park, along the Myton Road and many other infillings. This is far greater than other areas in the District and history has shown that the necessary infrastructure has never been put in place. The NPPF (48) states that Local planning authorities may make an allowance for windfall sites in the five-year supply". 1,224 properties have planning permission or a planning brief at the moment and yet you do not appear to have taken these into consideration. This would equate to a two-year supply of houses. We do not believe our authority has identified and brought back into residential use the 300-400 empty houses and buildings (NPPF 51) to the extent they should have done.

We believe that the only motivation for WDC producing such figures for demand is the income that will benefit WDC in New Homes Bonus, rent, rates, council tax monies etc.

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? The Ford Foundry site is a prime example of revitalising an eyesore of a brownfield site to vastly improve the area and bring it back into good use. There are many more examples of brownfield sites in Warwick District which could be regenerated.

Gypsy Site

We suggest the land adjacent to Junction 15 of the M40 might be a suitable site. There is little nearby existing housing, but a public bus service and good road access

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."

An incredible 37% of the 11,000 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 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 your reason for allocating development on Green Belt is that "there is nowhere else to build" (your quote at the Warwick Society Meeting).

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.." The exceptions given in NPPF 89 and 90 do not apply in your proposed Local Plan. Our Green Space is already designated.and 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. Why are we facing urban sprawl rather than the housing being spread equitably around the District as you stated was your aim? The previous Core Strategy stated that 90% of the population live in the urban areas and 10% in rural areas. Yet in the new Plan 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 would propose that at least another 1,000 could be spread around the villages and the number proposed for Warwick reduced.

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 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 agricultural land, essential for food self-sufficiency, environmentally precious landscape with many wildlife habitats and biodiversity including badger setts and also prevents coalescence which you declare is one of your aims. Our existing green space provides open space, sports and recreation and such land, including playing fields, should not be built on!

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 Milverton and 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.

Yet your reason for allocating development on Green Belt, against the National Planning Policy Framework is that "there is nowhere else to build". This argument is totally flawed and I would expect the Inspector to find this Plan unsound if only on this issue.

The NPPF (17) states that planning should be "empowering local people to shape their surroundings."

Why has this amount of housing been proposed for South Warwick when the previous consultation on the Core Strategy produced a 97% response in overwhelming opposition to housing here (700 objecting to the Europa Way, Gallows Hill and Banbury Road area.. Why were those results not heeded when you devised the new Plan? These plans do not reflect the aspirations of the community as the Government intended in the Localisation Act.

 
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 but you are proposing 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) You have not carried out a Strategic Flood Risk Assessment before allocating these sites for housing.

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. This 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 problem will possibly increase next year when the agreement between the Government and the Insurance Association ends. The Portobello development, built on a flood plain, is a prime example where many of the apartments are still unsold. 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. 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.

Why are we allocating housing for the Coventry Gateway project? It should be up to Coventry Council to provide for this. They should also 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.

Infrastructure

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 shown 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 (particularly Myton which is the catchment area), the hospital is at breaking point and cannot cope with the load, having day surgeries and evening clinics 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.

CIL

The NPPF (175) states "Where practical, Community Infrastructure Levy charges should be worked up and tested alongside the Local Plan. The Community Infrastructure Levy should support and incentivise new development, particularly by placing control over a meaningful proportion of the funds raised with the neighbourhoods where development takes place."

You have not provided information on these charges at all. We do not believe that there will be anywhere near the amount of funding available from CIL to cover the above extra infrastructure needs, especially new roads, bridges, schools and hospital.

 
Air Quality/Traffic

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."

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 10,800 new homes, 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 County Council admitted that air quality will suffer as carbon emissions will increase in surburban sprawl. 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 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 and Europa Way 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.

Historic Environment

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. 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. 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).

Conclusion

You state that in 2026 Warwick District will be renowned for being "A mix of historic towns and villages set within an attractive rural landscape of open farmland and parklands that have developed and grown in a way which has protected their individual characteristics and identities....." In our opinion this could not be farther from the truth.

The above comments demonstrate that this Plan is seriously flawed. It is not specific to the needs or the character of this area and the necessary infrastructure is not deliverable. We believe the Planning Inspector will declare it unsound. It cannot be justified as "the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence" and it is not "Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework." (NPPF 182)

This Plan should be completely revised taking account of the above, specifically reducing the numbers of housing proposed for Warwick.

I look forward to your response to the comments contained in this letter.

INTRODUCTION
As Mayor of Warwick, I am supposed to be apolitical during my year of office; however, I am assured by the Town Clerk that I am entitled to submit my objections, on behalf of the people of Warwick.
AIR QUALITY
I think the people of Warwick worry about the air quality in its town centre. There are laws about Air Quality in town centres. I have already been on the Environmental Health dept to enquire whether the fumes in High St/Jury St are lessening because of the traffic calming and I am assured that it is too early to monitor yet. Therefore, these plans are unacceptable to put an extra 27% of traffic on to our crowded streets.
OUR OBJECTIONS DISMISSED
The dismissal by WDC of all the multiple objections which were submitted when the recent Core Strategy was in public consultation was a poorly judged decision. All areas of Warwick District are dismayed at this and having to re-submit our objections.
FUTURE GROWTH FORECAST
Your population numbers are flawed and are, therefore, incorrect. Your numbers are highly inflated at 40,000, whereas in reality it is forecast at only 13,000 in Warwick Observatory's research.
INFRASTRUCTURE
Warwick residents feel you are forcing this huge number of future dwellings on our fragile infrastructure. There has already been massive development in Warwick. When the 1994 plans for Chase Meadow were passed it was for 1,100 dwellings but 1,600 are built or have planning permission passed for them. £1M Section 106 money was set aside for traffic calming in Warwick Town Centre from this development. Ditto when Warwick Gates was on the drawing board I questioned a Severn-Trent Water official at a presentation as to whether Warwick's Sewage Works and pumping station could cope with so many more people in these houses, using dishwashers, baths, showers and washing machines. I was assured there was sufficient capacity in both the sewage works and the water pumping station. So Warwick Gates was built. Immediately, it became apparent the water pumping was inadequate and an extra pump unit had to be built. Likewise with electricity National Grid have inadequate powers supplies and a new sub-station had to be built. These two plants were built AFTER Warwick Gates was built. Therefore I argue your infrastructure plan is flawed because infrastructure must be BUILT IN ADVANCE.
There are plans for both a Primary School and Secondary School in or near Warwick Gates. Neither have been built so where are they?
Electricity
We have the news casting this week of India's infrastructure failure this week with 6M people without electricity due to power failure. This is because of the increasingly wealthy middle-class in India demanding air-conditioning which has defeated the ancient power plants. A similar problem will occur in the 2020s in the UK unless more power stations are designed, built and come into use. This is relevant to Warwick District with its pylons and sub-stations.
Rural
Villages to the west of Warwick have marvellous infrastructure with a main rail line (Chiltern Line) to get to and fro work in big cities. Warwick Parkway station car park increases in size every 2 years and is full every weekday. The demand for quick access to major centres of population, Birmingham & London is unquenchable. Why cannot these 10,800 houses be built 100 in each and every village in Warwickshire? Then the shop, school and bus service would be viable.
TRAFFIC
No way can Warwick's fragile infrastructure of roads and bridges cope with 27% more traffic as is forecast in your plan.
I was instrumental in stopping a new traffic scheme in Warwick Town Centre in 2004 when we defeated the then Labour WCC's plans on 8/11/2004 with the promise of a new bus station (built on time and under budget), a cycle track to the Tech Park and VMS. The Traffic Forum (£30,000 set aside for it - about £10,000 spent to date) rumbles on with constant consultation and causes irritation to the commercial section, who sometimes refuse to get involved, then grumble (as they are now) with the remedial work being done on High St/Jury St. Warwick's narrow streets (some under 7.6 metres the national standard for a two-way road) and complicated junctions which cannot cope with 27% more traffic.
One hot day in June, when the bricked humps were being built, Warwick ground to a halt for 7 hours, because of a car/truck accident when a driver pulled out of Westgate car park - didn't realise it was a one-way road (as most are in the town centre) and a truck had right of way and the car driver piled into it. It took that long for a tow truck/emergency services to arrive. Children arrived at school 2 hours late with wet knickers/shorts, medical staff arrived hours late to run clinics, appointments for out-patients and impatient people arriving at WCC (whom I witnessed) really angry with the traffic hold up. The town literally ground to a halt. One shop only sold 6 postcards. With the extra 27% of traffic you forecast Warwick will become moribund with no commercial activity.
BRIDGES
The Earl of Warwick built the bridge across the Avon in 1797 and WCC renewed its pavement, the utility supplies which are trunked under the pavements in July 1998. It is a wide (yes widened) two way bridge with two narrow York stone pavements. It is widely used by tourists to photo Warwick Castle. Tourists try to cross on the apex of the bridge. A man in a TR3 killed a pedestrian doing that in the 1980s. The car was low and the tourist didn't see it.
BRIDGES/JUNCTIONS/SAINSBURYS
Every day (except Xmas Day and Easter Day though I have noticed that law being infringed in the last three years) there are 6 HGV movements delivering goods to Sainsbury's on Saltisford. Planning permission was passed for that store before the 7.5 tonne bylaw came in. The rail bridge being 13 ft 5 in (what is that in metres?) precludes the HGV truck coming off the by-pass and entering Birmingham Rd direct into the loading bay of Sainsbury's.
So the route has to be from the Hams Hall depot, A46 by-pass, exit Warwick Stanks Island, over a flattened Canal bridge, left at Lone Tree Island, right into Upper Cape, over another Canal bridge, up a congested Cape Road, over some speed humps (narrow ones) over a narrow 19C rail bridge with very narrow pavements, around Northgate, around another island down North Rock, around another roundabout and into the loading bay. 20 minutes later it returns via the same route in reverse.
I have investigated the cost of heightening the offending bridge (£5M) or lowering the land under the bridge which would have the effect of heightening the bridge. That is impossible because of a culverted stream. With the projection of flooding and this summer's monsoon it impossible to widen and deepen that culvert because water does not flow uphill.
The actual gate at Northgate vanished in the 14C because of "press of traffic" (according to the archives) and there are no drawings of it. Therefore, the foot, horse, animal traffic of those days made it a complicated junction at the top of hill for the past 8 centuries. The HGVs, on occasion, demolish the 1698 sundial and it is replaced by their insurance.
This is just one instance of the congestion of Warwick, already, with its weak links which are the bridges. It only needs one of these to fail, Network Rail to replace a bridge or the new Canal charity is perhaps unable to replace a canal bridge and there are no supplies at Sainsbury's Saltiford.
HEALTH FACILITIES
Warwick Hospital is built on the former 19C workhouse site and is totally inadequate for the needs of the four towns in Warwick District and the rural population. It is so busy. This is the 21stC and most out of Warwick visitors, out-patients, staff, cleaners etc drive. The parking is totally inadequate. I deal with angry residents who resent shift workers parking on their residential streets. Now the Rehabilitation Hospital is going to charge for parking so the same thing will happen in Warwick South.
I spent March to June 2011 visiting my dieing husband in Warwick Hospital. The care and attention he received was magnificent, however, I had time to observe the staff, which are overworked, overstressed and thanks to Harold Shipman light on the morphine, prolonging the deaths of the elderly. My husband had prostate cancer in the skeleton and there was no hope of recovery. With an increasingly elderly population this problem is going to get worst (it is masqueraded as "bed blocking") and it going to escalate in this litigious society.
There are no signs when exiting Lakin Rd car park to Warwick Town Centre (right) and M40 M42 Birmingham and the North (left). I am actively trying to get this sign put in place. Drivers are stressed visiting a hospital for a blood test, an X-ray, visiting the sick, collecting samples, prescriptions etc. When the driver has fathomed out how to exit the car park then the thought comes: Did I drive left or right into this car park? There are no signs at all. Mr Glen Burley (NHS head of the hospital) says it would cost WCC £5000 to put up suitable signs.
The answer is to demolish some of the 19C streets around and rebuild the 19C part of the hospital with a multi-storey car park for staff. Plans have been passed for another private hospital on Tournament Fields, but due to the Banking crisis no funds are forthcoming to build it. Along with the Nuffield Hospital (who has had an MRI scanner delivered this week) this would have relieved the pressure on Warwick Hospital out-patients dept. The initiative by WDC, Pete Cuts and St John's Ambulance Service to curtail the visits by the drunks bleeding from "Payday" incidents in Leamington's pubs has helped tremendously.
CONCLUSION
No way can these plans be accepted. There are far too many in your forecast of future population for Warwick and its fragile infrastructure will break down. Your population forecasts are incorrect. There must be no pressure to build on farmland food is needed, only brown field sites are acceptable. 4 1-bed apartments are to be built on Vine Lane, the Vine pub will be converted into 2 flats, why cannot these (only 6) dwellings be counted within the number required for the future? The residents of Woodloes are angry about the 180 houses along by the Saxon Mill, North Leamington is angry about the proposal to build in their green belt to the north of the allotments.
Ford Foundry site has Morrison's supermarket going up with a large truck and car park. The rest of that huge brownfield site should be housing, some 2/300 could be built there. Behind Leamington Spa rail station there is a temporary car park, another 80 could be accommodated there. Down Cape Rd, Warwick, planning permission could be rescinded on the Benford site for another 25 (P/P was refused) so that would be another 400 off the total. I'm sure other Cllrs could think of other brownfield sites which could be made available.
Finally, Warwick suffers from empty buildings (mostly owned by WCC) 2-22 Northgate St is currently for sale for £3M. Why does not a developer not refurbish those huge houses into two dwellings each, making 20 more. Riverside House would convert into magnificent duplexes.
Warwick's fragile infrastructure will break down if you approve this plan, please do not.

Dear Sirs,
Please find below my views regarding the Consultation for the New Local Plan. I am
submitting this as a letter because the consultation web site appears unreliable and also
does not appear to allow me (as requested by the Council) to make alternative proposals. It
only appears to allow me to make comments on particular sites.
SUMMARY
I am totally opposed to the plans to allow development on the Green Belt to the North of
Leamington Spa and the complete change in direction since the 2009 Core Strategy
document. There is no evidence or requirement to change any of these North Leamington
Green Belt Boundaries.
In particular I oppose the proposed developments to the Milverton Gardens (North of
Milvertion) and Blackdown. Your references are I believe are L03 and L07 together with L48.
L07, and L03 in particular, must be among the highest public amenity value of any rural
space in Warwickshire providing very highly used public footpaths from two access points
directly onto open country side.
The Green Belt has been vital in maintaining the identity of the Warwickshire towns for
many years and Government policy under NPPF is very clear regarding the importance of
preserving Green Belt.
The Council have not demonstrated the required very special circumstances to build on the
Green Belt to the North of Leamington. It is therefore unacceptable to change the Green
Belt boundaries to the North of Leamington.
Plans for a major new relief road, to alleviate the traffic caused as a consequence of the
proposed new housing, only causes further loss of Green Belt and is unjustified.
Housing should be provided, as the previous 2009 Core Strategy document, to the South of
Leamington Spa where the employment and infrastructure exists and where there are not
the issues of coalescence.
The evidence base is not sufficient for the preferred plan to be derived from it. It fails to
provide balanced investigations of the considered sites. It is clear that it must have been
used to attempt to justify a politically motivated plan to 'share the pain'. Further evidence
of this has been provided from Council responses to enquiries with statements that the plan
has in fact arisen as a result of lobbying pressure from South Leamington.
Other such statements have indicated that the reasoning behind the proposed housing to
the North of Leamington Spa also relate to assumptions about employment arising from
around Coventry airport. This would be inappropriate because housing should be provided
close to the employment in Coventry providing a more sustainable future with shorter
commuting. Furthermore the Council should be planning to invest for employment in
Leamington Spa rather than making Leamington a commuter area for Coventry. If this was
part of the reasoning for the plans, then this should have been made clear in the
consultation documents for people to comment upon. If on the other hand employment
arising from Coventry airport was not part of the reasoning behind the proposed housing to
the North of Leamington Spa, then the Council should not be using it as a justification in
responding to consultation questions.
On a positive note the proposals to enhance the quality of the proposed new housing
developments (along the lines of garden towns) is positive and would be an asset to, and
raise the housing diversity in, South Leamington Spa.
EVIDENCE BASE
The Council Preferred Options plan are not, as we would be lead to believe in the Forums,
developed from an evidence base. On inspection there are significant omissions in the
evidence base and significant conclusions are included in the plans which are not supported
by the evidence base. The only conclusion I can make is that the evidence base was
developed in retrospect to try and support a political plan to 'share the pain' or 'spread it
about'.
Not only does the evidence demonstrate this lack of consistency in approach, the anecdotal
comments from some Councillors, as well as presentations by officers, have demonstrated
the back to front approach to developing the plans.
When pressed for an explanation regarding the errors in the statistical analysis of the
population growth, Councilors have made the statement that the council settled on the
required number of houses "as what was considered we could get away with".
There is over-provision of housing resulting from the Council making projections from past
population data which includes a period of exceptional growth. Calculations of future
population should have more accurately taken account of the reducing trend in population
growth, rather than having an unlikely high projected population as a result the past, short
period, of abnormal high growth. If the calculations and projections exclude the period of
abnormal growth then the housing on the Green Belt is not needed.
The Council has stated in forums that the infrastructure to the South of Leamington Spa has
been investigated and found not to support the required number of houses. However they
also state that their infrastructure plans to the North are not yet completed. Request for
details of the traffic surveys established that they have not in fact been carried out. This is
further evidence that the infrastructure investigation is being used to justify the plan rather
than being the basis for it.
The Council have concluded that more houses in the South of Leamington Spa than is
allocated in the plan cannot be delivered. This is not evidenced anywhere. When challenged
in Forums, the Council stated that the Developers with whom local residents have consulted
(to confirm that the Council assumptions are incorrect) cannot be trusted 'because they
have a vested interest'. Can it be that the Council have therefore only consulted with
Developers / Landowners of the Green belt to the North? Clearly these parties would have a
far greater vested interest to have the Green Belt boundary redrawn!
What appears more likely is that the Council have simply made an assumption on
deliverability rather than carry out a proper investigation. It would appear that the Council
have lost track of the phased nature of the delivery requirements when considering the
deliverability argument.
The conclusion that the area to the South of Leamington Spa cannot accommodate more
homes and therefore there is no option but to put the houses on Green Belt is not
evidenced and is incorrect.
GREEN BELT
The reasoning behind relocating the development from South to North of Leamington is the
result of previous objections from South Leamington with no account taken of the
underlying planning advantages which exist. It is a purely political move.
The Local Plan is governed by the National Planning Policy Framework (NPPF) which clearly
states that Local Plans must accord with its principles. The value of Greenbelt is set out in
the NPPF to prevent urban sprawl by keeping land permanently open. Green belt land
should not be developed when other suitable land is available for development.
The National Planning Policy Framework (NPPF) sets out five purposes for Greenbelt land. In
summary these are, to prevent urban sprawl of built up areas, to prevent neighbouring
towns merging, to protect the country side from encroachment, to preserve the setting and
special character of historic towns and to assist urban regeneration by encouraging the
recycling of urban land. The Greenbelt land identified for development in the Preferred
Option does fulfill the majority of these purposes and its development would therefore be
contrary to the NPPF.
The NPPF requires there to be "very special circumstances" for development in the Green
Belt. It also requires the harm caused to the Green Belt by the development to be
outweighed by the benefit of the development. According to Warwick District Council the
very special circumstances are that there is nowhere else for the homes to be built. This is
demonstrably untrue.
The Council identified available land east of the A452 (Europa Way) and south of Heathcote
towards Bishops Tachbrook however these sites have not been included in the Preferred
Options sites. Presumably, this is because of the policy of 'spreading it around'. That is not a
planning policy, it's a political policy.
The proposals ignore Warwick District Council's study of the Green Belt land at Old
Milverton and Blackdown, which concluded that these areas have high Green Belt value.
The proposals will reduce the "Green Lung" between Leamington and Kenilworth to less
than 1 1/2 miles.
Planning policy dictates that Green Belt must be valued more highly than Green Wedges.
Therefore the Preferred options are flawed as the opposite has in fact been planned.
NO EVIDENCE OF ANY VERY SPECIAL CIRCUMSTANCES FOR DEVELOPMENT ON
GREEN BELT
No "very special circumstances" have been proven for the use of Green Belt land.
The Council's own previous plan the "2009 Core Strategy" accommodated significantly more
houses and identified suitable sites without using Green Belt. The land south of Leamington
Spa (not in Green Belt), was identified and is still available, for development.
The assessment performed by Warwick District Council shows that this land to the south of
Leamington is easier to develop and already has a substantial amount of infrastructure to
support the development, and the new residents who will live there. It is close to the M40
and there are existing employment opportunities in the South of Leamington Spa as well as
existing out of town shopping facilities and good access to the town centres.
Therefore, the previous plan (the 2009 Core Strategy) is direct evidence that there are
alternative areas for development other than the Green Belt and that consequently there is
no evidence that very special circumstances exist to change the Green Belt Boundary.
Warwick District Council argues that the land in the South of Leamington is not as attractive
to developers because concentration of development in that area may result in the
developers making less profit. Consideration of the developers' financial gain is not a very
special circumstance to permit unnecessary development in the Green Belt. Concentration
of development would encourage the housing to be competitively priced and more
affordable when built in the south of Leamington Spa.
RECREATION VALUE OF OLD MILVERTON AND BLACKDOWN
Milverton Gardens (North of Milvertion) is an important local amenity for exercise and
recreation as there is very little alternative publicly accessible open space in this area.
It is enjoyed by many walkers, runners, riders, and cyclists. It provides a countryside
environment close to the neighboring areas of Leamington Spa. Evidence has also shown
that people are traveling from the Centre and also the South of town to use the amenity,
further demonstrating the value of this amenity to a wide community.
Both the proposed building development and the "Northern Relief Road" would
substantially reduce the amount of land that is available to be enjoyed and have a
catastrophic detrimental impact on the ambience and hence the amenity value of the land.
The implication that somehow the proposed type of development will magically turn some
of it into a maintained park land is both unlikely and unsustainable. It would also detract
from, rather than enhance its value; managed parkland is a poor substitute for access to fine
agricultural land.
North Leamington Forum recently (and ironically at the presentation of these plans!) had to
allocate funds to struggling local groups trying to maintain and create small recreation
spaces within housing developments which the Council will not / or cannot afford to
maintain. This demonstrates the value of the currently free amenity which the community
enjoys.
North Leamington Spa does not have parks such at Victoria Park and Jepson Gardens as do
other areas of Leamington Spa. This area of Green Belt provides an invaluable and
irreplaceable open and free resource to the community. A great many signatures have been
collected on petitions in support of keeping this amenity.
The Housing Assessment fails to identify the footpath between Milverton and Old
Milverton. Policy QE4 in Regional Spatial Strategy for West Midlands states that footpaths
and the green spaces around them must be preserved. The document is being used
powerfully at the moment in the "evidence base" to support council desires, yet has been
heavily cherry picked. Indeed Policy QE6 states "Local authorities should
conserve...protecting and where possible enhance natural features that contribute to the
character of the landscape and local distinctiveness"
INFRASTRUCTURE / PROPOSED NEW ROADS
The Northern Leamington Relief Road, at an estimated cost of £28 million, would ruin Old
Milverton and divert resources from other much needed public investment. As a Charted
Quantity Surveyor it is evident that this estimate is unlikely to be the maximum outturn cost
considering the ground over which the road must run and the bridges and retaining
structures which will be necessary together with the other costs which will be attributed to
it.
Traffic flows in the area tend to be north to south rather than east to west. The road will
serve no purpose other than to take new home owners quickly on to the A46 and to jobs
and shopping opportunities away from our Town. If the development does not go ahead the
road will not be required.
Turning the A452 between Leamington and Kenilworth into dual carriage way will not help
traffic flows. At peak times the delays on the A452 result from commuters wanting access to
the Town centres. Building nearly 3000 houses north of Leamington will simply increase the
congestion. The dual carriage way will have a detrimental effect on the picturesque
northern gateway to Leamington and southern gateway to Kenilworth.
A "Northern Relief Road" will form a natural barrier and encourage further development in
the green belt up to this new road. It will need to be built across the flood plain and will
violate an important nature corridor along the River Avon.
If the proposed development is concentrated in the South of Leamington there is an existing
road network that could be upgraded at considerably lower cost than the £28m allocated to
construct a "Northern Relief Road" so reducing the sale price of the houses.
NEW OUT OF TOWN STORES AND EMPLOYMENT
The proposed "out of town" retail operations will be another blow to independent retailers
in Leamington, Kenilworth and Warwick who make the area an attractive place to live.
Further "out of town" shopping will take trade away from the Towns.
However the Council have stated at Forums that they don't plan out of town shopping,
apparently therefore the Consultation information is inaccurate?
They have also played down the concept of new employment land in the Green Belt in these
same Forums and have been totally unable to give details at to what is alluded to in the
Consultation by these phrases. They indicate this has yet to be thought through. Further
demonstrating that the evidence base is still being developed to justify the plan not the
other way around as should have been the case.
LOSS OF AGRICULTURAL LAND
There will be a loss of a significant amount of high quality agricultural land in Blackdown and
Old Milverton which is unnecessary.
OVERALL LEVEL OF HOUSING PROVISION / NUMBER OF HOMES INCLUDED IN THE
FORECASTS
There appears to be over-provision of housing resulting from the Council relying on
projections from a past period of exceptional growth as noted earlier.
Furthermore the Council have agreed in the Forums that there is a "contingency for the
consultation" to the tune of at least 1400 homes. Detail investigation of the low numbers
assumed for allocations on sites such as the Fire station and other town centre sites indicate
that there is also a further 'hidden' contingency.
The Council appears to be building contingency on contingency. Consequently, even
accepting the population and demand projections, the units proposed for the green belt to
Milverton Gardens (North of Milvertion) can easily be deleted without causing a deficit,
even if no alternative sites were substituted.
The situation is exacerbated in that having identified non Green Belt Land as suitable for
development, but then having rejected it without adequate justification, there is a real
possibility that the owners of this will gain planning permission on appeal resulting in
further over provision of land.
Returning to the 1400 homes contingency alone. If this "buffer" is removed from the
forecast there is no need to include the Green Belt land at Milverton Gardens (North of
Milvertion) (L03 & L07) in the proposals.
ALTERNATIVE PLAN
The Council have said in Forums that in making objections to the plan, residents should also
give solutions. However the Council have done little to publicise the very short 8 week
consultation. Furthermore the Council have refused requests for an extension until the last
few days (It was slipped quietly into the Consultation details page after the 18th July with no
announcement and the Web landing page was not updated to make the public aware of the
change). This gives the impression that this was a consultation in name only and very little
time has been available for people to make alternative proposals. However the plan is
poorly put together and there are clear considerations and alternatives which should have
already been accommodated.
Significant areas of land to the South of Leamington Spa have been stated by the Council to
be undeliverable. This is incorrect.
Developing the land to the South of Leamington has significant advantages:
 The employment land is to the South and local employers are already saying they
need much more affordable housing in this area.
 The transport routes to M40 exist in this area and relatively affordable traffic
solutions will accommodate the expansion.
 The infrastructure already exists in this area, even to the point that traffic islands
have been built to take some of the new development!
MY KEY POINTS OF OBJECTION ARE
1. Local Amenity: The land proposed for development is a vital local amenity for
exercise and recreation; the recreational value of this land would be lost. The heavily
used footpaths make this element of greenbelt one of the most valued in the area. It
is for this reason there is such strong opposition.
2. These areas of greenbelt meet 4 of the 5 purposes of greenbelt land and should
therefore be protected from development. The Greenbelt Study undertaken by the
council is highly subjective and residents don't believe this is a sound basis for the
Preferred Plan.
3. Greenbelt land should not be developed because the Local Plan is governed by the
National Planning Policy Framework which states greenbelt should only be built on in
exceptional circumstances, and local residents believe exceptional circumstances
have not been demonstrated. In particular there is suitable land identified by the
Council to the East of Europa way and South of Heathcote that have not been
included in the local plan. Namely Grove Farm.
4. The apparent Council policy of spreading development around the county is not an
appropriate planning policy, but is rather a political policy and thus this greenbelt
land should not be built on.
5. There is further adequate land available around Radford Semele, this land has been
unnecessarily discounted by the Council due to the presence of gas mains, but this
land is viable in spite of the 100m exclusion zones by incorporating these zones into
part of the open space of a garden town.
6. The National Planning Policy Framework states that one purpose of greenbelt is to
prevent urban sprawl, the Preferred Option ignores this and causes sprawl, which is
compounded by Southward development of Kenilworth.
7. Even accepting the population and demand projections for housing the units
proposed to be built on the Green Belt land to Milverton Gardens (North of
Milvertion) could be deleted by omitting the 1400 over provision without causing a
deficit; residents believe this should be done.
8. Non greenbelt land that has not been included by the council is likely to have
planning permission granted on appeal from developers resulting in an overprovision
of land and needless development of this greenbelt.
9. The existing infrastructure is not appropriate to the new development, requiring a
£28 million relief road. The need to include such a massive undertaking invalidates
the argument that there is exceptional circumstances to build on the greenbelt. The
£28 million, even if raised from developers, is a waste of public money and will have
an adverse impact on the price of the houses and undermine the aims of affordable
homes
10. There is significantly better infrastructure in the South with access to the M40,
where development should therefore be placed.
11. There are inadequate employment facilities in the North of the town surrounding
the proposed development site and little evidence how the employment land, which
the Council propose to allocate, would be used. In contrast there is a good track
record and existing employers in the South of the town who chose to be locate close
to the M40. The plan must be evidence based and there is not enough evidence to
suggest there will be enough employment opportunity in the North of the town.
12. If additional housing is required for Coventry and Warwickshire Gateway then that
housing should be adjacent to the airport site to allow sustainable transport e.g.
cycling, avoid congestion, avoid coalescence, and justify exceptional circumstances.
If this were not possible then non-greenbelt land in the South should be released
capitalising on the M40 infrastructure and improved road layout near the site that
has already been identified by Councillors.
13. To be sustainable housing should be planned close to proposed employment
otherwise it will have adverse impacts on commuting and travel. If for example
people end up having to commute to the Coventry Gateway project then and is
contrary to a sustainable community and contrary to the declared aims of the
Gateway project.
14. The preferred options plan states that it is vital to ensure that new housing is
affordable, construction on the greenbelt to the North of the town will not create
affordable housing. House prices are higher in the North of the town and the cost of
the relief road will be passed on by developers to new homeowners in the
development. Furthermore if development is focused in the South then an increase
in housing supply will ensure that the developers focus on delivering good quality
affordable homes. This is a simple supply and demand argument.
IN CONClUSION
I strongly urge you to reconsider your plans. There are no grounds in your evidence base to
justify building on any Green Belt Land at Milverton Gardens (North of Milvertion) and
Blackdown.

See attached