5. Preferred Level of Growth

Lack of evidence to support such high level of growth

I believe in the currrent economic climate the growth forecasts are over estimated and a more cautious approach to development should be considered. Brown field sites and ensuring existing housing within the town is fully occupied should be the first step, only when this supply has been proven to be exhausted should expansion into green belt land be considered? This would also ensure the existing infrastructure is optimised before reinforcing existing or building new.

I think that the preferred option requires too many new houses. The assumed population growth figure I think implies some inward migration. Natural population growth would not be as high as stated over this length of time. There is brownfield land to spare in Coventry and Birmingham and if houses are needed in the Midlands as a whole, that land should be used first. Too many people here will start to damage the very features which made it an attractive area in the first place.

The projections are unrealistic and way beyond the requirements of the district for sustainable ongoing development.

The failure of the economy and therefore the inability for people to afford the housing does not mean build more houses, the economy must recover to enable existing properties to become more affordable.

When economic recovery takes place additional housing will mean more competition for existing properties, if people wish to sell their property it can only be concluded that this will leave people with negative equity within their property.

I cannot see the need for this level of growth when we have houses standing empty on the old Potterton site, and in the knowledge that the Chase Meadow development has dragged on for so long due to slow sales of the houses there.

I understand the Council's obligation to put in place a plan to manage physical growth, in support of a nationwide desire for economic growth.

I do not accept that physical expansion of the town to facilitate economic growth will ever be justifiable in one of the UK's wealthiest towns, where economic growth itself is hardly needed - compared for example to Coventry. With economic growth itself hard to justify, there can never be a justification for expanding the town at the expense of the Green Belt.

I further object to the PO1 choice of 555 homes/year from options stated by the Council as 250/500/800 because I do not accept that the Council must plan to build any new homes. I am not satisfied that there is valid evidence of demand for new homes other than from Developers with established land Options. I do not accept a consultation process which asks for comments on a choice of house numbers without the choice including zero.

I do not consider appropriate or sound the Council's policy of creating affordable housing through land development deals: creating private housing at the expense of the Green Belt and the consequent roads, schools and employment zones is an indictment of the Councils inability to fund affordable housing directly.

insufficient evidence to support this level of growth

Jobs are needed for people to be able to pay mortgages/rent. The level of growth used by this survey is from a projected level estimated in July 2010. Since then we have gone into further recession - not expected to recover fully until 2025.

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

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

At the meeting at Woodloes School it was agreed by councilors that the data used to predict future levels of growth (and therefore future housing requirements) was out of date. As recent financial reports have confirmed that the UK is still in recession, the estimations regarding growth and future housing requirements used in this plan seem exaggerated and inaccurate.

This level of growth seems far too high, and based on statistical guesswork trying to look too far ahead. Our countryside is far too valuable and important, in so many ways, for it to be covered with tarmac and concrete unless the necessity is absolute.

I'm not convinced that these levels of growth - as proposed - are correct as forecasts. They seem incredibly optimistic.

I find the proposed development plan very ott and full of promises that will probably never come to fruition. I know that there is a requirement for new housing but feel that the 10,000 is excessive, bearing in mind empty properties and places proposed for in-filling. I do not believe that we have the infra-structure in this area to cope. Surely you start with employment opportunities and then start building houses. The roads in the centre of Kenilworth, Leamington Spa and Warwick can barely cope with the amount of traffic there is at present. Public transport needs to be improved first, ideas to limit car travel need to be considered before any housebuilding, otherwise the result will be chaos and gridlocked roads. Buses should be subsidised. Some routes are hardly used, e.g. the Hatton Park development where the buses into Warwick are normally empty and those living on the estate should be encouraged to leave their cars at home and use the empty buses. Otherwise the number of buses should be curtailed or stopped.

I am especially worried about areas 2 and 3 as it appears to be complete over-development. Will traffic be pouring into Warwick and Leamington from these estates? If so, Myton Road, Castle Hill, Tachbrook Road, etc. will become totally gridlocked. What plans are there to overcome this?

Infilling is also very worrying. I live opposite the old fire station in Warwick and see that it is now a very useful additional parking area for people living in Albert, Victoria and Edward Streets. It also provides many parking spaces for County Council employees who work in the Saltisford Buildings. If social housing is built on this site, not only will we lose this valuable parking space, each new house/dwelling will have to have a minimum of parking space for 2 cars otherwise it will just add to the already serious parking problem. I only have a visitors parking permit but quite often my visitors have great difficulty in finding a parking space. Thought needs to be given to the allocation of parking permits for each household. When considering infilling, thought needs to be given, not only to what will be built on the site but how it will affect everything around that site. We see very few parking attendants and the "No Entry" sign at the Saltisford and Albert Street Junction is often ignored. Parking is already a very serious problem. Unless something is done when the social housing is built it will become an even bigger problem.

I do hope that lessons have been learned from development of estates like the Woodloes where a school was one of the last things to be built.

General: The term "preferred options" implies that the decisions have already been made, and that there is little, if any chance of them being changed. This underlines the FACTS that the results of the previous "consultation" have been ignored, so leaving residents with the impression that this consultation will also have no effect.
PO1: 52% of the respondents to the previous consultation opted for the lower number of new houses to be built, on the grounds that this would meet the requirements of current residents and their families. It would not attract further influx of people seeking employment not available in the District, employment which they would only find outside it, further increasing the already unacceptable traffic problems. The Council decided to ignore this view and propose a much larger (100% larger) number of houses. We can only conclude that the Council is bowing to instructions /bribes from Westminster to allow more houses to be built by private developers, since there is no indication anywhere that the Council itself intends to carry out any of this housing growth.
PO2: The infrastructure levy is an essential feature of any increase in the number of houses built in the District. However, it must be levied and spent BEFORE the new housing is occupied. We have already experienced the problems which delaying this expenditure has created in Warwick.
PO3/PO4: There is clearly a preference for a high proportion (almost 50%) of the development to be located in Warwick. There seems very little proposed for the villages. Half the proposed housing development is on the south side of the district. Given that the bulk of the new employment opportunities will not be in the small area of the District, but in the larger employment proposals for Coventry, commuting through the towns will increase, not decrease.
PO5: The balance of the types of new housing should be very carefully scrutinised: too much of recent development has been of small properties and retirement flats, only suitable for short-term occupation by first-time buyers. More of the new housing must be for family use. The proposal that 40% of new housing should be "affordable" is essential, and must be maintained against developers' pressure for its reduction. A better definition of "affordable" is also required
PO6/PO7: Statements of the blindingly obvious.
PO8: The designated employment land must be maintained against the pressure which will be put on the Council by developers. We have already experienced in Tournament Fields the result of this pressure proving effective. There is no indication in the Plan of what percentage of the land will be designated as employment land.
PO9: We note that there will be "support for new retail investment on Leamington Town Centre". Why only Leamington? The other towns are equally deserving of support, though there is no indication that this proposal has any financial backing.
PO10: Forget the concept of "garden towns/suburbs". These were built in an era of weaker planning regulations and allowed a much larger area of land to be taken into use for housing. In the current climate, such land use is not acceptable to the general population. Planning law is about to be relaxed, and the Council must be vigilant in maintaining the quality of development.
PO11: This is a very weak section, "offering help and advice" is not very positive: more concrete proposals, including financial commitment is needed. This is repeated in PO17 where "support" and "seek contributions" are the key words.
PO14 (and un-numbered section following): The road improvements proposed would be of marginal value. The "improvements" to Europa Way and the junctions would be very expensive, and could use up a substantial proportion of the available infrastructure levy, to the detriment of more useful projects, such a schools, health centres and open areas.

In my opinion the Council has not considered the long view, i.e. the housing and infrastructure needs by the middle of this century. In 1500 London was the size in area and population of Leamington and Warwick combined, at most. It now covers 609 sq. miles and it is home to 8 million people. Birmingham may well join to Coventry and Coventry to Leamington by the mid century and most certainly by the end. Any interval of open land, parks, allotments, tennis courts, cricket pitches, large town gardens is a godsend in any large conurbation. The Georgian and Victorian town square gardens in London or Houseman's in Paris or the intervals of open space in Georgian Bath make them 'walkable' cities. The overall plan could look at developing land to the South and over the next few decades we could see the re-establishment of the rail link to Rugby and a motorway link between M40 and the M1 skirting Southam, which may, in 50 years, be a suburb of Birmingham.!!! In conclusion a long term plan for urban development in the direction of Rugby via Radford and Southam would help to retain some open green space between Coventry and Leamington Spa, for which your great grand children would thank you as I do thank the Town Planners of previous generations for their sanctuaries of open spaces. Any one for tennis?

It is very clear that an enormous amount of work has gone into this draft. Nevertheless, it is seriously flawed.
It does not reflect the views of the district residents, who, in the published surveys, advocate only modest development.
The justification appears to be based on an assumption that there will be a substantial growth in population.
This country is already overcrowded and cannot afford the growth predicated.
The economic situation also implies that population growth will be less than in the recent "boom" years. This means that strategies based on past population growth statistics are erroneous.
There is a fast developing global food crisis. Britain will have to become more food self-sufficient, which means preserving prime agricultural land.
Even if the local population does grow at your forecast rate of 13%, it is unnecessary to plan housing at the rate of less than 2 persons per property!
I propose that the Council develops an alternative strategy, which is properly based on the following key elements of the NPPF. The current draft does not follow the NPPF.
1 Promote competitive town centre environments
2 Promote vitality of urban areas
3 Protect green belts around them
4 Recognise the benefits of best agricultural land
5 Conserve landscape and scenic beauty
6 Use brown field sites first
7 Only change green belt boundaries under exceptional circumstances
8 Even then, only consider limited infilling of green belt land
9 Avoid potential coalescence
I propose the plan be based on the following principles:
1 Accept that this area is already overpopulated.
2 Regenerate urban areas. Much of the housing is decrepit and should be redeveloped with a higher urban population density.
3 Regenerate town centres and depressed urban areas. Replace old housing with modern accommodation.
4 Accept that maximising economic growth and housing is NOT the priority for Warwick District.
5 Quality of life and the environment are more important.
6 Moderate development is the key.
7 Existing green belt boundaries are sacrosanct.
The plan should be developed strictly within these parameters.
If this means a slower rate of economic development, then that is appropriate for this District.
If this means a slower rate of population growth and housing, then so be it.
It is still possible to encourage new business, reduce unemployment and provide more housing, given a moderate development strategy.
Green belt boundaries are sacrosanct in this 'Green and Pleasant Land'.

Introduction

The Warwickshire Branch of the Campaign to Protect Rural England (CPRE) is a charity registered No 1092486 with over 700 members in Warwickshire. CPRE is very concerned about many aspects of the New Local Plan Preferred Options agreed by the Council on 21st May 2012 and now published for consultation.

Firstly we give our response to the main Preferred Options. We then examine key issues on the Vision, projected growth, population growth assumptions, the Green Belt, and the proposals for employment.


The Preferred Options (PO1 to PO18)


PO1 Level of Growth

We strongly oppose the level of growth of 555 houses/year that PO1 proposes. The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and much of this is by windfall development within the urban areas.

The proposals to impose 100 houses on each of five villages would damage their rural character and unbalance their structure.


PO3 Broad Location of Growth

The proposal is 'growth across the District' including on Green Belt, and in villages. No direction of growth or focus on particular broad locations is proposed. This is contrary to the policy of previous Structure and Local Plans. Those plans protected Green Belt and identifed key locations while ensuring that urban land was re-used, and villages were only asked to accept limited new housing.

No clear reason for the change from past Local Plans has been offered. As those have been successful, the policies and patterns of development that they provided for should be maintained in the new Local Plan.
The extent of windfall development and use of brownfield land in Warwick and Leamington has been high for many years. There is no reason to depart from the practice of encouraging these forms of development.


PO4 Distribution of Sites for Housing

PO4 proposes a large number of greenfield housing sites which are currently Green Belt or greenfield. Most of these would not have been considered at all acceptable in past Local Plans, and we strong oppose the following sites, because they would require release of land from the Green Belt or would affect historic landscapes (such as the approach to Warwick around the east side of the Castle Park).

Sites:

3. South of Gallows Hill, west of Europa Way : harms setting of Castle Park and approach to Warwick from the south
4. West of A452 Kenilworth Road, between Northumberland Road and Old Milverton Lane - Green Belt, and essential part of the open countryside separating Kenilworth and Leamington
5. Blackdown - open countryside, which if developed reduces the separation between Kenilworth and Leamington by a quarter
8. Red House Farm, Lillington - Green Belt, visible land facing southeast
9. Loes Farm, Warwick - extends Woodloes Estate into Green Belt, and undermines tight planning control on north side of Warwick
13. 100 houses in each of 5 villages - this is an arbitrary imposition. Individual villages should be able to determine how much development they wish to accept.
14. 350 houses in smaller villages - there is no basis for such a figure, and most smaller villages should only accept 5-10 dwellings over 15 years if their rural character is to be ensured.

We also believe that Site 6 South of Sydenham, is too large an allocation and only a smaller development should be considered; that Site 2, Myton / West of Europa Way, is high-grade farmland protected from development under past Local Plans for its agricultural value, and its loss would be the end of the remaining green wedge left when employment land was developed east of Europa Way; and the scale of Green Belt release for Site 7, Kenilworth (Thickthorn) needs to be reduced. If these sites are released, this should be only after brownfield sites have been developed and windfall potential within the urban areas has been assessed.


PO5 Affordable Housing

CPRE supports the policy of 40% affordable housing which is carried forward from the 2007 Local Plan. It is strongly opposed to the part of the policy which would allow private sector developments in villages to fund affordable housing. If affordable (rented) housing is permitted in villages, this must be only following a sound assessment of local need, and should not bring with it housing for sale simply to provide funds for the affordable houses.


PO7 Gypsies and Travellers

CPRE supports finding an official site for gypsies. The numbers to be accommodated need reassessment against new policies: some gypsies have property elsewhere, and do not need to live in caravans. CPRE would propose that the gyspy site at Siskin Drive, just inside Coventry, be enlarged or re-sited in the Middlemarch employment area, so that part at least meets the needs of Warwick District.

PO10 Economy

CPRE opposes the provision of employment land north of Leamington on Green Belt. There is no need for major new employment land identification in the District. Surplus employment land and buildings in the towns come on the market continuously and can generally be re-used without any need to allocatec new greenfield land.

There is no shortage of employment land in Warwick District. In a recession, with economic difficulties meaning that land for employment becomes surplus, loss of existing sites to housing is more of a problem than any lack of new greenfield sites.

North of Leamington, proposed in PO8, would be an unsustainable location for employment development. It would be outside the town centres where the focus of employment is supposed to be; it would generate much car traffic; and the main transport routes through the District are south not northof Leamington.

The proposal for the Coventry Gateway around Coventry Airport has no economic justification: it would not be relevant as an employment site for most who live in Warwick and Leamington, is not easy to reach from Warwick District's urban areas, and would compete with the Ansty and Ryton employment locations nearby which are in Rugby District.

Established and new small businesses rarely need any planning permissions for their commercial activities.

Our conclusion is that no development of new employment land in the Green Belt is justified.


PO11 The Historic Environment

The existing (2007) Local Plan contains clear policies to guide conservation and decisions on developments that affect a Conservation Areas. This set of Policies should be generally carried forward, without any simplication (which can cause ambiguity).

A Policy to make the lengths of the Grand Union Canal and Stratford Canal in Warwick District into Conservation Areas is needed. Other Districts with extensive lengths of canal have created linear conservation areas.


PO14 Transport

The proposed new road links and road widenings in the Preferred Options would be harmful to the Green Belt and tend to encourage more car traffic. That would create unsustainable patterns of movement and increased car depenency. By contrast the proposals for the bus network are thin. They focus on Park & Ride provision which is not of importance to residents of the towns.


PO16 Green Belt

The Preferred Options would require major removal of land from the Green Belt for urban development. It would also require the removal of 'washed-over' status of some smaller villages which are currently covered by Green Belt designation. The very special circumstances required to be demonstrated if Green Belt land is to be released for building have not been shown to be justified.




The Key Issues


1. Vision and Growth

1.1 The key aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This reflects a current focus in national government thinking and speeches by Ministers. It fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years.

1.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

1.3 CPRE believes that there should be a much more careful balance between development and the environment than the Preferred Options would achieve. The proposed scale of development would risk being unsustainable and contrary to the NPPF policy that supports sustainable development.

1.4 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

1.5 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.


2. Sustainability

2.1 The National Planning Policy Framework (NPPF) at para 49 sets out the principles of sustainable development. The NPPF says that Sustainability has three aspects, environmental, economic and social. The Preferred Options pay little attention to the environmental aspects of sustainability.

2.2 The term 'sustainable' is used about 120 times in the full Preferred Options report, but this is mostly in relation to economic aspects of sustainability.

2.3 We do not believe that large-scale destruction of open countryside is sustainable development - it is unsustainable. Once lost it will never become available for future generations.

2.4 We acknowledge that a few mentions of sustainability in the proposal do relate to the social aspects such as providing sufficient of the right kinds of housing and facilities.


3. The Projected Housing Requirement

3.1 CPRE is strongly opposed to the proposed level of housebuilding advocated in the Preferred Options.

3.2 The justification for this level of housebuilding is weak, for the following reasons.


1. The ONS projections for Warwick District are arbitrary and probably overstated. They do not yet take account of likely reductions in net migration to the UK or the potential effects of the recession. They assume in-migration at recent levels although this is now reducing rapidly.

2. Projections for individual local authorities are notoriously unreliable because they do not take into account the implications of planning and other policies. Already the 2011 Census (issued in summer 2012) shows that the growth of population in the last decade given at para 4.2 of the preferred Options is nearly 50% too high. Population growth 2001-2011 was not 14,800. It was 10,000 from 2001 to 2011 (126,000 to 136,000).

3. House building rates in Warwick have been very low over the past five years and are likely to pick up only slowly. The rate of housebuilding proposed by Warwick DC in the Preferred Options is well above the rate achieved in the last 10 years and on current economic trends is unachievable.

4. The work by G L Hearn / JGC at Appendix 2 of the SHLAA does not lead clearly to any particular level of population, household or employment growth. Their projections are highly volatile, depending on a range of key assumptions.

5. From statements in the Preferred Options, and made at public meetings during consultation, it seems that Warwick District Council has decided to seek a relatively high level of housing development in the mistaken belief that it will help to boost economic growth. There is no overriding need for major new employment development. If population grows rapidly, it is more likely to result in a change in the balance of commuting, with more Warwick residents working outside the district.

6. The consultants' work on translating population growth into household growth is inadequate. It assumes too high a vacancy rate for new housing stock and fails to consider sharing and institutional population.

3.3 We have other major concerns about the population projections.

3.4 In its commentary on the projections, the Office for National Statistics says - 'Projections are not forecasts and do not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. They provide an indication of the impact that changes in demographic patterns might have on the size and age structure of the population in the future.' Therefore the projections should not be taken literally.

3.5 There are particular questions over two of the assumptions made in the national projections:
* Net international migration, which makes up roughly half the projected population increase, is likely to reduce in future, reflecting a tightening of government policy on this issue. This change will not yet have been picked up by the projections;
* Although there is little sign of this yet, birth rates may fall as a result of the recession and the slow recovery from it.

3.6 The Preferred Options forecast that Warwick District's population will grow by 21,600 between 2010 and 2026, and from this a requirement for about 9,390 extra dwellings is produced. (The average household size would stay at 2.3 persons.) This produces a rate of building of 587 dwellings per annum, not achieved in any past year for some decades

3.7 The suggested rate of building, at 550 dwellings per year, has not been achieved in the District for some decades, if ever. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The Government predicts only a slow recovery from the recession, with a gradual increase in house building rates. Therefore it could be many years before the Preferred Option's desired rate of house building can be achieved, and the past record suggests that it will not be achieved.

3.8 In an earlier consultation in September 2009 Warwick District Council asked for public views on three scenarios for numbers of houses. These were 200 per year, 500 per year and 800 per year. 51% of the public chose 200 per year. Despite this result the Preferred Options propose that over 500 houses be built annually.

3.9 The net in-migration element in the forecast housing requirement is large - 57% of the population growth forecast by the Council's consultants (in the SHMA) would be the result of net in-migration. However in-migration has fallen fast in the last 2 years and there is no clear reason why it should be provided for. If more houses are built, given the location of the District on the M40 and Chiltern Railway route, more inward migration will take place. There is not an objective need to provide for or seek inward migration.

3.10 We consider that the Preferred Options housing figures should be reduced substantially; the 2011 Census results and latest migration data be taken into account, and an objective need recalculated instead of assuming that in-migration should be planned for.


4. Proposed Locations for Housing


4.1 CPRE believes that a number of the major new housing locations proposed would be harmful. See response to PO4, Distribution of sites for housing.

4.2 The NPPF at para 109 states that "the planning system should contribute to and enhance the natural and local environment". This militates against development in the countryside and favours protection of landscapes, animal and plant life, public footpaths and Scenic Views. Further research would identify valued landscapes, geological conservation sites, soils ecosystems, impacts on biodiversity and ecological networks.

4.3 NPPF para 112 states that Local Planning Authorities should take into account the economic and other benefits of the best and most versatile agricultural land and should seek to use areas of poorer quality land in preference to that of a higher quality. Much of the land around Leamington is 'best and most versatile' agricultural land. This places a presumption against its loss to development.

4.4 Clearly any use of green land will require destruction of hedges, ponds and other habitats of animals and plants. It is likely to destroy public footpaths. It will certainly affect the views of countryside which are currently available to visitors, walkers and residents at the edge of the existing built-up area.

4.5 The area of the district which is not in the Green Belt is generally to the south and east of the built up area. While there are constraints here, and location (3) is wholly unacceptable, there is scope for some development at the locations previously considered in the 2009 Core Strategy.

4.6 Three pipelines run to the south-east of Offchurch, Radford Semele and Bishops Tachbrook, but not through the area of land adjacent to Europa Way or between Whitnash and Bistops Tachbrook, so do not appear to be a significant constraint.

4.7 There is some scope for more housing at Hatton Park which has been a successful development that maintains a 'washed-over' Green Belt status.


5. The Green Belt.


5.1 In para 79 of the NPPF, it is stated that "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."

5.2 Para 80 sets out five purposes of Green Belt. The West Midlands Green Belt to the north of Leamington and Warwick and the south of Kenilworth meets four of the five purposes:
* It prevents urban sprawl
* It prevents towns merging
* It is assisting in safeguarding the countryside from encroachment
* It assists urban regeneration by encouraging recycling of derelict and other urban land.

5.3 NPPF para 83 states that confirmed Green Belt boundaries should only be altered in exceptional circumstances. We are far from convinced by the arguments that the boundaries should be altered. The sole reason appears to be to spread the pain of development on greenfield sites across the District. This is not a planning justification which satisfies the need for exceptional circumstances.

5.4 NPPF 84 makes it clear that sustainable development to be channelled towards urban areas inside the Green Belt boundary and towards towns and villages inset within the Green Belt boundary or towards locations beyond the outer Green Belt boundary.

5.5 As in other parts of the report we see clear conflict with the Localism agenda of the coalition government. The Localism Act gives communities, including neighbourhoods, towns and villages, a procedure for determining for themselves what development should take place and where it should be located.

5.6 NPPF para 87 states "as with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances".

5.7 NPPF para 88 states that "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".

5.8 Taking extensive Green Belt land out of the Green Belt and proposing it for housing is the opposite of a sustainable development policy.



6. Employment Land Proposals

6.1 CPRE supports a low-carbon economy; but it has a very long timescale, and must be developed but we are concerned that the proposed Preferred Options will not enable this. In particular, we question the proposal to "distribute development across the district". Established towns (and nearby cities) offer critical mass where homes and jobs can be developed in a balanced way supported by infrastructure such as public transport.

6.2 Substantial development in the countryside, such as the proposed major employment at the Coventry Gateway site, would increase the need to travel with the vast majority by private car. The Preferred Options recognise the importance of the need to reduce travel (e.g. in section 8.30) but do not seem to apply this principle consistently.

6.3 Major development in the countryside would make the principle of "developing an effective and sustainable transport package" very difficult to achieve and undermine the agreed principle of regeneration of urban areas. We support the preferred option (in PO3) to concentrate growth within urban areas but we are concerned about significant development in villages and rural areas.

6.4 We recognise the need to provide land for employment to meet proven local needs but are concerned about the proposed principle to provide land to "encourage the creation of jobs". Sustainable jobs are critically dependent on factors such as people, skills and finance, not just buildings or land. Increasingly, attracting skilled people and knowledge-based businesses to an area is dependent on the quality of the environment: somewhere people want to live as well as work. The social and environmental strands recognised in the NPPF are as important as the economic strand.

6.5 It is essential to keep employment balanced with housing: over-statement of housing numbers leads to over-statement of the need for employment land. We object to the over-allocation of housing (proposed in Section 7.22) to support the proposed Coventry Gateway, which has not been justified.

6.6 We note (from sections 8.21 and 8.22) that the Preferred Options propose some 66 hectares of employment land in the period from 2011 to 2026 and that 43 hectares have already been identified. For the remaining 23 hectares, we agree with the urban-brownfield-first priority and agree with the approach of locating employment with housing where new housing developments are really justified.

6.7 Compared to the remainder of 23 hectares of employment land over 15 years, the Coventry Gateway proposal amounts to over 97 hectares in one rural location in the early years of the strategy period. Such a volume of over-allocation would be indefensible and should not be considered as part of a balanced plan.

There is already a regional investment site at Ansty Park. It has fully developed infrastructure and yet currently vast tracts of empty land off blocked-up site roads. Empty buses frequently serve the mostly-empty site; it has excellent access to major highways but too few occupiers. The duty for local planning authorities to cooperate should mean that this site is supported by WDC rather than undermined with a competitive development in the Green Belt just 8km away.

6.9 Recent planning studies and processes have concluded that there is no need for more employment land in Green Belt. The Inspector's Report for the Examination in Public of the Coventry City Council Core Strategy (April 2010) concluded "There is no current need to allocate any additional employment land outside the city boundary, over and above that available at Ryton, to meet the overall economic objectives of the CS".

6.10 The Warwick District Employment Land Review of April 2009 concluded that "there is an oversupply of land suitable for the development of general industry/distribution that is already committed/allocated in the current Local Plan to accommodate demand in these sectors". The Addendum dated January 2011 noted a continuing decline in demand for B2 and B8 floorspace. While the 2009 Employment Land Review did identify a potential deficit of land suitable for office development, it identified "the area around south west Warwick and Leamington as most attractive both in market and planning terms". The 2011 Addendum noted decreased demand overall but also decreased completions, recommending further study. The earlier preferred development directions remained unchanged.

6.11 These plans and studies confirm there is no need for development of Green Belt land for employment. The plan numbers are backed up by experience on the ground, where for example the ex-Peugeot site at Ryton-on-Dunsmore has been vacant for 6 years and Ansty Park has struggled to find occupiers. We recognise that the Ryton site is in Rugby Borough but paragraphs 178 to 181 of the NPPF make it clear that local authorities must cooperate when drawing up Local Plans. The NPPF confirms that the Government attaches great importance to Green Belts, supports 'brownfield first' and reasserts that inappropriate development should not be approved except in very special circumstances. Need for development has not been proven and there is no evidence of valid special circumstances that would justify development in the Green Belt.

6.12 The Preferred Options consultation document picks up the claim that the Gateway "has the potential to provide in the region of 14,000 jobs" (section 8.33) even though this number is not justified and falls partly within Coventry. There are many examples of large, speculative developments where job creation assumptions are inflated and over-optimistic. New developments can remain half-finished for many years because demand proves to be far lower than anticipated. That would be a particularly damaging outcome for a large development with a devastating impact on the Green Belt to the south of Coventry. The number of jobs 'created', put forward by developers, cannot be relied upon as a measure of sustained economic benefit.

6.13 There are better ways of achieving more and better-quality employment. This is to put the emphasis on technological advance and the proposed "Emphasis on infrastructure": investment in communications technologies for rural areas in order to support small businesses and home offices. Broadband for rural communities continues to fall behind urban areas so rural businesses are increasingly uncompetitive. A well-wired rural community would help achieve both the low-carbon economy and the rural economy objectives. It would also make the district a better place to live and work for knowledge workers.

6.14 Finally, all the evidence indicates that in Warwick District no new development of employment land in the Green Belt is justified.

Letter and representation form attached electronically.

1. Level of Development required.

The assumptions for the overall growth of the housing market in WDC was taken prior to the recent publication of the 2011 census results which showed a smaller than expected population for the area, This means the the growth for the period 2001 t0 2011 was less than expected. If this lower than expected growth continues then the demand for extra development in the area should be less than that in the Plan. To add weight to this the figure of 550 new homes per year has never been achieved in a single year let alone for 15 consecutive years. This whole section should be reviewed in the light of the new figures.

2. Sources of Development Land

The level of brownfield site allocation seems to be low. These sites have appeared more frequently in the past and the migration of industrial sites from town centres is by no means complete. We hope that this area could be reviewed.

3. Allocation of new Greenfield Development Land

The allocation of 10% of the development land to the rural areas seems suspiciously arbitrary and appears to be a political decision to "share the pain". Similarly the selection of 5 "larger" villages to absorb 100 new homes is decidedly arbitrary. Firstly, the 5 selected villages do not have any special characteristics over a number of other villages or rural conurbations. The exclusion of Cubbington, Leek Wootton, Bubbenhall and the Hatton Park/King Edwards conurbation seems perverse. Secondly, the choice of villages which are deemed to have the infrastructure to take the extra development puts extra strain on the existing overburdened infrastructure, especially traffic in these areas. An alternative route, to expand the areas with poorer infrastructure so as to improve the quality of life in these areas does nopt seem to have been considered. In the case of Hampton Magna and Hatton Park/Kings Meadow and the West Warwick (Chase Meadow) developments, Hampton Magna's facilities are used in great measure by the other two conurbations. An improvement in their local facilities would improve the quality of life in their communities and relieve the strain on the facilities in Hampton Magna, We use this example as we are well aware of our local situation and feel that there may be other areas that also have other communities that are acting as cuckoos in their nest. This strain on the infrastructure of existing communities could be lessened by improving the infrastructure in the satellite communities by the application of CIL money generated from a modest expansion there.

The New Local Plan has to be evidence-based. The arbitrary choice of the five villages, the arbitrary allocation of the same numbers in each of them and the the policy of adding to the already straining infrastructure of these villages rather than improving the infrastructure of those suffering from lack of amenities all show a lack of being based on any evidence at all . We hope that this whole section could be reviewed

4. The situation of Hampton Magna

Hampton Magna was built on a 1960s brownfield site to wit the Royal Warwickshire Barracks at Budbrooke. It was built in the late 60s/ ealrly 70s and so is in its fifth decade. As such it has well defined historical boundaries, ie the Barracks perimeter. There has been a little infill over the years and the Parish Council invited Warwickshire Rural Community Council to carry out a Housing Needs Survey which identified a need for 5 houses in the Parish. The need for further development is not locally required nor, according to the Parish Plan is it supported by the local residents who gave their views in a long questionnaire that formed the basis for the Plan.

The basic built infrastructure of Hampton Magna has changed very little from the the early 1970s when the building of the houses was completed. The village is served by C class roads that link us to the Warwick/Birmingham road and Warwick/Henley Road. The electricity supply is very similar to that supplying the barracks and the sewerage system was put in by builders during the period of "the lump". The school has bee extended, but is, in essence, still the standard 1960s/70s building that is seen all around the county.

The roads leading to and inside the village become very busy at the peak time, in the morning and evening. The locally generated traffic is increased by the use of the C roads as short cuts from the Birmingham Road to the Henley Road and the A46 and the M40 at junction 15, and by traffic going to and from Warwick Parkway Station. The A 4177 at Stanks roundabout which is the main exit/entry to the village is severely congested every morning and afternoon.

The electricity supply is frequently interrupted for a shorter or longer periods, showing the fragility of the current arrangements

The sewerage system was not adopted by Severn Trent Water Authority until privatisation, when the Authority agreed to adopt the system prior to flotation. The system has not been improved and one of the areas where the system was extended to accommodate a few new house frequently suffers from problems.

The school is very popular and has recently had its standard number increased. Whilst this has improved the viability of the school, it has also lead to a great deal of school time traffic congestion at the beginning and end of school.

The infrastructure of Hampton Magna in these areas is at the limit of its usefulness. There is little that can easily be done to improve the local traffic situation, because of the need to cross canal and railway lines. We are not aware of any plans to improve the electricity or sewerage system locally. The introduction of such a large number of house into this village would lead to a complete overload of these services. We hope that you will look again at the need to use this village as one of the villages for expansion and will take a more pragmatic approach, allowing infill in non village areas and improve the infrastructure in other areas.

5. Overall

The residents of Hampton Magna have long been strong supporters of the green belt, not just around Hampton Magna, but throughout the District. There is a deep suspicion of moving green belt boundaries and if any such changes do prove necessary anywhere in the District it should be done with clarity, leaving no area for doubt or future challenge.

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.

Is this Development really needed?
Your plans indicate that up to 8,350 new homes would be built between 2014 and 2029 which is massive growth by any standards. Where is the evidence that this housing is needed? I have some sympathy regarding the need for social housing where it is a well known fact that affordable housing is in short supply nationally. However, all around Warwick and Leamington, there are empty houses and flats as well as developments that started but which have never been finished. One example would be the housing development on the old Pottertons' site by the River Leam between Warwick and Leamington. If properties are in short supply, why have these properties not sold and why have developments of this type not been completed?

I note that new student accommodation is included within the proposals. Surely the Council is actively trying to stop any further growth in student accommodation in Leamington? If so, why has this been stated as a reason for this type of expansion?

Why build on the Green Belt?
The District Council is proposing building on green belt land such as the Gallows Hill area, Thickthorn, Milverton and Blackdown. Why have these areas been targeted when there are alternative sites which have already been identified as being developable but which have been omitted from the Local Plan? One such area is south of Heathcote and contains Grove Farm. The impact on the surrounding area here would surely be far less than it would be if the Gallows Hill development went ahead because the latter is much closer to the centre of Warwick and effectively fills in the open space between Warwick Gates and Warwick?

Milverton is a well known walking area with paths that have been used by locals and visitors for many years. These walking routes that bring you out at the top of Northumberland Road would be wrecked forever. In addition, the planned new link road would destroy the whole character and tranquility of Old Milverton which is used by many walkers going from Leamington down towards the Saxon Mill area.

The Kenilworth Road between Leamington and Kenilworth is already a very busy road. By building on the land at both ends of this road, you are not only eating into the green belt that currently separates these two urban areas but you are also increasing the level of traffic significantly.

In summary, I accept there may be a case for some new housing in this area between 2014 and 2029. However, I believe this should be focused on locations that have already been identified as being developable rather than green belt land which you should be protecting. Most importantly, where is the evidence that a development on this scale is required, given that Warwick and Leamington already has a substantial quantity of housing that has been empty for a long time and other developments that have not been completed due to lack of demand?

I wish to register my objections to the Preferred Options of the New Local Plan, which have come as a complete shock to me when the previous plan seemed so eminently sensible! Although I'm not a constituent of Jeremy Wright MP I support much of what he has written in this weeks' Leamington Courier. Why has development been moved from areas adjacent to Warwick Gates to Green Belt land north of Warwick and Leamington? How exactly have the projections for the numbers of houses needed been arrived at? They do not seem to have paid any attention to the consultations in which 58% of respondents said that the lower growth option was preferable.

I wish in particular to comment about my own local area and the proposal to build 180 houses at Loes Farm. They would be built on the hill or ridgeline, which is what anyone entering Warwick from the north along the Coventry Road sees. This is against the NPPF, which says that the historic character of our towns should be preserved. The last plan stated that the area was "unsuitable for development' and I would like to know what has changed! I understand that the Local Plan of 1949 refers to the undulating land as a "beautiful buffer" for Warwick.

Woodloes Lane, with its view of open fields has always been a favourite walk of mine since moving onto the estate in 1978. This is because of the clearly very old hedgerow, which runs either side of the lane. This habitat supports and encourages a wide variety of wildlife. I expect a new full biodiversity assessment would be needed but I believe that there are for example 280 species of moths, including one previously thought to be extinct; 16 species of butterfly, great crested newts and at least 2 species of bat. The Millennium Way runs up the lane and there are a wide variety of birds living in the area. Green woodpeckers can be seen feeding on the ants in the field and I'm told that there are rare yellow ants living there. Aren't areas of such great biodiversity meant to be safeguarded in the National Policy Planning Framework? Isn't there also legislation which protects ancient hedgerows?

I understand that access to the Loes Farm site is proposed via Primrose Hill, which will cut straight across the old hedgerow I've mentioned above. What consideration has been given to the additional traffic the new estate will generate onto Primrose Hill and out to the Birmingham and Coventry Roads? Traffic at the roundabouts off the estate is congested already at peak times. Whether a roundabout or a new junction is built traffic hazards will obviously increase. The junction with Woodloes Avenue South is notorious for accidents already and this could be another such problem. Presumably this is why a police presence with a "speed trap" has been needed just where the access is proposed.

I refer again to Jeremy Wright's "Westminster Briefing" column where he identifies the councils' failure to consider other sites first whether brownfield or those previously identified for development south of the two towns. I believe these must be properly considered first before any incursion is made into Green Belt land. For this reason I'm not opposed to the eventual development of the former Ridgeway school site and equally near to Woodloes.

In conclusion, I believe there are many good reasons not to include the Loes Farm site in the final plan.

2:2 - Why is the environment not listed as a key priority: without it, all manner of planning applications can be granted which are anti-environmental

Is leisure included in "Health and Wellbeing". If so, this should be made clear.

2:5 - As there is no way the economy can be predicted, there should be a commitment to responding to new opportunities and needs which arise

Can the areas mentioned as requiring regeneration be identified?

I am concerned about the second bullet point under Emphasis on infrastructure, as most areas of the countryside and of importance for wildlife need only a very light touch, if a touch at all. There should be a clear distinction between the approach to parks and managed open spaces, and to wilder areas (e.g. Welch's Meadow would be ruined by heavy handed management).

3:7 - there are elements referred to in this draft plan which need to be prioritised and policy made before March/April 2012; in particular a policy on the concentration of HMOs.

4:6 - the protection afforded to conservation areas should be strengthened, particularly as these cover apparently only 4% of the district

4:8, point 2 - It should be noted that one major contributory factor to the current lack of affordable properties relates to HMOs. The house next door to mine is an example of this. It was owned by an elderly lady who went into residential care. There was a large amount of interest in the property from people who wanted it as a family home, indeed so much interest that it was decided on sealed bids. Because the property needed some updating, and I met several potential purchasers who wanted to restore it to its former self, the highest bidder was, almost inevitably, a landlord who could easily find the finance and would easily recoup the investment by turning it into an HMO. I have seen this repeated time and again in my area of south Leamington where the gains from HMOs has pushed up prices beyond affordable for an individual or family: indeed a local couple I know has not been able to find an affordable small period house and, despite wanting to stay in Leamington, is having to move to Cheltenham to find such a property. In addition to the price problem, most often the conversion to HMO is the cheapest possible and degrades the period property.

4:10.2 - It is right to accommodate university students, but not at the expense of other "settled" residents. South Leamington is at a tipping point where the area could be completely dominated by students The advantages of a large student population tend to benefit the few - landlords and places selling cheap food and drink, whilst the cost and disadvantages are picked up by Council tax payers and local neighbours. It also means that businesses not directed at students tend to stay away. One south town resident recently pointed out that because Leamington is only a student dormitory town rather than a university town, we have generally ended up with all of the problems of a large student population and none of the advantages of the university culture which takes place on campus. I can see no reason why special consideration should be afforded to the University of Warwick in providing accommodation for its students.

4:11 - I agree with all these points, particularly endorsing numbers 7, 9 and 10. It is particularly important in any development not to let the developer be the tail which wags the dog, as the developer will inevitably want to take the easiest and cheapest route in contradiction to the area's best interests.

5-7 - Level of growth:
As forecasting population growth is a very inexact science, the Council should constantly monitor what is actually happening. If the expected population growth is not materialising, planned development should be scaled back accordingly. It makes sense therefore to insist on development of the brownfield sites before eating into Green Belt.

P04:D - Loss of green space should also be taken into account when assessing development of garden land. This space may not be directly accessible to the general public, but if it contributes to the overall feeling of green space which is enjoyed by the general public (e.g. with trees that can be seen from neighbouring streets), it is very important that it is maintained. It is also important for biodiversity and the environment, as gardens are now understood to be extremely important habitats for wildlife.

P06.D - It is most important to identify the locational criteria and to carry out a thorough survey of all HMOs and their residents, not just those which have previously had to get Council approval.

7.59 - We need this policy now!

P08 - We also need a firm policy now regarding the protection of existing employment buildings from change of use, as in my area I can think of several schemes either applyng for or already granted planning permission to change from commercial to residential use. The Plan already points out that f the area population is going to increase, then employment will need to increase as well and it is short-sighted to be allowing commercial property to disappear.

8:21 - Does the projection of additional job requirement take into account that the growth in the older population will automatically mean the release of the jobs these people were doing?

9: Retailing

It is a mistake to be led by the retail "experts" who push for constant retail development schemes in order to compete with neighbouring towns. There is a fine balance between having enough "High Street names" to serve shoppers and having so many that Leamington becomes indistinguishable from any other shopping centre - in which case, why would any non-residents want to come here? The success of the last major retail development - which seems dubious to me - (Parade to Regent Street) should be assessed before rushing into another similar development. Outside shoppers will travel to a shopping centre to find something different and it is this difference which needs to be identified and promoted. These major developments also seem to push up rents for retailers.

13: Inclusive, Safe and Healthy Communities

Developments should not be permitted which will downgrade and produce associated problems to an area, e.g. SEVs.

14: Transport

I suggest WDC promote a car sharing scheme.

P014: How can you plan a retail development in Chandos Street whilst aiming to maintain sufficient parking in town centres. Chandos Street is a much more popular car park than the multi-storeys.

15: Green Infrastructure

A relevant issue is that Network Rail is destroying, and has been for a long time, the natural environment and wildlife habitat along railway lines by felling all the trees and killing undergrowth every year with weed killer.

15:14 - Yes to urban tree planting; concern about messing with the River Leam borders unless already in a well-used managed area.

P017 - I agree with the continued support for the development of a cultural quarter

I believe that existing visitor accommodation should be protected from change of use.

18: Flooding

Planning permission should be sought by someone wanting to pave/concrete over a front garden, as I believe this trend has contributed to flooding problems.

Summary of major concerns

* Restrictions needed on HMOs
* Light-handed touch needed on non-parkland open spaces and riverside
* More creative study of retail demands and opportunities needed
* Although the Plan does seem to recognise this, the expansion of the district must avoid segregating areas into a single use, e.g. residential, employment, etc. Areas are much more interesting and attractive if they include a mix of residential, employment, cultural/leisure, etc. properties.

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