6. Community Infrastructure Levy

The draft plan does not explain what the levy is or how it will operate, or indeed if you are expecting the public to pay for this.

Needs to actually happen-too often dvelopers don't appear to fulfill their commitments to infratsructure

If I understand correctly the CIL will be paid by the developers. This is an important part of ensuring that the developemnt delivers funds needed to improve the infrastructure - such infrastructure improvements should be a detailed part of this plan.

Developers should pay something and what it is and how it will be used is in the hands of the Counciil. However, developers will only want to develop in those areas where they expect to get a good return on their buildings - hence the wish by the Council to use green belt land to the north of Leamington where property values will be higher and subsequent CIL and Council taxes can also be higher - thus bringing the Council more revenue. Stop worrying about developers and worry about the farmers and residents.

So I now need to find and read yet another document!!!!!

The Community Infrastructure Levy may lead to development in the wrong places, e.g. on greenfield sites rather than brownfield sites because the former will give a greater yield than the latter. It looks like a bribe to induce the Planning Authority to consent to schemes that it would otherwise reject.

it is not clear what this is or how it will be calculated

There are many existing areas in Warwickshire which require funding. It seems foolish to work to find funding to build new housing when existing buildings and organisations already lack necessary funding.

A supporter of the 'Taxed Enough Already' (TEA) party.

The Leamington Society supports the proposal for a Community Infrastructure Levy.

I think that this is a good idea.

Electronic attachment

Dear Sir

Following the consultation meeting at Old Milverton I would like to make the following points:

Why are even thinking of putting this development on Greenbelt land when other Brown and White field sites have not been properly investigated?

Old Milverton and Blackdown do not have the infrastructure for a development of this nature and it would extremely costly and disruptive to put this in place.

Much infrastructure is already in place south of the town.

Employment is mainly south of Leamington and practically none in the area where you are planning to build.

People's views should be heard - I hope you are going to listen to them and not present people with a fait accompli.

Why are you making these changes to the 2009 Core Strategy, which was carefully thought out, in contrast to these recent ideas which appear to lack any imagination or appreciation of this lovely natural area of countryside, which is a fitting divide between Leamington Spa, Old Milverton and Kenilworth. This is something that should not be lost for ever.

I do hope you will listen to the people you represent - you have a duty to do so.

Thank you.

Yours faithfully

Jill Wiglesworth

With regard to Warwick District Council's New Local Plan and Preferred Options: I support the numerous objections of the residents of Old Milverton, Blackdown and the views of Jeremy Wright MP in the Courier of July 20th. The source of WDC's evidence for future population growth was successfully (and evidentially) challenged at the Parish council meeting on 16th July. The NPPF is referenced by WDC's new Proposed Local Plan regularly but the content is selectively ignored:
Section 3 - Supporting a prosperous rural economy
* The development of this area will keep infrastructure developments in urban areas and ignore the employment and housing requirements of more rural communities.
Section 4 - Promoting Sustainable transport
* It will increase private traffic through areas used by families and schoolchildren and ignores the requirement for sustainable well-placed transport networks.
Section 5 - Supporting High Quality Communications Infrastructure
* It ignores the need for public transport and high-speed broadband in smaller rural areas.
Section 9 - Protecting Greenbelt Land.
* It dismisses the high value of greenbelt land directly in contradiction of the NPPF.

I refer you to the foreword in the NPPF and its Core Planning Principles. Please follow the requirement of consultation by acting upon the objections of members of the local community with as much vigor as you have done with landowners and development firms. Most of the developers and landowners, particularly in Old Milverton, do not live locally. Financial gain on their behalf does not come with a qualitative cost.

Contrary to Councilor Doody's apparent advice of the 16th of July this year, I will be sending copies of this letter and its objections to my local Members of Parliament. I do not share his alleged opinion that my elected political representatives and their governing processes are a waste of time. I have attached further explanation of my objections below.
Section 9 - Protecting Greenbelt Land.
The area of greenbelt on which development is proposed was identified as such in the last local plan. It was confirmed as of high value by WDC's study of greenbelt not very long ago.
To develop this greenbelt area is to poorly site several thousands of residential houses at the opposite end of town from their road and rail links, main shopping sites and other amenities.
The proposals are contrary to the National Policy Planning Framework's Guidelines on Protecting Greenbelt Land. 'Very special circumstances' do not exist. More suitable land with better transport and amenity links has been identified in south Leamington, closer to most of the aforementioned developments (including new development at the old Ford foundry) which is not green-belt.
The proposed local plan would destroy greenbelt land which for the most part is currently good, economically productive farmland with public access for recreation and provision of views, wildlife habitat, and a barrier for the protection of further farmland that currently prevents urban sprawl.
I hope that the council does not consider the financial gain proposed by development firms more important than the social, environmental and economic needs of its future residents or the benefits derived by current residents from the green-belt land.
Section 3 - Supporting a prosperous rural economy
The smaller villages surrounding Leamington Spa have become commuter dormitories due to lack of infrastructure development and withdrawal of services. The proposed plan will set in motion their complete assimilation into the greater urban area.
The proposed development areas in Warwick University, Coventry Airport and Stoneleigh Park would afford the opportunity for local employment to some of these villages and negate the need for a large, counter-productive block of development to service them. This has obvious economic and ecological benefits.
I agree with the NPPF that there is a need for controlled rural development, it is needed in order to arrest the decline of rural communities, not to write them off completely and leave them years behind their urban cousins in order to maximize on private industry profitability.
Section 4 - Promoting Sustainable transport
Traffic on the Old Milverton and Kenilworth roads is already significant. The proposed northern relief road will do nothing but compound the poor placement of houses and park-and-ride by increasing traffic from north Leamington, through Old Milverton and through housing estates in Milverton where it already conflicts with pedestrian traffic of school children. Flow the other way will increase traffic from north and west Leamington to transport links off the A46 through the same areas.
Expanding the existing Kenilworth-Leamington road to dual carriageway will have a massive impact on long-standing greenbelt and increase traffic from the A46 through Blackdown towards Stoneleigh-park and the routes above.
Development should be concentrated to the south of Leamington keeping the destinations of park and ride nearer to the rail links in Leamington and Warwick, motorway links, shopping, amenities and better transport links which all exist to the south.
This approach would support the NPPF's aims whilst allowing for the larger developments to be focused on land to the south of Leamington and other already brown-field sites. It would also add to the revitalization of Leamington's old town.
Section 5 - Supporting High Quality Communications Infrastructure
The proposed plan states that it has chosen to concentrate development in areas where transport, amenity, communication and recreation already exist. This is clearly not the case as the infrastructure developments in the greenbelt area are huge. They are designed solely to support the proposed expansion of the urban area.
The proposals contain no mention of improving transport infrastructures such as bus, and cycle routes outside of their urban expansion; no mention of high-speed broadband in outlying villages (particularly in green-belt) and only a slight nod in the direction of community led housing - without attempting to include affordable rural housing.
Green-belt in this case is a rural environment; one which is protected for the good of the character, appearance and health of the towns it surrounds. It also contains a working populous who are to be penalized for the sake of convenience and private company income.
One of these villages is now home to 3 generations of my family. I feel that providing a future for my children offering variety and opportunity rather than conurbation and limited options is something worth discussing properly.
Developments over the last 30 or so years have changed the face and character of this area completely. Their continuation is detrimental to the character, nature and vivacity of the area. I would hate to see The NPPF ignored to further add to the urban/rural division and creeping conurbation of the area inflicted by previous planning strategies.

Introduction and Context
This document has been developed by South Warwickshire NHS Foundation Trust to feedback on Warwick District Council's (WDC) Local Plan and Preferred Options in relation to the impact of any developments on Community and Acute Health Services' infrastructure.
South Warwickshire NHS Foundation Trust is the major provider of acute and community health services to the population of South Warwickshire and delivers services to patients from sites across the district;
* Warwick Hospital - This site houses the majority of the Trust's Acute Services including; Accident and Emergency services, Diagnostic and Pathology departments, Maternity and SCBU (Special Care Baby Unit), Main and Day Surgery Theatres together with an Intensive Care Unit and Coronary Care Unit.
* Stratford-upon-Avon Hospital - This is one of the Trust's community hospitals and it includes a minor injuries unit, outpatients department, radiology department and an intermediate care ward.
* Royal Leamington Spa Rehabilitation Hospital - This site offers rehabilitation services to adults and includes a Neuro-rehabilitation Unit together with a number of outpatient services.
* Ellen Badger Hospital - This community hospital has a 26 bedded ward which offers rehabilitation to patients to enable them to return to the community. In addition, a Day Hospital operates, which offers continuing rehabilitation and help with medicines management and reduced mobility. Due to its rural location, some out-patient appointments are also offered.
* Our community services teams operate out of a number of clinics, some of the larger ones include Saltisford House, Cape Road Clinic and the Orchard Centre.
In April 2011 the Trust acquired Warwickshire Community services as part of the Transforming Community Services initiative and, as a vertically integrated organisation, has already made good progress in establishing out-of-hospital services and pathways to deliver care closer to patients' homes. However, South Warwickshire's demographic growth and the ageing population have resulted in demand for Acute and Community health services increasing, creating capacity pressures for the Trust and challenging commissioner aspirations to reduce hospital beds on the back of increased disability free life expectancy assumptions.
Current Capacity and Infrastructure Requirements to meet Population Demand
During 2011/12, South Warwickshire NHS Foundation Trust's acute services saw in excess of 300,000 outpatient appointments and 55,000 patient admissions. 26,000 of the patients admitted during the year were registered to GPs within Warwick District, occupying an average of 216 acute hospital beds. The highest user group of hospital beds from the Warwick District were the over 80 year old patients, occupying nearly 100 beds as a result of an emergency admission. It is evident from increased demand from this patient cohort that, whilst our growing elderly population are living longer, they are not necessarily living well for longer. The Trust has been working with health and social partners to develop and implement new pathways and services for the elderly population. These are already being delivered in the Stratford District and have resulted in reduced admission rates per head of population. It is expected that these pathways and services are transferable to Warwick District to achieve the same benefits.
Vision for Acute and Community Health Services in Warwick District
Our vision is "to provide high quality, clinically and cost effective NHS healthcare services that meet the needs of our patients and the communities that we serve" which we aim to deliver through service underpinned by the following values;
1. We place the care and safety of patients and users as our first priority.
2. We will provide the best possible patient and user experience in every aspect of service delivery and aspire to deliver excellent outcomes.
3. The facilities that we run will be comfortable and clean and we will use effective techniques and technologies delivered by senior experienced and capable staff.
4. We are committed to the highest standards of honesty, openness and accountability in the way we carry out our public duties.
5. We want our staff to feel pride and satisfaction from their work, to work in a safe environment in an open and supportive team working culture that enables them to perform at their best, innovate and develop.
6. We will engage constructively with General Practice and other partner organisations and stakeholders to develop seamless, efficient services that respond to public priorities.
Scenario Modelling
Following on from work initiated by the Arden Cluster to understand acute hospital capacity requirements for the future, we have further developed the Cluster's capacity modelling tool to support impact assessment of different population and service delivery scenarios. Our capacity requirements are predominantly driven by age specific admission rates and age specific hospital length of stay and these will vary by different admission type (i.e. emergency or planned care). We have applied each of the three population projections considered by WDC's Strategic Housing Market Assessment to our modelling tool over the plan period (2011-2031) to forecast future hospital bed requirements based on the expected age profile of the population and 2011/12 admission rates and length of stay.
The results of these three projections are as follows;
Table 1 Summary of Projections 2011-2031
Table here

The implication of the three projections on acute capacity requirements over the plan period ranges from an additional 70 to 113 hospital beds.
Infrastructure Proposals
As a result of our modelling, we have considered our infrastructure requirements to deliver Acute and Community health services to match the health needs of the population growth associated with the three projections. Assuming we are able to accommodate 23 beds in a ward, we will require an additional 3 to 5 wards. Current Health Building Note (HBN) regulations require a 1395 m2 footprint per ward and current HBN compliant build costs, as detailed in the 2010 Healthcare Premises Cost Guides are in the region of £3,820,00 per ward.
We have also considered our infrastructure requirements if the new pathways and services we are developing in our Community Services successfully mitigate some of the impact of population growth on hospital beds. Based on Healthcare Premises Best Practice Guidance, we will require assessment, treatment and therapy rooms, office accommodation and storage equivalent to 1327 m2 for each ward we do not need to build.

Town's Position
Kenilworth is situated in close proximity to the boundary of Coventry and in places, the Green Belt is less than 600 metres wide. The protection of the Green Belt as a whole, and in particular on the Coventry border, has always been a matter of great importance to the Town Council and it has made this a priority over a number of previous Local Plan consultations.
The population of the Town has grown by 140% in the last 40 years and this has led to the whole of the available land within its boundaries being used for additional housing. This has included in recent years land zoned for employment, as the District had accepted that there was no demand for some of the existing employment land.
Given the tremendous increase in population and the lack of demand for employment land, it was the view of this Council on the previous (subsequently withdrawn) consultation on the preferred options, that there was a clear case for there being no further development within the Town. This was vitally important, as any development that was allowed had to be on the Green Belt surrounding the Town. Those arguments are, we believe, still valid, especially as it is apparent from the Options paper that there are areas of land within the District that are not within the Green Belt, but which it does not intend to zone for development.
The Preferred Options do include land available for development that is not within the Green Belt. It is the Council's view that this should be reflected by requiring the phasing of developments to ensure that non Green Belt land is developed first. In this way, the existence and benefits of the current Green Belt would be extended.
District Council Position
The Town Council does, however, recognise that the District has put forward arguments, supported by the SHLAA and SHMAA surveys, that the Town does require now, and in the next 20 years, a certain amount of housing and employment land, for it to remain sustainable and viable; these will inevitably be in the Green Belt. It further appreciates that, if such developments were to be allowed to proceed, then it is necessary and essential that these should be carried out in the right place and subject to regulation that would enhance the Town and not damage it.
It is further aware, and accepts that it is the view of the District Council and the surveys carried out, that this would mean the addition of some 700/800 houses and provision for employment land and that it proposes that this development should be in the Thickthorn area.
Town Preferences
So that it assimilates better into the Kenilworth community, it is the Town preference that development of such magnitude should be distributed instead of being concentrated on one site. Such an approach would also assist in alleviating the disruption to the town's infrastructure that the planned block development would create.
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With this in mind, we have considered a variety of sites within the Town and since the areas available are all within the Green Belt, have tested those sites on the basis that the following requirements should be met:
1. It must be capable of being protected from further extension by having clear and defendable boundaries.
2. There should be clear separation from any other urban areas so as to avoid ribbon development.
3. It should be capable of having easy access to the Town.
4. It should complement the local community and not form a separate entity.
We applied these tests to the sites we had identified. Overall, we concluded that they would suffer from the major problem, not only of incursion into the Green Belt, but also of lacking defendable boundaries for the future.
Preferred Option Land
We also considered the Thickthorn site on the same requirements basis as described above.
This site has for many years been in danger of exclusion from the Green Belt. On all previous occasions, development has been opposed by the Council because of the danger of opening up the whole of the area bounded by Kenilworth, the highway and Stoneleigh Road.
Our view in regard to this site was as follows:
1. The northern extremity of the proposed development area is shown as the northern boundary of the Wardens Cricket Club. This was felt to be too far in a northerly direction, whilst there was no clear and defensible boundary to protect the Green Belt from further incursion to the north.
2. It would result in the loss of the Cricket Club and Rugby Club and its four training pitches, with the need to relocate them in the Green Belt if they are not to be lost to the Town.
3. This would also effectively double the loss of Green Belt in the Town area if, as we would wish, they were relocated adjacent to the Town.
4. The roads serving this area are subject to considerable congestion now. The addition of perhaps 700/800 houses and business use would add considerably to an existing problem, especially at the Thickthorn Junction, which is a major access point to the Town and its main connection to the dual carriageway.
Whilst we would not wish this area to be developed, we appreciate that the District has this in mind and, if development is to take place in that area, then it would be essential that:
1. The development should terminate at Rockey Lane in order to have a clearly defensible boundary.
2. This would allow the Rugby Club to relocate its number one pitch and Club house to the Cowpatch (being the field to the north of Rockey Lane) and the Cricket Club to
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remain in its current location, which it is understood, would be the Cricket Club's preference. These two grounds within the Green Belt, together with Rockey Lane, would then serve as buffer to development, as well as providing for open space and retaining the very important sporting facilities they provide for the Town.
3. We are aware, however, that the Rugby Club would have difficulty in relocating all of its facilities onto the Cowpatch.
4. If, in those circumstances, it was felt that the inclusion of the Cowpatch should be allowed then the protection of the Green Belt required by the Town Council could be obtained by the dedication of a public open space adjacent to the Cricket Club's southern boundary. This would not only protect the Green Belt but also act as protection to the Cricket Club from being too close to housing.
5. The inevitable traffic congestion at the entrances to this area require very specific planning provisions and, without definitive assurances in the Plan not to increase vehicular movements along Glasshouse Lane West and Birches Lane, then the Town Council would object to the site as a whole
6. There would be a clear need for road improvements at both the Leamington Road and Dalehouse Lane junctions to ease traffic flows. These would need to include the widening of Leamington Road, certainly in the area of the junction, and perhaps the widening of the slip road into the junction, allowing for traffic from the new estate direct access to the highway. Likewise, careful attention would be required at the Dalehouse Lane junction in order to have the same effect and the provision of an island should be considered to ease traffic flows at that access point. Having regard to the importance of these matters, it should be a condition of any development that the road works are carried out in accordance with traffic surveys and a modelling of the effects of the development should be carried out in advance.
7. The internal roads and infrastructure of the area will be equally important. Having regard to the size of the proposals there is a real danger of it being developed piece meal and by different developers. This could lead, as elsewhere in the Town, to the overall theme being distorted. It should therefore be built into the Plan that there should be an overall planning brief agreed before any development is started and that this shall be carried through.
8. Any development on the site would need to meet the requirements of the Plan for Garden Town type layouts, together with the need for the provision of open space, and a road layout that complements these requirements.
9. We feel it will also be necessary to make provision for a Primary School. For the purposes of safety and sustainability, this should be within the site thus allowing children to walk to School where possible.
10. The Local Plan presents an opportunity to include an Inset Plan that takes into account all these requirements. The Planning Department of Warwick District Council should provide a brief on the basis of these requirements, which should form part of the Plan, to assist in the development of the site as part of the local community and a complement to it.
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Effects on the Local Community
These must be taken into account, as the presence of the Town and its facilities are the main reason for making this area so attractive for development and will have a huge effect on its value.
In these circumstances, it is essential for facilities to be expanded and improved to cater for the new development as well as easing the strain on those already existing. This requirement will not only benefit the existing community, but also conserve those facilities and make the Town more attractive.
With this in mind we would expect that funds arising from the development should be provided to help the aspirations of the Town for the expansion of the Civic Centre to include all facilities, including a Theatre.
Further the introduction of 700/800 houses, whilst making the Town Centre more viable, will increase the burden on the Town Centre car parks and would merit the construction of a car park similar to the Waitrose model, namely one and a half storeys.
It will also require the provision of addition medical services by way of at least one more Doctor accompanied by the nursing services that the Surgeries now provide. This will mean that both surgeries serving the Town will require some extension. There will also be further pressure on the Clinic, which will require enhancement to enable it to serve the additional population.
The Rugby Club
The Rugby Club is a very valuable asset to the Community and if it is to be relocated then it is essential to the community that this is adjacent to the Town. This could provide an opportunity for the District to make provision for it at Castle Farm. The opportunity for joint working with the Club could provide an enhanced sporting offer that not only includes Rugby and the current pursuits, but also an Athletics Track. There would be a need to increase the area of the sports centre and this would fall within the Green Belt. It would, however, be immediately adjacent and accessible and to some degree within the Town. The increase of this existing use within the Green Belt would complement the Town.
Open Spaces
There is a need to increase the area of accessible open space within the Town. This is a matter that must also be addressed within the Plan. Whilst the Abbey Fields and Castle Farm and the Common give an impression of the Town enjoying a great deal of open space, Kenilworth does not enjoy as much open space as the other Towns within the District. Even taking into account the Play Area at Burton Green and Crackley Woods, both of which are outside the Town, the area available per 1000 of the population is 4.42 hectares as against the District average of 5.46 hectares and the Proposed Minimum Standard in SPD of 5.66 hectares.
Allotments
The Town and its Community enjoys several allotment gardens that not only provide an ability to grow vegetables and fruit for home consumption, but also the opportunity to enjoy outdoor exercise and recreation, whilst at the same time providing an additional open space for the community.
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The allotments are invaluable to the town and extremely popular, confirmed by the waiting list of 200 applicants, despite additional plots being provided in the last few years. It is essential therefore that an allocation of allotment land be found within the plan to meet and encourage this demand, especially as it will provide the further benefit of further open space.
This problem must be addressed in the new development and for the Town as a whole in the Plan. The provision of additional open space at Castle Farm would be a very useful additional contribution.
The Mere
We are awaiting the results of the feasibility study for the renewal of the Mere adjoining the Castle. This exciting project, adjoining an internationally recognised heritage site, would bring increased economic benefit into the area, as it would make the Town a National Tourist attraction with its Castle and Mere. Further, the additional amenity would enhance the open space available to the community and visitors.
Abbey Fields
Overview. The Abbey Fields are and have been for many years an invaluable centre for peaceful, open-air recreation that is easily accessible from all parts of the Town. We would stress that any Plan affecting the Town should ensure that no encroachment should either be allowed or envisaged. It was, and always has been, used for recreation for the community and children and any intrusion will conflict with those uses. No vehicles or cycles should be allowed within its confines other than for the provision of essential services or maintenance.
Cycle Routes through Abbey Fields. The Town Council would object strongly to the provision of a cycle route through the Fields, as this is contrary to the use envisaged for the fields since they were dedicated to the Town. Furthermore, it would be contrary to the byelaws that currently protect them from such use and which were imposed for the sites protection. Any such intrusion would inevitably conflict with people using the paths and the many children seeking recreation in the Fields; it would be impossible to police from abuse.
The Abbey Fields Play Area. The Council would, however, see some elements of evolution of the current usage as being advantageous and in keeping with the original grants. The Children's Play Area is in need of renovation, as is accepted by the District. When this is able to proceed, it is suggested that this would be an ideal time to reposition it on the bowling green area, which has been redundant for many years. This would provide a secure area for the Play Area and the existing Pavilion could be used as a shelter for accompanying parents. A further benefit of the secure area thus provided would be the exclusion of dogs from the play area.
The Play Area released by this relocation would allow for the expansion of the picnic area adjoining and the provision of a more formal site for the periodic Band Concerts. This would provide a better facility for the community and its visitors and be a better use of the Fields without in any way damaging them or being contrary to the original gift and purpose. It would also enhance the setting of the Barn Museum and improve it as an attraction.
Abbey Fields Car Park. The Town Council has considered and approved the proposed resurfacing of the car park in the fields, subject to such work complying with the advice of English Heritage to protect the underlying monument, and work being included to protect the trees in the Lime Walk.
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The trees form an invaluable asset to the Fields. Relocating the boundary of the parking area away from them and releasing the compaction around their roots caused by parking will improve their life span, although this raises the issue of their age. During the currency of the plan, preparations must be made for their replacement and the preservation of this beautiful part of the Abbey Fields. This should form part of the Plan, as the future of the Walk must be assured for future generations.
The existence of the car park does, however, affect the drainage of the meadow below it and this must be addressed. The meadow below, a very important part of the fields, currently suffers from bad drainage and frequent flooding. This must be improved to increase the recreational use of the area.
Civic Centre
It has been the joint wish of the Town and the District Councils to develop a Civic Centre in Smalley Place. This has begun to take place over the last few years with the relocation of the One Stop Shop to the Library and, latterly, the Town Council, MP, and Town Centre Development Manager, as well as the local Safer Neighbourhood Police Office, to Jubilee House.
It is the clear desire of the local authorities that this process will continue, in the hope that all the services required by the Public shall be available from that site or at least accessible. Further, we would like to see the relocation of the Talisman Theatre to the same area on the basis that this would also provide a venue, not only for the theatre, but also perhaps for use as an occasional Cinema and Meeting Hall in the centre of Town. The relocation of the Theatre would also provide a site for further housing.
There would also be the opportunity for the relocation of the Clinic into Jubilee House. This would provide patients and staff with enhanced accommodation and at the same time release its current site for redevelopment in accordance with the overall plan for the centre. An arrangement of this type would be in keeping with the objective of providing all services to the Community on one site and at the same time would lead to cost savings for the public purse.
This plan would, in our view, be an ideal project to seek support from the monies arising from the developments envisaged in the Local Plan. These facilities will complement and improve the facilities that the Town already enjoys, but would also be available to the persons who relocate to the new areas of the town.
Fire Station
The provision of employment land at Thickthorn could perhaps provide an opportunity to relocate the Fire Station as its current situation is not ideal. Its relocation at Thickthorn would provide an opportunity to build a full-time Station that would be easily accessible to the whole District along the existing and adjacent routes. This would be an advantage to the public purse as this could easily serve the whole District and release the current sites for other purposes.
Schools
As mentioned previously, it will be necessary for a Primary School to be provided for the children of the 700/800 houses likely to be built on the site and this must be provided within the development.
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There will also be additional pressure on the Secondary School at Kenilworth School and it will be necessary for this to be enhanced for that purpose. Kenilworth School is presently housed on two sites, with the Sixth Form located in Rouncil Lane. This might, therefore, be an opportunity for the Sixth Form to be relocated to Leyes Lane and the other site utilized for housing, as it has access already on to local roads and much of the school site is not used. The income generated would provide an opportunity to reinvest and enhance our Secondary School.
Further, the release of this area for housing would compensate for the loss of the area from the Cricket Club from the Preferred Option Plan area.
Railway Station
Finally, Kenilworth has a population in the region of 25,000 and as such must be one, if not the only Town of this size in the country, which does not have the benefit of a Railway Station. Warwickshire County Council has prepared a strong business case for the reintroduction of a Station upon the former station site at the junction of Waverley Road and Priory Road. The additional population that will result from the new development proposals can only strengthen the case already made for a new Station; the Council feels strongly that the suggested site should be included in the Plan. Additionally, it should be shown as a major objective of the Plan and an essential part of its future sustainability.

Thank you for providing English Heritage with the opportunity to further comment on this evolving strategic plan for the District. This correspondence will regrettably reiterate certain points made in previous letters dated 9 April 2010 and 5 July 2011; both are therefore attached for your information.
As the government's adviser for the historic environment, English Heritage broadly welcomes the positive strategy set out in section 11, and in particular Objectives 7 and 14 of the Plan.
I note a recognition in the Plan of the pressure for new development threatens the "highquality
built and natural environments in the district, particularly historic areas"1 but however goes on to reassure that 10,800 new homes (to 2029) will be founded on "best evidence"2 and located in the most suitable locations3 to help ensure the historic environment is then protected and enhanced4.
The National Planning Policy Framework (NPPF) provides the context and justification for doing so, requiring Local Plans to be prepared with the objective of contributing to the achievement of sustainable development in accordance with the principles and policies for the historic environment.5
The following comments on a number of the proposed allocations unfortunately highlight an inconsistency with the above:
1 WLP PO Paragraph 4.8 point 6
2 WLP PO Paragraph 5.1
3 WLP PO Paragraph 7.6 "In addressing the important housing issues, the Local Plan will aim to...provide well-designed new developments in the most suitable location".
4 WLP PO Paragraph 4.6
"To protect and maintain the character of the District, the Local Plan will have to balance the growth of the District with the protection and enhancement of these assets".
5 NPPF Paragraph 151
2
Site D Land south of Gallows Hill, Warwick
Key assets affected - Warwick Castle Park Grade I Registered Park and Garden; Warwick
Castle Grade I Listed Building; Warwick Conservation Area
In comparison to all the nine sites assessed in the Landscape Character Assessment for
Land South of Warwick (Richard Morrish Associates, 2009 - Referred to herein as the LCA Report), the site to the south of Gallows Hill is described as being the area of highest relative value to the setting of Warwick. It is the only site that is considered to be unacceptable in principle.
"This is generally an area of well maintained agricultural land that is important to the setting of Castle Park and prominent in approaches to Warwick. We feel it should be safeguarded from development". Paragraph 5.4 LCA Report
"Warwick and Leamington Spa have highly-valued historic cores and Warwick Castle and the associated Castle Park have national heritage significance. Protecting the setting of these features must be considered a principal goal of future development planning in the locality".
Paragraph 5.1 LCA Report
It is needless to say any proposal which harms heritage assets of such national significance to such a degree is contrary to the NPPF6 and the principles of sustainable development.
The harm is not outweighed by the public benefit associated with this housing development.
It should be noted that the LCA Report does not refer to either the Historic Environment Record or the Warwick CA Appraisal; and it preceded the publication of the NPPF (March 2012);The Setting of Heritage Assets - English Heritage Guidance (October 2010); The Warwickshire Historic Landscape Characterisation (HLC) Report (WCC 2011)7; and the Conservation Plan for the park. If applied these are likely to reaffirm the sensitivity of the site and the unsuitability of the allocation.
Site WL5a Loes Farm, Warwick (Guy's Cliffe)
The draft local plan fails to have adequately considered the impact on designated and undesignated heritage assets to determine the suitability of the allocation. The proposal would appear likely to cause substantial harm to undesignated heritage assets of significant value, and harm to the setting of designated assets that contribute to that assets significance. This would be contrary to the NPPF and the great weight that should be afforded the conservation of heritage assets.
I refer to my letter dated 10 April 2010.
"You should ensure that thorough evidence is applied to determine whether the proposal would adversely affect the significance of the designated historic landscape and its setting including key views in and out. The direct and indirect impacts of major new development on the individual components that determine the relative value of Guy's Cliffe in total should be understood.
English Heritage considers that the well preserved areas of ridge and furrow should certainly be regarded as of national importance and preserved as a consequence, see:-
http://www.english-heritage.org.uk/upload/pdf/turning_plough.pdf?1267377944 "
The NPPF is clear that a draft local plan may be considered unsound if there has been no proper assessment of the significance of heritage assets in the area, including their settings,
6 NPPF paragraph 132
7 NPPF paragraph 170
3
and of the potential for finding new sites of archaeological or historic interest8, or, there has been no proper assessment to identify land where development would be inappropriate because of its historic significance.9
The Joint Green Belt Review recommends that to determine site suitability "finer grained, more detailed analysis" should be undertaken including the consideration of "Archaeological Constraints; Character, Setting; and Historic Landscape Character Analysis"10. This appears not to have been undertaken.
Site K5 south east Kenilworth
Previous correspondence highlighted the need to consider the evident significance of the adjacent Stoneleigh Abbey and designated Glasshouse Roman settlement, and the potential for further archaeology. Has this evidence been addressed?
Any future development would certainly need to protect the scheduled archaeology and its setting and that of the Grade II* registered Stoneleigh Abbey Park.
Coventry and Warwickshire Gateway - Baginton
The scale and form of any future development here is currently unclear. However it should be noted that the area includes designated and undesignated heritage assets of great importance. In accordance with the national policy expectations referred to above, a specific historic environment assessment must be undertaken to fully understand the landscape's special historic interest, the locations of particular historic significance and sensitivity. This can in turn inform the areas capacity, where development may best take place and what form
it might take.
Section 11. The Historic Environment
One of the twelve principal objectives for planning in the NPPF is the conservation of heritage assets for the quality of life they bring to this and future generations11.
Conservation means maintaining what is important about a place and improving it where this is desirable. This is not a passive exercise. Consequently we welcome the proactive approach you intend to take.
To compliment these measures might I suggest the Plan also address and target specific environmental improvements; the assets within the area on the heritage at risk register and the opportunity afforded by CIL/S106 agreements.
I note paragraph 5.1 of the LCR Report. "In addition and particularly as the towns are important tourist destinations, the quality of approaches to the town should be considered in all development planning. A combination of protection of landscape assets and enhancement or removal of landscape detractors should be considered in strategic planning".
Might the enhancement of the public realm be linked to creating an attractive environment for businesses and visitors? I refer to paragraph 14.18. How will the Local Plan compliment and help deliver the Warwickshire LTPs intention to "improve the quality of transport integration into streetscapes and the urban environment"?
Are there specific opportunities to demonstrate how CIL/S106 agreements could contribute towards the enhancement of individual assets or specific historic places, particular streets, spaces and the public realm?
8 NPPF paragraph 169
9 NPPF paragraph 157, seventh bullet-point.
10 Joint Green Belt Review paragraph 5.4.2/3
11 NPPF paragraph 17
4
Might the Plan address the particular issues identified during the development of the evidence base, including the ten monuments, four buildings and two parks on the national heritage at risk register?
Section 15 -Green Infrastructure appears to provide the 'bench mark' for a thorough and proactive strategy. I would be welcome the opportunity to help support a further refinement of Section 11 to achieve a similar comprehensive iteration.

Scanned Response Form

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.

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

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

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.

On behalf of the Federation of Small Businesses in Coventry, Warwickshire and Solihull this paper responds to the consultation on Warwick District Councils Local Plan.

The FSB is the UK's largest business support organisation with 200,000 members nationally and 3,000 of those members in Coventry & Warwickshire.

FSB Warwickshire & Coventry response:
Despite the economy falling back into recession small business confidence levels remain positive, but we aren't out of the woods yet. Small firms still face challenges from weak demand and rising costs. In spite of these challenges, many small firms want to grow. Warwick District Council must put long-term measures in place to instil this optimism - in turn the economy can grow.

Planning:
The planning system is a constraint on small businesses. Unlike major infrastructure providers or large businesses, they often need only minor changes to their premises in order to diversify and grow. Almost half of our members have found the planning system complex and difficult to understand, while nearly 40 per cent said that it was a costly process. So, the planning process must be made much simpler, quicker and cheaper for small firms. This must be complemented by robust protections for businesses in existing town and commercial centres. We welcome Warwick District Council's commitment to a strong expression of 'Town Centre First' policy and recommend that;

* Planning policy must take into account the needs of small businesses.
* There should be a range of affordable local business premises available, both to encourage new enterprises and allow existing businesses to grow.
* Measures are needed that would allow planners to refuse any out of town application that would draw business activity away from the town centre.
* Planning permission should be designed to positively encourage development of appropriate business premises in town centres.
* Provide timely advice for businesses wanting to build or expand their premises. Obtaining planning permission is often a minefield.

Housing
The provision of affordable housing in order to help address skilled labour market concerns should be central to the council's local plan.

The costs of housing, transport and daily life are often higher in rural areas, and in some places the presence of a disproportionate number of retirees and properties used as second homes have exacerbated this situation, causing house prices in rural areas to rise. Yet this has not been met by corresponding rises in rural wages, which are often lower than in urban areas. This has led to a serious labour market imbalance in some areas, which needs to be addressed. Your housing policy must redress the balance and secure a bigger supply of affordable properties as a priority.

Broadband:
It shouldn't matter where a business is located. With the technology we have today all firms should be able to trade overseas, throughout the UK, and from town to village. However, our research shows that six in 10 (63%) of small firms are suffering with the speed of their broadband. Another 34 per cent are unhappy with the reliability of their connection and a quarter (24%) with the value for money. This blocks the growth of businesses. Rural firms and households have had even longer problems with accessing broadband and slow speeds. To close the digital gap between rural and urban firms, we feel 20Mbps superfast broadband should be available across the countryside. Warwick District Council must consider fast and reliable broadband within their development and growth plans for the District.

Rural Economies:
Our rural economies have the potential to make a huge contribution to economic growth, but only given the right conditions. The rural economy is dominated by small businesses but they struggle against the odds of poor communication, unreliable broadband services and patchy transport services. These exacerbate the distance they are from their markets. Rolling out broadband in all rural areas and looking strategically at transport will ensure that these businesses can grow and prosper home and abroad.

Market towns and village centres have also declined with the closure of anchor businesses such as the village pub and post office. Warwick District Council must consider the community infrastructure when developing new housing sites and how they will be integrated with the business community.

Transport & Parking:
The provision of suitable public transport links is crucial to helping small businesses access markets. Reliable and frequent public transport makes it practical for employees to seek work in the local community without having use of a car. Likewise, frequent rail and bus services bring customers and tourists to local businesses such as shops, hotels and B&Bs.

Those living and working in rural areas face a far greater challenge getting from A to B than their urban counterparts. Indeed, on average, people living in the most rural areas travelled 45 per cent further per year than those in England as a whole and 53 per cent further than those who are based in urban areas.

The need to travel greater distances means efficient transport links and infrastructure is essential to realising the potential of business economies. It is crucial that firms are served by a transport network that allows both individuals and small businesses too effectively and efficiently move goods and people, both within rural areas and, importantly, urban areas where larger, more diverse markets often lie. The added benefit of good transport services is that it will attract additional visitors and their spending power to local economies. Warwick District Council must consider suitable public transport links when developing new housing & business sites.

There is a clear correlation between short term revenue driven parking policies and the closure of businesses on the high street. Therefore parking should be seen as a vital service which is an integral part of transport policy not as a quick means of raising revenue. Parking policies are all too often a short-term revenue grab, to the detriment of business and the wider community, and ultimately lead to longer term decline in revenue generation for local authorities.

In responding to the 2011 consultation, the Town Council indicated support for Scenario 1, which was to provide 3750 new homes on greenfield sites and to allocate 60 hectares of employment land.

This view was the preferred single option of those responding to the consultation, despite attempts to demonstrate evidence to the contrary, to allow for the District to put forward a much greater annual housing development figure.

In supporting Scenario 1 the Town Council accepted that the number of homes to be built would increase from 3750, to reflect the development of windfall and brownfield sites, but urged that the District Council should clearly identify the realistic population growth for the District and that an evaluation of housing and employment land needs, should be dictated by that appraisal.

Regrettably that approach has not been adopted by the District Council and the population projection for the Local Plan period is very close to that put forward in the Core Strategy. A figure of some 40,000 additional population, which was deemed to be unrealistic by the District Council.

Indeed, it was the Town Council's understanding that the District welcomed the government's decision, supported by our MP, to abandon the Core Strategy to allow for a Local Plan which would produce a blend of housing that would meet local needs, and especially the provision of social and affordable family homes, and reflect the aspirations and housing needs of local people.

The Local Plan would also need to recognise the existing shortfall in the infrastructure in the District, which had failed to keep pace with the high levels of development and population growth in the last decade, in addition to provision the infrastructure including transport, educational & health needs, roads and sewers to meet proposals within the development in the plan period.

The Town Council had suggested that in particular, to address the reliance on the car, with resultant issues of traffic congestion and pollution, consideration should be given to development in proximity to railway stations at Warwick Parkway, Hatton and Lapworth and given the planned new station, that Kenilworth should also be considered, including sites at Glass House Lane and Crewe Lane.

To avoid the creation of urban sprawl the Town Council also recommended that the greenfield areas between the towns should also be retained and such action would also retain the historic and natural boundaries between towns, thus preserving and distinguishing identities of the Districts communities.

Such a policy would meet local need, and equally importantly, avoid a disproportionate impact, on particular residents and communities. The policy would also serve to reduce the levels of infrastructure required to support large scale development, and avoid coalescence and the creation of urban sprawl.

The proposals now put forward by the District Council are not based upon a realistic population growth, and considerably exceed the population estimate forecasts put forward by Warwickshire County Council. Rather the figures are assumptions, adopted by the District Council to justify a level of housing development, which are as great as those put forward by the 'Core Strategy'. The proposed population figures, resulting from the assumptions, are dependent upon high levels of inward migration, based upon previous peaks, without any qualified analysis, and which at the same time accept that the past level of high migration, reflected and were dependent, upon the high number of houses being built in the District.

The sites chosen for development in Warwick were substantially rejected within the Core Strategy consultation and it is both disappointing and surprising that the District Council should have so little regard for community opinion that almost 37% of all development proposed in the District, during the plan period, should be allocated to Warwick and also on those sites rejected in the Core Strategy consultation. Such development, it is accepted will generate high levels of infrastructural needs, in respect of transport, including a new river bridge, education and health needs and roads & sewers. The development which will of itself further increase traffic congestion, creating even higher levels of nitrogen dioxide in the Town Centre, which currently exceed the levels approved in the Air Quality Regulation 2008. Thus, the Local Plan Option will increase traffic and create even higher levels of NO2 emissions, and in doing so will be contrary government policy with regard to air pollution.

The Town Council therefore seek to object to the Local Plan proposals on the grounds that:

1) The projected housing development over the planned period are based upon
assumptions of population growth, which are not supported by population estimates and which reflect the Core Strategy population figures, which the District Council have previously considered unrealistic.

2) The development sites are not spread throughout the District in order to meet local need, and concentrate development on sites previously rejected by local communities and very much reflect developer preference.

3) The Plan does not accept that the quality of life and the environment should be guiding factors of the Local Plan and not levels of growth which cannot be absorbed by communities.

4) The Plan does not allocate development to sites which have local support or distribute development proportionally throughout the District to recognise local need, thereby avoiding any single community or locality being subject to the disproportionate impact of development.

5) The proposals do not clearly identify infrastructure needed to support proposed development or avoid detrimental impact of large scale development
upon existing communities and areas of the District, and fail to recognise the existing infrastructure problems.

6) The proposals should reduce the development to levels which can be justified by local population increase and local needs, rather than seeking to maximise development to generate income levels and developer aspirations.

7) The Local Plan proposals do not seek to promote the development of brownfield sites to meet local need for social and affordable housing, but seeks to promote development to generate higher levels of inward migration.

8) The recommendations place a disproportionate level of development in Warwick, whilst not exploring sites elsewhere in the District.

9) The proposals ignore how properties yet to be built, within existing planning permissions, will contribute to housing provision in the period of the Local Plan.

See attached letter

See attached

The following comments are in response to the Draft Infrastructure Plan Appendix 2 Section 4.2 Education.

Barford St Peter's C of E Voluntary Aided Primary School

Barford primary school has a current admission number of 20 places which are consistently fully subscribed with 53 applications made for 2012-2013, of which 29 placed the school as first choice.
The proposed development of 100 houses will inevitably generate extra numbers of children to be accommodated by the school and the Preferred Options identifies the school to become a Single Form Entry school and hence accommodate 30 pupils per year/intake.
This is not possible with the current infrastructure and staffing levels. There needs to be a clear strategy to ensure adequate funding to provide essential provision of built infrastructure and staff to accommodate pupils generated from new housing whilst not disadvantaging current residents, pupils and their families.

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.

Whitnash Town Council respond to each of the Preferred Options in turn, and
make comments in respect of the Vision and Objectives.
Vision and Objectives
We broadly support the Vision and Objectives for the Local Plan, but reserve
our position on the level of housing supply, for the reasons set out in our
response to PO1 below.
PO1 - Level of Growth
In principle we agree that sufficient housing should be provided across the
District to meet future housing needs. However, we are unable to comment on
the proposed level of an average provision on 555 per annum on allocated
sites, plus windfalls, as housing numbers are an immensely technical issue.
Notwithstanding this, we are very concerned that Warwick District and
Coventry City Councils are failing to exercise their statutory Duty to Cooperate
under the Localism Act 2011 by not addressing the important matter
of cross-boundary housing need.
We are concerned that, in its current state, the proposed strategy will be
found to be "unsound" by the Inspector at the eventual Examination. This
could well result in additional housing provision having to be made, and this
would have clear implications for non-Green Belt areas, such as those
surrounding Whitnash.
We therefore urge the District Council to effectively exercise the Duty to Cooperate
with Coventry in respect of cross-boundary housing provision at this
WHITNASH TOWN COUNCIL
Franklin Road Town Clerk
Whitnash Mrs J A Mason
Warwickshire Email: jenny.mason@whitnashtowncouncil.gov.uk
CV31 2JH
Telephone and Fax: 01926 470394
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stage, therefore preventing the danger of the Local Plan being found
"unsound" in the future and the Council having to consequently revise its
strategy and land allocations.
PO2 - Community Infrastructure Levy
We fully support the District Council in seeking to introduce a CIL scheme as
the Town Council considers it vital that full and appropriate infrastructure
provision is made, in advance of development wherever possible. It is
essential, however, that the funds raised are used to develop infrastructure in
the areas where the impacts will be felt, irrespective of Town and Parish
administrative boundaries.
We look forward to seeing and commenting upon the Infrastructure Delivery
Plan in due course.
PO3 - Broad Location of Growth
We support the strategy to make Green Belt releases to the north of
Leamington. For the first time in many years, this will allow a spatial
rebalancing of the urban form and provide for significant development in areas
away from the southern edge of the Warwick/Leamington/Whitnash urban
area.
Apart from relieving some of the development pressure on the south, it also
represents sensible planning practice by creating a more rounded and
balanced urban area, enabling greater accessibility, especially for the town
centres, and should enable more effective transport planning through
maintaining a more compact urban form with Leamington and Warwick Town
Centres as two central hubs.
Past development allocations had resulted in Leamington Town Centre
becoming increasingly less "central" to the urban area as development
extended to the south. The proposed strategy ends this practice and is
therefore welcome.
PO4 - Distribution of Sites for Housing
At this Preferred Option stage, we do not have detailed proposals for any of
the sites covering, for example, access arrangements, amounts of
employment land, types and forms of community facilities to be provided, and
such like.
Therefore, we wholly reserve our position in respect of objection to, or support
for, any of the sites and we will make strong representations in this respect at
the Draft Local Plan stage.
However, we have a number of concerns in respect of several of the sites. We
draw these to the District Council's attention at this stage so they can be
addressed in formulating detailed proposals.
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Education Provision
A general comment we wish to make is that it is critical that detailed
consideration is given, up front, to the level and location of future school
provision, both Primary and Secondary.
In Whitnash we have suffered from the lack of provision of a Primary School
at Warwick Gates. The draft Development Brief included a school, but this
was subsequently deleted as the County Council, as LEA, took the view that a
better option was the expansion of the existing three schools in Whitnash. As
this was, in planning terms, "policy neutral", the District Council amended the
Development Brief accordingly and deleted the school site.
This has led to problems for the residents of Warwick Gates and we would
seek to ensure that such a situation does not arise again through this Local
Plan process.
Our comments on education more specifically related to individual sites as
follows.
Sites 2 and 3 - if these sites progress, these should be seen as incorporating
a possible location for a Secondary School.
Site 6 (Whitnash East) - we understand that access could only be achieved
through the Campion School site. We are concerned that the school should
remain viable and continue to be located where it is.
Site 10 (Warwick Gates Employment Land) - consideration should be given to
siting a Secondary School on this land, given its advantages in terms of
accessibility from across the south of the urban area. The opportunity should
also be taken to explore the siting of a Primary School on the site, to meet the
needs both of existing Warwick Gates residents and also the needs arising
from any additional housing, on the site itself or in the vicinity.
Site 2 - Myton Garden Suburb
Our concern in respect of this proposed allocation is that its development will
result in the coalescence of the three components of the urban area, Warwick,
Leamington and Whitnash. We consider that this will result in a loss of
individual identity for the three towns.
Site 3 - South of Gallows Hill
We raise the following concerns in relation to this site:
* The land is extremely prominent in the landscape and will be highly
visible when entering the urban area from the south
* The site does not represent a logical extension of the current urban
form. It is in no way "rounding off" and would constitute a "peninsula" of
development extending to the south
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* It would have a negative impact upon the setting of Warwick Castle
Park
Site 6 - Whitnash East
We raise the following concerns in respect of this site:
* We are not convinced that access to the site is feasible. Our
understanding is that the South Sydenham development constituted the
maximum number of dwellings that could be accommodated off a cul-de-sac.
Given that access to the site via Church Lane or Fieldgate Lane is clearly not
feasible, access would have to be achieved via land within Campion School.
As this would involve relocation of school buildings, we are sceptical that the
number of houses proposed could fund the necessary works required to
achieve this solution
* Given the above issue, and our earlier comments on the wider subject
of education provision, we do not wish to see the future location of Campion
School prejudiced by this development
* There are, in the immediate vicinity of the proposed site, substantial
areas of both historical and nature conservation interest. Any development
must not have an adverse impact on any of these cultural, historic and natural
heritage resources
* In the event that the site is developed, we would wish to ensure that
sufficient community facilities are provided within the development and also
that adequate footpath and cycleway links are provided between the
development and the existing community of Whitnash
Site 10 - Warwick Gates Employment Land
We raise the following concerns in respect of this site:
* The site appears to be proposed for development at an extremely low
density. We make this observation elsewhere in respect of other proposed
allocations. We are concerned that, to accommodate the projected housing
need, land is allocated at appropriately high density, thus reducing the overall
level of new land that is needed
* This site is currently a high quality employment land allocation and we
understand that a reason the land has not been developed is landowner
aspirations, rather than demand for such a site. It is essential that the Local
Plan provides a balanced supply of employment land to meet all sectors of
demand, if economic growth and prosperity is to be fostered. There is
currently no other site in the urban area that offers this amount of land area in
such an accessible location. We are therefore concerned at its proposed
reallocation from employment to housing
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Site 11 - Woodside Farm
We raise the following concerns in respect of this site:
* We fail to see how two access points could effectively be achieved to
this site. We do not consider access from Harbury Lane to be feasible due to
the existing road alignment. We doubt whether access could be achieved
from Tachbrook Road due to the proximity of the Ashford Road and Harbury
Lane junctions to the north and south of the site respectively. Construction of
a roundabout at the Tachbrook Road/Harbury lane junction would offer
potential for one access point, but we are concerned about the impact of such
construction on the important oak trees in the vicinity
* We also doubt whether the development could carry the cost of such
highways works. The option of gaining access via Landor Road is utterly
unacceptable due to the road alignment and lack of vehicle capacity.
Furthermore, it appears that physical access could only be gained through
demolition of existing buildings
* In the event that a single access point was sought, we consider that
this has the potential to isolate the housing from the existing community and
also lead to unnecessary and unsustainable vehicle movements
* The site would be highly prominent in the landscape - there is
therefore a concern about visual impact
* The presence of underground High Voltage electricity cables will limit
the site layout
* There is considerable local opposition to the proposed allocation of the
site. It is our duty as a Town Council to inform you of this high level of
opposition
Site 12 - Fieldgate Lane/Golf Lane
The raise the following concerns regarding this site:
* We consider there to be fundamental access problems and have
concerns about the capacity of the Coppice Road/Morris Drive and Whitnash
Road/Golf Lane junctions to accommodate the additional movements
generated by the development, especially at peak periods
* We are concerned that, at a proposed level of 90 dwellings, the site
density is too high. This would be a prestigious site and the proposed density
should reflect this. Our argument does not run contrary to that made in
respect of other sites, where we consider the density to be too low, as
provision needs to be made at varying densities to reflect different sectors of
the housing market. This includes provision of sheltered housing and singlestorey
dwellings on appropriate sites. This may or may not be the case at
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Fieldgate Lane, but should certainly be considered across the portfolio of
proposed housing allocations
PO5 - Affordable Housing
We support the provision of appropriate levels of affordable housing but would
seek this to be distributed across all sites to ensure the development of
socially balanced communities
PO6 - Mixed Communities and a Wide Choice of Homes
We support the Preferred Option PO6.
PO7 - Gypsies and Travellers
Given that Whitnash has experienced particular problems through unlawful
traveller encampments in recent years, we support the principle of the
Preferred Option of proper site provision
PO8 - Economy
We support the principles of PO8. However, we reiterate our concern that
appropriate levels of employment land should be provided, in the right places,
and this should constitute a balanced portfolio of sites to meet as wide a
variety of needs and demands as possible
PO9 - Retailing and Town Centres
We support the principles set out in PO9
PO10 - Built Environment
We support the principles set out in PO10
PO11 - Historic Environment
We support the principles set out in PO11
PO12 - Climate Change
We support the principles set out in PO12
We will seek to ensure that any future development in Whitnash seeks to
reduce the Town's overall carbon footprint through the application of
sustainable development and design principles
PO13 - Inclusive, Safe and Healthy Communities
We support the principles set out in PO13
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PO14 - Transport
We support the principles set out in PO14 with the exception of the section
relating to High Speed 2.
Whitnash Town Council neither objects to nor supports HS2
We urge the District Council to ensure that the final Infrastructure Delivery
Plan takes full account of public transport needs and the principles and
policies set out in Warwickshire County Council's Local Transport Plan 3
PO15 - Green Infrastructure
We support the principles set out in PO15
PO16 - Green Belt
We support the limited release of Green Belt sites as set out in PO16 as this
will create a more balanced and sustainable urban area and urban form
PO17 - Culture and Tourism
We support the principles set out in PO17
PO18 - Flooding and Water
We support the principles set out in PO18