PO2: Community Infrastructure Levy

If a levy is to be used, then it should be ring-fenced to pay for the needed infrastructure caused by the new building and NOT, as in the case of Warwick Gates, be subsumed into the council's budget. Our present difficulties with getting into Warwick or Leamington via Harbury Lane are proof that ignoring infrastructure causes delay and costs money in the long run.

Not only are you trying to railroad through changes that we are very opposd to, you also want us to pay for it- how is this democratic?

CIL would enable raised funds to be spent where of most benefit rather than being tied to specific developments as under the present system.

The levy should only be applied to those new homes built. One would assume that the current infrastructure services the current residents and hence is already paid for. An levy is an additional tax on existing residents!!

We are concerned that CIL charges will have a detrimental effect on specification levels and adversely affect design. Local infrastructure will be supported by increased numbers of rate payers.

The JPC has concerns over just how a CIL may be administered locally and believes that use of such funds must be in negotiation with the local (ie Parish and Town) councils

The whole approach to the provision of infrastructure is fundamentally flawed! Too many developments have been allowed in the past without providing adequate infrastructure - with the result that roads are congested, sewers are overloaded, and there are insufficient school places. I write with particular reference to Hampton Magna, but the same problems are almost certain to exist elsewhere. A levy on new developments is unlikely to provide adequarte infrastructure just for those developments, with no chance at all of addressing past inadequacies. We need to take a step back, and find a way of fixing existing problems before contemplating ANY new development. Otherwise, it's a vicious circle of more and more development to fund more infrastucture, but you never catch up. Remember the old woman who swallowed a fly?

Yet again all very well in theory, but didn't a similar thing happen with Chase Meadow. The developers paid for the absolutely unnecessary road humps along Jury St atc. Hmmm how is that inproving the infrastructure as a result of the development?

In principle we support a CIL but the funds must be allocated to specific areas, agreed during the planning process, for work identified both locally and District wide.

We support the option of a Community Infrastructure Levy, CIL, as a necessary means to provide a new infrastructure for the town of Kenilworth.As the only school in the town, we consider it a priority to provide education for all young persons in the locality. The school would need appropriate funding from the CIL to expand our capacity and provide suitable resources for the students living in the community. Without the CIL the school does not have the financial resources to meet the needs of an expanding community.

I support the general idea of CIL, but WDC must ensure that the funding is returned to and used within the affected community and not disappear into a general pot.

CIL will provide funds for the necessary infrastructure needed for new housing and employment developments. I support this provided that it is the council along with parish councils and NOT the developers who decide how the funds are spent.

There is a risk that the Council will encourage developemnt in areas where the value of such Levys is highest - for example where developers will achieve maximum returns on investment from sales. This translates directly into a pressure on the Council to encourage and maximise development in areas where for example House prices are highest such as the North side of Leamington. The Council will need to demonstrate that land is selected without influence from such factors. Encouraging development close to zones where House prices are high will provide the Council with the greatest potential for developer Levy and at the same time risk causing a lowering of values in the wealthiest areas: maximum benefit to the Council and town, minimum benefit to the nearest residents - looks like social engineering.

Good, but let's make sure it is used for worthwhile things. Who will be deciding where the money goes and what it will be used for? Obviously back into Community Infrastructure but what?

This is fine so long as the infrastructure is in place when the developement is initiated and not once it has been compleated.

We support principle of the development of a Community Infrastructure Levy for Warwick District, but wish to ensure that the development industry is properly represented in the CIL formulation. It is evident from the draft Local Plan that there misconceptions about the practicalities of delivering strategic development sites, for example seeking to impose an inappropriate phasing policy (paragraph 7.20 and PO:4). The development industry can assist the local planning authority and other stakeholders in formulating a robust CIL and this expectation of co-operation should be added to the policy.

To some exent it depends on the level at which the levy would be imposed and how the resulting funds would be administered and spent, but really I can't see why those who are going to profit from these developments shouldn't bear the costs of a). having to provide the underpinning infrastructure, and b). improving any parts of the existing infrastructure that will be adversely affected by the new developments, rather than WDC's having to impose a further tax on residents, some of whom might well be adversely affected by those new developments.

Developers do not 'contribute' to anything. All costs, including CIL go to the customer. If the cost is too high, fewer people can afford them. So it works against housing affordability. If CIL makes unit cost too high, the developer will not proceed. No homes, affordable or market will be built. Because developers are not confident in sales, sites that already have planning approvals have not started.
So, CIL needs to be at an affordable level for directly related costs, not for large costs of district wide traffic improvements, schools, parks etc., where the existing provision is deficient.

I support that developers should contribute to the cost of infrastructure BUT make sure that they do actually contribute and not make vague promises which they later rescind.

Good idea as long as it is actually carried through

COMMENT
The proposal to utilise a Community Infrastructure Levy (CIL) in the future to fund new infrastructure considered necessary for the delivery of planned growth in the District is supported in principle, although we reserve the right to comment on this once further details of the proposed charging rates, supported by an appropriate evidence base, are available for public consultation.

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

We have been advised to write to you re new objections to the Core Strategy Plan. Having studied the documentation we wish to object to the overall plan to build a further 8100 new homes in the Warwick district area and in particular the 2700 planned in the south of Warwick (P04 Distribution for Sites for Housing: Location 2 and 3).

The whole basis for the homes is population growth nationally. Imposing massive growth on an area with little expansion of employment would create greater numbers of people who would have to commute to work, much to the detriment of the area and a poor location of people. Warwick District has already seen much development recently, much of it to accommodate those moving from the urban areas of Coventry and Birmingham into a less dense area. Many of those still commute into Birmingham or London and if people are prepared to work in London and commute from the Warwick district this will do nothing to help keep the prices affordable for the locals who want to continue living here.

Warwick District population has in fact increased by 12% since 2000, which is approximately 2x the rate of increase for Warwickshire; 2x the national average increase, and over 3x the increase for West Midlands. (PO1 Level of Growth).

Warwick has therefore already been subject to significant recent Urban Fringe development and population expansion, a large proportion of which is in South Warwick where the majority of further development is now proposed. (PO1 Level of Growth).

As it stands, we wish to object specifically about the development zone 2 in the area of restraint to the west of Europa Way. This area was identified as an area of restraint at the time of the agreement of planning for the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa, to prevent the two towns becoming one urban sprawl.

There is likely to be considerable job creation towards Coventry (PO3 Broad Location of Growth), including up to 14,000 new jobs at the Coventry Gateway scheme. Therefore several extra thousand people per day will want to drive through Warwick, morning and evening, which would lock up the highly congested Myton Road, Banbury Road and Europa Way at peak times and also the road layout of historic Warwick. (PO14: Transport).

The suggested improvement to the junction to the end of Myton Road and Banbury Road is redundant. The bottle neck of the narrow historic Avon Bridge, constrained road layout and traffic


calming in the Town centre, means such provision would not ease the current backlog along Myton Road at peak times. (PO14: Transport).

The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and onto the M40 will have the opposite effect at the eastern end of Myton Road with the addition of Morrisons and the proposed trading estate and Aldi supermarket all exiting out onto the double roundabout system.

Development of this particular site will have a profound impact on the area where the roads are already gridlocked for a considerable period every day during school term, not to mention the excessive pollution that would be caused. It is currently possible to queue from the M40 into Leamington and the length of Myton Road in both directions with queues heading down the Banbury Road and Gallows Hill. Narrow side roads off Myton Road, in particular Myton Crescent, are blocked by parking making it difficult to negotiate these roads as the schools come out.

There is no capacity on these roads for another 1,500-2,000 cars to exit from this triangle at peak times and join the current traffic load plus, extra traffic from other proposed developments needing to use these routes at peak times. The access to Warwick and Leamington from the site would be queued back even at a fraction of the proposed development.

There is no capacity for extra cars at the stations in either Leamington or Warwick town centres for commuters. This means additional traffic driving through Warwick at peak times to Warwick Parkway.

Furthermore, the land West of Europa Way is an area of rich agricultural land which has been under the careful stewardship of the Oken and Henry VIII Trusts. There are wide green hedges providing habitats for many species including woodpeckers, buzzards, bats, foxes, the occasional deer, as well as newts, hedgehogs etc. (PO11 Historic environment, PO15 Green Infrastructure).

This is the type of area that should be being protected for recreation and education and healthy food to have a positive impact on the quality of people's lives with the traditional land-based activities such as agriculture, new tourism, leisure and recreational opportunities that require a countryside location. By building dwellings on this land, we will have no countryside left in the urban areas to make use of to support healthy lifestyles through ensuring sufficient land is made available to all for play, sport and recreation without travelling out of the area.

Development on the area of restraint threatens the local houses with flooding. At present, during heavy rain, the runoff is slowed by the pasture and crops. It backs up by the Malins and is relieved into the Myton School playing fields. At these times both ends of Myton Crescent become flooded with the current drainage system being unable to cope.

Property in Myton Crescent was flooded when development was carried out on the Trinity School site. Developing the Myton side of the site would threaten all of the houses south of Myton Road. (PO18 Flooding and Water).

The most disturbing consequence of the proposed development of sites 2 and 3 is the danger to Public Health as a result of exposure to dangerously high Nitrogen Dioxide (N02) levels. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. In 2012, air quality remains in breach of these regulations, and will become toxically high with the increased traffic volume resulting from the Local Plan preferred options. Please see weblink: http://aqma.defra.gov.uk/action-plans/WDC%20AQAP%202008.pdf. (PO12 Climate Change; PO14 Transport).

It was pointed out at the public meeting in 2009 that the areas designated to phase 3 at that time may not be needed for development in the future so why is this area, the worst area for infrastructural needs and more importantly an area of restraint put into the first phase for building?

This should, with immediate effect, be designated as the last site to be developed so as to protect this area until a viable alternative is found.

The further urban fringe development of Warwick is unsustainable with respect to saturated infrastructure, constrained historic town layout, and the existing Public Health danger that exists today as a consequence of high traffic volume.

Current infrastructure including town centre rail stations, schools, GP surgeries, sewage, water, drainage are at capacity with the current population, and will not sustain the proposed increased numbers within the Myton proposed sites 2 and 3. (PO2 Community Infrastructure levy).

Numbers have reduced drastically in schools over the years with those such as Trinity and North Leamington moving to smaller sites and a number of primary schools having given over part of their accommodation for other uses whilst village schools have closed completely. This means that the schools in this area are oversubscribed, including Myton in whose catchment area the whole of that site would fall.

There are suggestions that schools would be expanded or new builds created but a new primary school was in the plans for Warwick Gates which never came into fruition.

The hospital is completely surrounded by housing and has no capacity for expansion so how will they cope with another 25,000 people based on the figures of 2007 with 71% in a traditional family set up with 1.8 children.

Why do district councils have to accommodate a certain amount of housing? Should the government not just be looking for appropriate sites for building? At that same meeting in 2009 the suggestion of a perfect site around Gaydon was mentioned for a new town but the response was "It's not in Warwick District". Not only would road improvement be possible where air quality is not already in breach of regulation but this site is perfect for links to the M40 and there is also a rail station already at Kings Sutton on the main Birmingham to London line so commuting traffic would not be funnelled through Warwick's congested urban centre. To build one whole new site would be more cost effective in the long run. There is also the possibility of more use being made of the land around Warwick Parkway, which is in Warwick District and again perfect for rail and road links to both Birmingham and London.

So what can be done to accommodate the Core Strategy?

How about looking at sites already within the towns and regeneration areas? The infrastructure is already in place and could take out a large number of the dwellings required. We know this would not be chosen as great big swathes are cheapest but not necessarily the best option.

Build student accommodation near Warwick University in Coventry and return the hundreds of dwellings (including Station House with over 200 student flats) in the South Town of Leamington to private affordable starter homes and family homes.

Villages could be given their communities back - expand them with affordable housing. Let those that grew up in the villages and wish to remain there, stay there. Let them support the village schools and shops, some of which have closed over the past few years due to lack of numbers or use.


The original Strategy stated that 90% of the population live in the urban areas and 10% in rural areas. The paper work shows that the whole of the 8,100 houses still required are to be built in the urban areas. This will take the figures to 95-96% living in urban areas compared to 3-4% in the rural areas as there appears to be no allocation of any of this building to take place in villages.

The 90% of the district's population currently living in the urban areas occupy 10% of the district's land whilst the other 10% of the area's population live within the remaining 90% of the land.

The Core Strategy stated that there should be limited development within and adjoining villages so that they can be protected and the character of the villages kept. This is also the case within the towns. It is not that long ago that Whitnash was a village but is now a town along with Leamington, Warwick and Kenilworth. These towns want to remain separate towns. They do not want to become joined and eventually become part of Coventry as the way Edgebaston, Hall Green, Moseley and Sparkhill are to Birmingham.

Although the Core Strategy points out that the development will be directed towards the south of the urban area to avoid incursion into the West Midlands Green Belt area and hence becoming part of Coventry it is encouraging the joining of the towns of Leamington, Warwick and Whitnash, making it one urban sprawl.

It has been said that Warwick District in 2026 will be renowned for being "A mix of historic towns and villages set within an attractive rural landscape of open farmland and parklands, that have developed and grown in a way which has protected their individual characteristics and identities, ..." If this building work is allowed to go ahead as it stands, it will be far from that.

We also urge Warwick District Council to consider the overwhelming number of objections received from Warwick residents at the last consultation 2-3 years ago.

Scanned letter.

Scanned Response Form

Scanned Response Form

PO1 Preferred Level Of Growth

In summary we agree with the option for the Local Authority to go for a moderate growth. There may be evidence to suggest that higher growth is required but in these challenging economic times and the practical and political pressure the Local authority will be under in making this decision, we believe the moderate growth option is a more realistic and such a pragmatic approach is likely to be achievable.

PO2 Community Infrastructure Levy

We support the idea to bring in a CIL.
One item that is missing from the document is any indication towards New Homes Bonus. This is something we would support as a revenue stream and serve to reinforce your support for Affordable Homes (paid on non s106 schemes only). Again the NHB could be shown to assist in the provision for extra care (under PO5)

PO3 Broad Location of Growth

We support the Preferred option for Growth.

PO4 Distribution of Sites for Housing

We support the establishment of new boundaries. RSL's would like to be involved in discussions with Parish Councils from an early start to dispel the myths around affordable housing and this could assist the provision of housing in these areas.

PO5 Affordable Housing

We agree with the 40% affordable housing on new residential developments with the exception where the scheme is to be delivered as a 100% affordable housing scheme, in these cases the properties can be dealt with under a separate planning condition .
We agree with the housing being held in perpetuity but we would draw attention for a balance. In many cases RSL's will need to show a level of asset churn. The asset however can be ring-fenced to be used soley for the provision of future affordable housing in the district.

In rural terms we support a certain level of market housing but it should be on a case by case basis given the likely high land and sales values generated in many of the District's villages

There is no reference to new Affordable rents. The document does refer to affordability however, but with no mention of the level of affordable rents and with many areas of WDC the level of rents can vary greatly within a 1 mile radius (Micro Markets) Therefore we would recommend some primary data in the document to support your arguments.

PO6 Mixed Communities & Wide Choice Housing

Employment is very high on everyone's agenda currently and there are many threads that tie housing/ construction to this. There are opportunities through apprentices and other work opportunities that can be brought about by new housing and this could be a opportunity to ensure this happens on future sites.

Homes for older people and the link to the Extra Care rented opportunities will remain difficult to deliver with the decline in grant funding form the HCA, & Warwickshire CC .

PO16 Greenbelt

Again we support the option for Green Belt but we would like to be involved in any discussions with parish councils or other interested parties to outline what is affordable housing and dispel any myths.

We represent the West Midlands HARP Planning Consortium which includes all the leading Housing
Association Registered Providers (HARPs) across the West Midlands. Our client's principal concerns are
to optimise the provision of social / affordable housing and to ensure the evolution and preparation of
consistent policies throughout the region.
PO1: Preferred Level of Growth
The preferred level of growth identified would fail to meet even the basic level of affordable housing need
identified in the 2012 SHMA of 698 affordable dwellings per annum. For this reason Preferred Option 1 is
not supported. Our previous representations to the 'Helping Shape the District' consultation indicated that
the preferred options should be based on a full, robust evidence base, and the Council now has this to
rely upon.
The decision to bring forward a very basic level of housing growth across the District is likely to result in a
much lower level of affordable housing being brought forward over the Plan period than is necessary due
to significant viability constraints on development. The SHMA notes:
"Given the viability of residential development within the District and the availability of funding for
affordable housing, it is unrealistic to assume that all housing needs can be met. ... the supply of
affordable housing is likely to fall short of identified needs. The Council should look to maximise provision
of affordable housing where possible, including in working proactively with developing RPs ...." [Our
emphasis]
The implications of providing just 4,320 affordable dwellings over the lifetime of the plan needs to be
considered as part of the wider housing target. This reduction in the general housing target, and
subsequent reduction in the deliverability of affordable dwellings is very significant and will have a further
detrimental impact on housing waiting lists and affordability across the district. A single affordable
dwelling was completed in the monitoring period 2010/2011. With significant uncertainty as to general
development viability and the Affordable Housing Viability Assessment indicating variable viability across
the district, it is important for the Council allow sufficient flexibility in the housing land supply target to
secure affordable housing.
The Local Plan should be aiming for a much higher figure to take account of the need not only for
affordable housing delivery, but also to plan for economic growth across the district. We recommend that
a minimum target should be that set out in the SHMA, of 11,900 dwellings; the SHLAA indicates a more
substantial 13,385 dwelling capacity across the District to 2029 which could accommodate that minimum
target.
Unit 2 Eclipse Office Park Staple Hill Bristol BS16 5EL
T: 0117 956 1916 E: all@tetlow-king.co.uk
F: 0117 970 1293 W: www.tetlow-king.co.uk
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PO2: Community Infrastructure Levy
We support the Council's intention to bring forward CIL.
PO3: Broad Location of Growth
We support the Preferred Option for growth. We do however recommend that the Council clarify that the
hierarchy will allow for development at smaller villages. The NPPF states:
"In rural areas, exercising the duty to cooperate with neighbouring authorities, local planning authorities
should be responsive to local circumstances and plan housing development to reflect local needs,
particularly for affordable housing, including through rural exception sites where appropriate. Local
planning authorities should in particular consider whether allowing some market housing would facilitate
the provision of significant additional affordable housing to meet local needs.
To promote sustainable development in rural areas, housing should be located where it will enhance or
maintain the vitality of rural communities. For example, where there are groups of smaller settlements,
development in one village may support services in a village nearby." (NPPF, paragraphs 54 and 55)
By the use of this minor textual change, the Council will signal flexibility to development at villages with
housing need but where there are no infill opportunities. As shown above, this approach is in line with the
NPPF and the Council's own commitment to meeting housing need across the district. The Council can
control the extent of development at rural villages by requiring this to be proportionate in scale to the
settlement size and housing need.
PO4: Distribution of Sites for Housing
B. Category 1 and 2 Villages
We support the establishment of new village boundaries to enable development to come forward at rural
villages. In addition to discussion with Parish Councils, Warwick District Council should also ensure
consultation with local landowners and developers, including HARPs, to support development in the most
sustainable locations. We support the removal of land within village envelopes from the Green Belt.
D. Development on Greenfield Land
We support the proviso that affordable housing development will be permitted on greenfield land.
PO5: Affordable Housing
A. Affordable Housing on Housing Development Sites
We support the Council's intention to seek 40% affordable housing delivery from new residential
developments, as this is supported by the Affordable Housing Viability Report. The thresholds for urban
and rural areas are also supported, as this strikes the right balance between seeking affordable housing
from a high number of developments, whilst still making allowance for viability considerations.
We note the Council's intention to require affordable housing be retained in perpetuity. The NPPF
requires only that affordable housing delivered on rural exception sites be subject to this condition and we
advise therefore that the Council adopt this approach.
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B. Affordable Housing on Rural Exception Sites
As per our comments above, we recommend a word change to state that rural exception schemes will be
permitted at village locations where housing development would not normally be permitted. This would
support the provisions already set out under this Preferred Option.
We strongly support the allowance of some market housing under this Preferred Option to support the
delivery of affordable housing. This is in line with NPPF definition of rural exception sites which states:
"Small numbers of market homes may be allowed at the local authority's discretion, for example where
essential to enable the delivery of affordable units without grant funding."
We are however concerned by the imposition of a 30% cap on the level of market housing to be permitted
to cross-subsidise affordable housing delivery. The reason for the level of the cap is not explained in the
justification section, nor is it discussed in the Affordable Housing Viability Report. It would be useful for
the Council to set out its reasoning for the cap figure as without this the policy is unjustified.
PO6: Mixed Communities & Wide Choice of Housing
B. Lifetime Homes
Whilst we support the Council's intention to seek a proportion of new residential developments as
meeting the Lifetime Home standards, a formal policy in the next draft of the Local Plan should recognise
the potential for those standards to change, as new standards could be implemented at a later date,
rendering the Local Plan outdated and ineffective.
C. Homes for Older People
We strongly support the Preferred Option for all strategic sites to include an element of Extra Care
housing. We also support the Council's intention to make allowance for Retirement Villages and
Continuing Care Retirement Communities (CCRCs). Locational factors, such as proximity to local shops
and public transport, should not be as strict as for general market housing, as Retirement Villages and
CCRCs typically provide a suite of on-site facilities which reduce the need for site residents to access
local services and facilities, as well as having a nil requirement for services such as local schools.
PO16: Green Belt
We support the Preferred Option for the Green Belt. The requirement however for affordable housing to
be brought forward "through a Neighbourhood Plan" removes the ability for development to be brought
forward on an ad hoc basis - for example where a community does not wish, or have the capacity, to
develop a Neighbourhood Plan. We recommend instead that a formal policy sets out the ability for
affordable housing to be brought forward, including through a Neighbourhood Plan, or otherwise where
there is evidence of need.

See attachment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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