PO2: Community Infrastructure Levy

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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.

RESPONSE TO WARWICK DISTRICT COUNCIL LOCAL PLAN PREFERRED OPTIONS

PO1: Preferred level of growth
I support the preferred option based on an average 600 new homes per annum, as being realistic against current demographic trends and economic growth projections. However, should economic growth trends change in future years the council should seek to respond flexibly as required.

PO2: Community Infrastructure Levy
This new system of raising funding from new developments to support infrastructure developments offers important new opportunities but also presents major challenges. It requires a new set of relationships between district council, county council and other local partners, to not only draw up and agree CIL-funded infrastructure development plans for the district but to create a long-term stable framework for them to be implemented over many years.

PO3: Broad location of growth
I support the preferred option, and in particular that Kenilworth should have its fair share of new housing development (770 homes per Table 7.2) within the total district target. I disagree with the stated view of Kenilworth Town Council that there should be no further development in the town. A vibrant, sustainable community requires some headroom to expand and develop. There is a clear need for a better housing mix in Kenilworth, especially for more starter homes for young people and opportunities for older residents wanting to downsize to smaller properties.

PO4: Distribution of sites for housing
I support the preferred option that Kenilworth new housing development should be concentrated on the Thickthorn site. Kenilworth Town Council has stated a preference for 700/800 houses to be distributed across the town, but has admitted that this cannot be done while meeting their own criteria. These mixed messages only serve to confuse local residents.
Concentrating new housing development in one Kenilworth location provides the opportunity for the right level of infrastructure development to support this - roads, walking and cycling routes, school and other community facilities. Piecemeal small-scale developments across the town, even if there were suitable sites, would be difficult to support through improved infrastructure, so putting further pressure on existing facilities and resources.
I support strongly the proposed designation of the Thickthorn site for employment use as well as for housing. There has been a long-standing shortage of suitable employment land in Kenilworth. I would not support just an office park however. What is needed is a good mix of employment opportunities, to include for example research and development organisations and light industrial units.
I support the proposed designation of Burton Green as a 'Category 2' village, provided that the Parish Council is fully consulted and involved in decisions about target numbers, types and locations of new housing.

PO5: Affordable housing
I support the proposed option. The proposed policies seem to be soundly based.
It is interesting to note that the Strategic Housing Market Assessment (SHMA) estimates the requirement for 115 affordable houses per annum for Kenilworth alone. This reinforces my earlier statement under PO3 that there is a clear need for a better housing mix in the town. The SHMA estimated need is greater than the total new housing allocation for Kenilworth over the 15 year period of the plan. Consideration should therefore be given to achieving a much higher figure than the minimum 40% affordable housing on the Thickthorn site, and also seeking every opportunity for more affordable housing in any 'windfall' sites that come forward for development within the town.

PO6: Mixed communities and wide choice of housing
I support the proposed option.
Regarding the Thickthorn site, for the reasons stated previously I see the priority within the housing mix being for starter homes for young people, and smaller units for older residents wanting to downsize but to stay living within the town. There could also be an opportunity to cement further the links between Kenilworth and the University of Warwick by the building of new student accommodation - something completely missing at the moment.

PO9: Retailing and town centres
I support the proposed option, in particular promoting the vitality and viability of town centres, and strongly resisting further out-of-centre retail developments.

PO12: Climate change
I support the proposed option, in particular ensuring flood resistance and resilience in all new developments through sustainable urban drainage schemes (SUDS). Well-designed SUDS are not only functional, but can enhance the natural environment of open space areas associated with new developments.

PO13: Inclusive, safe and healthy communities
I support the proposed option, in particular the importance of access to high quality open spaces and sport/recreation facilities for all residents.
In para 13.10 (2nd bullet point), I would like to see the words "pedestrian and cycling" substituted for "pedestrian". Policies should do everything possible to encourage the greater use of bicycles by all sections of the local community, both for healthy exercise and as a sustainable/zero carbon means of transport within our district.

PO14: Transport
I support the proposed option, in particular the strong emphasis on promoting sustainable forms of transport.
The importance of the K2L cycling route between Kenilworth and Leamington cannot be overemphasised, together with provision for bus lanes and bus priority schemes on this important route. I see these as the priorities for highway improvements on this route rather than increased provision for private vehicles.
Within the town of Kenilworth, there is a massive task to be done to improve routes and facilities for pedestrians and cyclists, and this should be the priority for infrastructure investment to support new housing development. I disagree fundamentally with the view of the Town Council that a multi-storey car park is required in the town centre. Policies should be seeking to encourage residents to leave their cars behind for short-distance local trips whenever possible.
Map 5 shows a proposed cycle route through Abbey Fields to link up two elements of the National Cycle Network. This has been the subject of considerable negative comment by some residents, community organisations and the Town Council, which has been reflected in other responses to this consultation I understand.
The council has a duty to balance these strongly-expressed views, i.e. that no cycles should be permitted in or through the Abbey Fields, with the needs of the local community as a whole. I would highlight some of the comments in the Draft Green Space Strategy document, in particular section 4.1.7 on page 19 of that document:
"The value of green spaces can be greatly enhanced by linking them together into corridors and networks giving safe, attractive access for pedestrians and, in some cases, cyclists.
"... enable people living in urban areas to reach the countryside .... provide a green alternative for journeys to work or school."
"By-laws prohibiting cycling and horse-riding in some green spaces may need to be reviewed to achieve this."
Through the development of the Connect2 Kenilworth (C2K) route, the town has gained a valuable green corridor linking it to the countryside, and providing an important new travel alternative for people working at the university, Policies should be focussed on making it more accessible from all points of the town, and there is no doubt that a cycle route through Abbey Fields would become an important link between the west side of the town and C2K. Currently no other options have been proposed which would achieve the same result.
There is also the fact that the Abbey Fields are an important destination in themselves for many local residents, including families with young children wanting to access the playground area, and yet at the moment there is zero provision for any residents wishing to travel there by bicycle. Residents lucky enough to live nearby are able to walk, but others have no alternative but to drive there. With the Abbey Fields car park already at saturation point and due to reduce its capacity shortly, the council must consider how it can encourage more residents to access the Fields by bicycle.
In terms of transport infrastructure to support a new Thickthorn housing and employment development, for the reasons stated earlier a high priority should be given to sustainable transport options - i.e. walking, cycling and public transport. However, this site also offers the opportunity to create an important new link road between the traffic island over the A46 by-pass and the eastern side of Kenilworth (joining Glasshouse Lane at a point near Rocky Lane). As well as serving the new development and ensuring it is fully linked into the rest of the town, it would help to alleviate current traffic congestion around the St John's gyratory - something which piecemeal development of eastern Kenilworth over many years has failed to address.

PO15: Green infrastructure
I support strongly the proposal for the development of a peri-urban park north of Kenilworth. This would build on the success of the C2K Greenway route in opening up this important piece of our local countryside to all sections of the local community.
I do not support the arguments so far put forward for the restoration of the Kenilworth Mere. The outline feasibility study conducted by Warwick Business School MBA students showed that any viable scheme could have a massive impact on a large area of precious countryside adjacent to Kenilworth Castle, almost certainly involving commercial developments such as hotels, apartments etc.

PO16: Green belt
I support the re-drawing of green belt boundaries to the east of Kenilworth and around the village of Burton Green in order to permit the developments proposed in this Local Plan, and for no other reason.

PO18: Flooding and water
As stated previously, I support the requirement for SUDS schemes as part of all new developments.

See attachments for full text of representations.

1. Introduction & Background
We act as planning consultants for Barclays Bank plc ("the Bank") in respect of the Local
Development Framework (LDF) for the District and this letter forms the Bank's response to
the above consultation. As a long-established business, the Bank has made a substantial
contribution to the vitality and viability of the District's town centres over the years that it has
traded and as a significant stakeholder it is therefore concerned that development plan
policies should not fetter the important contribution that it makes to the vitality and viability of
those town centres. Through high attraction of footfall, financial services retailers generally
(and the Bank in particular) play a key role in promoting town centre health and as a result,
the provision of financial services should be allowed to improve and evolve alongside the
improvements to shopping provision envisaged over the proposed plan period. Banks should
not be subject to outmoded restrictive controls on their location, particularly as this is not
supported by Government policy or by any evidence, so there is therefore a need to review
existing policies that restrict such A2 uses in designated frontages or the Council will risk the
plan being found unsound.
2. Representations on the current consultation
The Preferred Options document sets out the Council's 'Strategy for the Future and
Sustainable Prosperity of Warwick District' (Paragraph 2.5), highlighting several 'Key
Principles' which include "facilitating the growth and development" of the local economy to
support a "dynamic, flexible" economy and "a commitment to maintain and promote thriving
town centres". Paragraph 4.8 refers to "the threat to the economic strength of the town
centres of Warwick, Leamington Spa and Kenilworth from retail and leisure developments
elsewhere", a matter highlighted in the 2011 consultation which also set out the Council's
intention to facilitate a level of retail and leisure growth that will meet existing and future
needs and "maintain and improve the vitality and viability of existing town and local centres".
P-07-289- Warwick LP PO Page 2 of 5 June 2012
Paragraph 4.10 sets out the Council's Objectives to address the identified Issues including
the intention to meet people's existing and future needs and maintain and improve the vitality
and viability of existing town and local centres. However, whilst the Council intends that the
Local Pan will identify the role of each of the town centres and plan for their future
management and growth, the plan omits a firm intention to review existing outdated local
plan policies. The Bank objects to that omission as it will result in a plan that is unsound,
particularly as the Plan acknowledges the need "to respond to the rapid changes taking
place" in the economy (Paragraph 8.5), emphasises the need for growth and flexibility
(Paragraphs 8.6 & 8.7) and recognises the requirements of the NPPF to plan proactively and
flexibly to respond to changes in the economy (Paragraphs 8.11 and 8.12). The Plan refers
to the Council's draft 'Economic and Regeneration Strategy' which identifies 6 priorities
including attracting investment and the growth of businesses (paragraph 8.17) and also to
the Key Ambitions of the 'Coventry & Warwickshire LEP' which include creating an
environment where businesses can thrive (paragraph 8.18). Section 9 on 'Retailing and
Town Centres' confirms the need to "maintain the economic strength of the town centres"
and the need for "a strategy for future management and growth of the town centres to meet
future needs". Despite this, Policy PO9 fails to facilitate either, compounding this by saying
nothing at all about reviewing existing outdated town centre policies.
The Council's background technical paper (March 2011) relating to 'Retailing and Town
Centres' refers to national planning policy in PPS4 and the need for enhanced consumer
choice through the provision of innovative and efficient shopping, leisure, tourism and local
services in town centres. It highlights the concerns in Leamington Spa about decreasing
levels of pedestrian footfall and the limited amount of investment that has resulted in the
town "losing its competitive edge". The paper notes that in Warwick there has also been a
decline in pedestrian footfall and a limited degree of retailer interest, resulting in a less than
vibrant and robust centre. In the current Warwick District Local Plan 1996-2011 Policies
TCP4 & TCP5 place arbitrary restrictions on non-A1 uses in primary and secondary
frontages but these measures have clearly failed to prevent the decline in footfall and the
consequent detrimental effect upon vitality and viability. The focus should be on the quality
of the occupier, not on maintaining an arbitrary level of a particular use class. The Bank
considers that the omission from the Preferred Options of a firm intention by the Council to
review out of date policies relating to shopping frontages is unsound, particularly as those
policies are in conflict with Government policy. We set out below the national policy
background that necessitates such a review if the Council is to produce a Development Plan
that is sound.
The National Planning Policy Framework (NPPF) re-emphasises the requirement for a
Development Plan to be "sound" when it is submitted for Examination and that in order to be
so it must be "Positively prepared, Justified, Effective and Consistent with National Policy".
The Government expects the local plan process to consider alternative strategies before
deciding upon the most appropriate, that decision being based on evidence to support the
choice (paragraph 182). The NPPF is clear that each LPA should "ensure that the Local Plan
is based upon adequate, up-to-date and relevant evidence" and that their assessments and
strategies "take full account of relevant market and economic signals" (paragraph 158).
On the matter of policy formulation the NPPF states that for plan-making:
* "local planning authorities should positively seek opportunities to meet the
development needs of their area"; and
* "Local Plans should meet objectively assessed needs, with sufficient flexibility to
adapt to rapid change" (paragraph 14).
P-07-289- Warwick LP PO Page 3 of 5 June 2012
The Government is clear that there should be a positive attitude to "proactively drive and
support sustainable economic development" and to "respond positively to wider opportunities
for growth". Plans should "take account of market signals" and the needs of business
communities (NPPF paragraph 17). "Planning should operate to encourage and not act as
an impediment to sustainable growth" and "significant weight should be placed on the need
to support economic growth through the planning system" (paragraph 19). Local Planning
Authorities "should plan proactively to meet the development needs of business" (paragraph
20) and "Investment in business should not be over-burdened by the combined requirements
of planning policy expectations" (paragraph 21). In drawing up Local Plans, local planning
authorities should set out a clear economic vision and strategy which "positively and
proactively" encourages sustainable economic growth; and should "support existing
business sectors, taking account of whether they are expanding or contracting". The NPPF
confirms that "Policies should be flexible enough to accommodate needs not anticipated in
the plan and to allow a rapid response to changes in economic circumstances" (paragraph
21). In his Foreword to the NPPF the Minister for Planning is very clear that "Development
means growth" and that "Sustainable development is about positive growth", emphasising
that "Planning must be a creative exercise in finding ways to improve the places in which we
live our lives". This reflects HM Treasury's commitment that "the default answer to
development is yes" in its ongoing 'Plan for Growth', which was launched at the time of the
Budget in 2011, reinforced in the 2012 Budget and now underpins the NPPF.
Keeping significant generators of footfall out of primary frontages will actively work against
the achievement of the Council's strategic objectives and is inconsistent with national policy.
The Council should recognise the positive impact that financial service retailers such as the
Bank have upon vitality and viability. The review of the local plan provides an opportunity to
examine new evidence and to revise out-of-date policy, particularly if it is not consistent with
national policy. Limiting certain Part A uses in the primary frontage undermines the Council's
intention to attract private sector investment in the town centre. The implication that only A1
uses are appropriate derives from very outmoded and discredited thinking that other uses
such as banks detract from the vitality and viability of town centres. By definition, uses that
fall within Part A of the Use Classes Order are appropriate in town centres as they are
"shopping area uses" and are acceptable without any need for restriction or qualification.
This is particularly the case for the financial services sector. ODPM Circular 03/2005
"Changes of Use of Buildings And Land" which accompanied the last major revisions to the
Use Classes Order specifically states in relation to the A2 Financial and Professional
Services use class (which was created to separate those uses "serving the public, from other
office uses not directly serving the public" - paragraph 32), that the Class is also "designed to
allow flexibility within a sector which is very much a part of the established shopping street
scene, and which is expanding and diversifying". The uses within Class A2 are noted as
being those "which the public now expects to find in shopping areas" (paragraph 38).
The wider role played by town centres than a pure shopping function has been recognised
throughout Government policy on town centres. Government Policy in PPS6, PPS4 and now
in the NPPF particularly emphasises the importance of economic growth and the promotion
of town centre vitality and viability. Paragraph 23 requires that "Planning policies should be
positive" and states that local planning authorities should "promote competitive town centres
that provide customer choice" and allocate a range of sites because it is important that
needs for retail, leisure, office and other main town centre uses "are met in full". The clear
message is that "local planning authorities should plan positively for their future to encourage
economic activity". In fact there is nothing in Government policy that recommends or
supports imposing restrictions upon acceptable town centre uses at all and indeed, as noted
above, paragraph 21 of the NPPF requires flexibility in policies in order to allow a rapid
response to changes in economic circumstances. It is therefore essential that Development
Plan policies should facilitate the positive approach required by the NPPF.
Promoting vitality and viability in town centres are objectives of the Government and the
Council. To succeed, town centres need to provide a full range of services and these often
need to be located in ground floor premises in accessible locations. Indeed, Class A2
retailers such as the Bank routinely experience very high levels of customer visitation,
contributing significantly towards pedestrian movement and therefore the vitality and viability
of town centres. The Bank has undertaken a number of comparative footfall surveys in
connection with its current acquisitions programme at its branches in various towns and
cities in the UK (copies are attached). These conclusively show that the level of footfall
associated with Bank branches is commensurate with, and often higher than, the best known
national multiple Class A1 traders.
Banks also have moved away from the traditional style of frontage, preferring to have an
open, visually interesting and attractive face to the 'high street'. The Bank has become
increasingly retail in its presentation and has introduced an innovative 'flagship' branch
design, which has been developed in association with its customers, to transform banking
into what it terms as "a retail focused experience". The Bank estimates that some 10 million
customers use its branches each week and through listening to their feedback, a design has
been developed that meets their requirements for modern banking and provides branches
similar in appearance and in operation to retail shops. This is an example of the "changes in
economic circumstances" that the NPPF recognises and to which all Local Plans must
positively and flexibly respond. Whilst the design of every new branch has to be flexible in
order to be sensitive to the requirements of each building occupied, the aim is generally to
ensure that over 70% of the internal space at ground floor is accessible to customers. The
Bank's managers regularly report that upon the opening of a 'flagship' branch the customer
visitation levels significantly increase and thus the level of activity helps to underpin
pedestrian flows to the benefit of surrounding traders. It is therefore important that planning
policy recognises the benefit of bank uses in fostering footfall and pedestrian activity and
that it should not resist much-needed investment by financial service retailers.
The Bank's footfall surveys have been a key element in helping to change attitudes towards
the presence of banks in core shopping areas and primary frontages. Even planning
authorities that once strongly resisted Class A2 uses in their primary areas have granted
permission for Barclays 'flagship' outlets. Examples of authorities that have recognised the
wider benefits of the 'flagship' design (following receipt of applications which have been
supported by evidence of high footfall), include Southampton, Reading, Manchester, Milton
Keynes, Romford, Southend, Leicester, Plymouth, Sheffield, Kensington & Chelsea and
Cambridge. Follow up surveys were carried out in 2010 at Milton Keynes, Southend,
Reading and Southampton (copies are attached). In every case the new 'flagship' branch
significantly increased footfall, confirming the Bank's beneficial effect on vitality and viability.
The Council's objectives will require major commitment and substantial investment by the
private sector. Pursuing restrictive policies to keep significant generators of footfall such as
the Bank out of primary shopping frontages will actively work against the achievement of
those objectives and is an outdated and discredited approach. The Bank therefore considers
that, in the light of its evidence, it imperative that the Council revises existing policies such
as TCP4 and TCP5 as they are neither consistent with National Policy nor Justified.
Proposed Policy PO9 does not do so and the Council's documents show no indication that it
has gone through an objective process and audit trail of assessing alternatives to those
existing policies, or that alternatives have even been considered at all. That is unsound.
3. Draft Infrastructure Plan
The Council has also invited comments on the Draft Infrastructure Plan as part of the current
consultation. As this document evolves into an Infrastructure Delivery Plan, the Council
should consider very carefully the balance between seeking contributions towards
infrastructure from proposed development and threatening the viability of that development.
P-07-289- Warwick LP PO Page 5 of 5 June 2012
The NPPF is clear that "Investment in business should not be over-burdened by the
combined requirements of planning policy expectations" (Paragraph 21) and that
development proposals "should not be subject to such a scale of obligations and policy
burdens that their ability to be developed viably is threatened". To ensure viability, any
infrastructure contributions sought should still allow for "competitive returns to a willing land
owner and willing developer to enable the development to be deliverable" (Paragraph 173).
4. Closing Comments
The Government has confirmed its commitment to HM Treasury's 'Plan for Growth' and it is
clear that the Council's objectives will require major commitment and substantial investment
by the private sector. In the light of our Client's evidence and the Government's
determination set out in the NPPF that planning policies and their implementation must
facilitate economic investment and growth, it is imperative that the Council uses the
opportunity of the preparation and revision of its Development Plan to ensure that its
planning policies in respect of bank and building society uses in designated shopping
frontages are consistent with National Policy and fully justified by robust evidence. Up-todate
development plans are an essential element in providing support for economic growth
and in taking Policy PO9 forward the Council must revise its current Local Plan retail policies
TCP4 and TCP5 to provide that support for investment by stakeholders such as our Client
and to ensure that the plan is sound. We trust that the Council will indeed take on board the
Bank's objections in the light of it being "keen to hear the views of all interested parties to
help us shape a draft Local Plan" and the confirmation that these Preferred Options "are not
a final set of proposals for the Local Plan" (Paragraph 3.3).
The Council's recognition of the need for significant private sector investment in the town
centres means that policies in the replacement local plan must give greater encouragement
to appropriate Part A uses to invest and to improve the quality of their representation.
Restrictive planning policies designed to keep significant generators of footfall such as the
Bank out of primary shopping areas will actively work against the achievement of the
Council's objectives and is inconsistent with national policy. The Bank's evidence of how it
increases vitality and viability in primary frontages shows that there is considerable benefit in
seeking to attract those A2 users such as banks who provide a high level of investment in,
and maintenance of, their premises resulting in active and attractive street frontages. This
will foster very significant footfall and pedestrian activity and attract investment by others,
helping to provide the confidence and commercial viability necessary for any programme of
regeneration and investment. To be Justified and Consistent with National Policy the
emerging Local Plan must review existing out of date policies that restrict the presence of
financial service retailers such as the Bank in designated frontages. If this is not done, the
Council will risk the DPD being found unsound. Policy wording should make it clear that
uses such as shops, banks and building societies which contribute to the vitality,
viability and diversity of town centres will be encouraged and that such active ground
floor uses will be appropriate in all designated retail frontages without restriction.
In view of the requirement for improved provision of banking services in Warwick District the
Bank would like to confirm its continued interest in the Local Plan process and in that regard
we shall be grateful if the Council will continue to notify us of the progress of this document
as well as details of any other emerging LDDs.

Thank you for consulting the Environment Agency on the above Strategic document that was sent out for consultation in May 2012. We appreciate the opportunity to contribute to your emerging Local Plan.

Having reviewed the Preferred Options and supporting documents we have the following comments to make.

Summary
We welcome that the importance of Climate Change adaptation and especially flood risk are recognised in the preferred options and will form a key focus for the emerging Local Plan.

We have made comments based around the following other issues for Warwick:

* Water Quality
* Water Resources
* Flood Risk
* Waste

These key issues are all key components in dealing fully with the impacts of Climate Change and we support the Local Plan ensuring all these environmental issues along with Green Infrastructure as a whole contribute to Climate Change Adaptation within the District.

We would like to offer our continuing support in the development of the Warwick District Local Plan as it moves towards publication of the next consultation document. We are happy to engage with you on the issue of policy focus and specific wording after this consultation process is complete as you consider the responses move the plan making process forward. We can also assist you in identifying cross boundary environmental issues which would need to be addressed to fulfil the requirements of the Duty to Cooperate.

Objectives
We support the over-arching objectives of the emerging Local Plan in sections:
* 4.11 Carbon emissions and use of natural resources and adapting to the impacts of Climate Change in regards to flooding. We would also encourage the consideration of impacts on water quality in assessing the impacts of climate change.

* 4.12 We support the Plans recognition for the planning of the appropriate infrastructure in the District to support the desired level of growth and environmental protection with regards to water provision and waste water treatments as well as waste and linking these to making the District more adaptive to Climate Change.

These particular objectives provide a strong platform for the protection and enhancement of the environment and Climate Change mitigation and should clearly link the environment to promoting sustainable economic growth in Warwick District.

Climate Change
The National Planning Framework states that the Planning System should contribute to protecting and enhancing our environment and help to mitigate and adapt to climate change. We support the work undertaken by the council on mitigation and adaptation to climate change and the commitment to a climate change policy (PO12) which seeks to reduce carbon dioxide emissions and promote renewable and low carbon energy production. We also support this policy's recognition of Climate Change Adaptation in seeking to require that development is designed to be resilient to and adapt to the future impacts of climate change.

Climate Change Adaptation Strategy
We support the councils view that a policy framework be set in place to ensure all new developments and buildings are designed to be resilient to and minimise the future impacts of climate change such as heat and water stress, increased subsidence, flooding and extreme weather events. We would suggest that the factors summarised in the Local Plan from the Climate Change Adaptation Strategy by linked clearly to the issues which would be impacted upon directly. This would include flood risk, efficient use of water resources, the impacts of the urban heat effect and the protection and enhancement of water quality and biodiversity through the provision of well planned Green Infrastructure.

We have broken down our comments to the separate topic areas of Flood Risk, Water Quality, Water Resources and Green Infrastructure (including Biodiversity) but all inseparable from the over-arching issue of Climate Change.

Flood Risk
It should be noted that Climate Change could increase rainfall and river flows with increasing intensity and scale and so there could be an increase in both pluvial and fluvial flooding. We currently factor in an increase of 20% on currently flood modelling to account for the predicted impacts of Climate Change.


It is important to flag up that under the issue of Gypsies and Travellers (Page.31) there is no mention of the location of sites and pitches with regard to flood risk. Safety is paramount for these members of society and they can be vulnerable to the effects of flooding so allocation of these sites should be located primarily in Flood Zone1.

As a point of clarification, on Page 97 Para 18.5. the 2nd point reads - "To ensure that new development does not increase surface water flooding". We would recommend that this point should be amended to say "To ensure new development does not increase flooding from pluvial (surface water, run off) and fluvial (river) sources", as both types of flooding pose a risk to the District and wider catchment.

Looking at flooding on a catchment basis, development and defence strategies in Warwick District could have impacts on the wider Avon and other catchments. These impacts could be felt into Stratford and Wychavon Districts so a strategic view of flooding must be encouraged. By taking a more catchment based approach to the issue of flood risk, relationships with neighbouring authorities both upstream and downstream of the District will be identified and taken into account, therefore again supporting the Duty to Cooperate requirement.

Page 98 Para 018. 1st line reads, "new development will take place on sites outside of flood risk zones as far as practicable". We suggest that in line with the NPPF it may be better to amend the sentence stating that "no development in Flood Zone 3 unless it is water compatible." as Flood Zones 1 and 2 are developable subject to satisfactory drainage provision.

With regards to Para 18.10 and the description the role of the SuDs Approval Boards (SABs). They are still emerging after some delays, but they will be active in due course when the Lead Local Authority take on this function.

The Development Sites.
The development sites all appear to have avoided major flood risk issues as there are minimum sections of flood plain identified within them.

There are areas susceptible to surface water flooding identified for the majority of the sites but these should be identified and assessed in any site specific Flood Risk Assessments and these should consider all forms of flooding. We do not see any show stoppers associated with this aspect but in order to ensure surface water and flood risk is managed effectively in the District we recommend that surface run off be addressed in Policy PO18. We therefore suggest that PO18 where it addresses SuDs schemes should also include the commitment to ensure all new development achieves Green Field rates of surface drainage.

Water Quality
We are pleased to note that the issue of Water Quality and the implementation of the Water Framework Directive (WFD) are addressed in the supporting text to Policy PO18. However, we would encourage these issues to be fully addressed in Policy PO18 and suggest a policy be taken forward which insures no development should be allowed without provision of the necessary infrastructure to ensure no deterioration of local water bodies and such development should seek opportunities to make a contribution to the WFD objectives contained in the relevant River Basin Management Plan. Currently, PO18 makes no reference to wastewater, sewerage capacity and sewage treatment capacity at local treatment works.

We also suggest that the council work with Severn Trent Ltd and ourselves to consider the information in the sub-regional Water Cycle Study (March 2010) is still the most up to date and relevant to support the emerging Local Plan. It could be assumed that such a review should draw the same conclusion as the March 2010 document in that overall Water Quality is generally poor quality in terms WFD classification due to high phosphate levels, invertebrate/fish failures etc and these failures are caused from sewage treatment works and diffuse pollution from urban and rural sources. The majority of waterbodies are of poor - moderate status with only 4 waterbodies currently at Good Ecological Status/Good Ecological Potential (if heavily modified), Finham Brook and Radford Brook are two, the others being canals.

Infrastructure Delivery Plan
The supporting IDP states:
"As part of this funding cycle STW are currently making improvements to Longbridge sewage works (Warwick) to improve its efficiency and add further capacity and it is anticipated that this will be completed by 2014. They also have an existing ,discharge consent‟ to increase the capacity of Finham sewage works by 15%."

This statement needs to be confirmed with regards to the Finham works as this also serves Coventry as well as parts of Warwick District. Coventry has its own growth and development which could also impact on any free discharge and treatment capacity at the works. Both the Longbridge and Finham works ultimately discharge into the River Avon which means we strongly recommended that the council consider the whole Avon Catchment with regards to waste water treatment and WFD and this would also help the Duty to Cooperate requirement with regards to water quality. Finham STW is still a concern being a large STW with a Phosphorous removal consent limit already so it may be required that we have to Consent below 1mg/l in order to achieve no deterioration to the waterbodies for WFD.

Water Resources
Water conservation is addressed in Policy PO18 and we endorse the efficient use of water, especially in new developments, but we recommend that the plan includes specific targets, i.e. which level of the Code for Sustainable Homes and BREEAM ratings to be achieved. Specific water use targets would strengthen the policy and give a clear steer to developers. At the moment the CSH levels are recommended in the Draft Infrastructure Delivery Plan only and we would like the council to consider bringing these into Policy.

It is noted that in the Draft Infrastructure Plan (and WCS) it recommends CSH level3/4 as a minimum and that the Council aspires to achieve CSH level 5/6. To achieve level 5/6 developers may need to use rainwater/greywater harvesting systems. Since the WCS was published the Agency has published 'Energy and Carbon Implications of rainwater harvesting and greywater recycling' (August 2010) (http://publications.environment-agency.gov.uk/PDF/SCHO0610BSMQ-E-E.pdf ) which highlighted the high carbon emission associated with the use of recycled/ rainwater for anything more than outdoor use. This may influence the CSH level 5/6 aspiration. Our position statements on rainwater harvesting can be found at: Rainwater Harvesting Position Statement

If all cost effective water efficiency measures have been considered, rainwater harvesting and greywater recycling systems can be a useful means of reducing demand for mains water. It may be possible to make additional water efficiency savings from retrofitting surrounding properties with water efficiency devices and working towards water neutrality.

Each domestic rainwater harvesting (for more than just garden use) or greywater reuse should be examined on a case by case basis as their effectiveness varies considerably depending on scale, location and design.

As a guide, rainwater harvesting systems may be appropriate where:
* all feasible water efficiency measures are already in place;
* the planned system is cost effective (including ongoing maintenance costs);
* the planned system will be competently maintained and monitored;
* energy use and carbon emissions are minimised;
* they offer a more sustainable solution to manage surface water run-off than could be provided by other SuDS approaches.

The most recent and comprehensive guidance on rainwater harvesting systems is from BSI - BS 8515. On greywater it is BS 8525. Some case studies are available from:

Harvesting rainwater for domestic uses: an information guide (Environment Agency)
Conserving water in buildings, Chapter7: using greywater and harvesting rainwater (Environment Agency)
Greywater: an information guide (Environment Agency)
UK Rainwater Harvesting Association website
BSI British Standards: BS8515 - Rainwater harvesting - Code of practice and BS8525 - Greywater systems - Part 1: Code of practice

Waste
Development of additional housing and employment land will have implications for managing the waste arising from the new developments, both in terms of construction phases and during occupation. It is important that County and District work together to ensure waste is managed in a coordinated way, and if additional waste management infrastructure is required, the timing of new developments is phased accordingly.

As waste will arise during construction, and from new homes and businesses. There is an opportunity to consider the design of communities and supporting services to minimise waste arisings and encourage and enable waste to be managed in accordance with the waste hierarchy - reduce, re-use, recycle, recover, with landfill as the last resort. We support the comments in the IDP in that the council will ensure that sufficient infrastructure is in place to meet future demand for waste collection services in residential and commercial uses through the provision of household and commercial waste and recycling bins. We would recommend that in the design and layout of new housing incorporate waste recycling and collection issues such as by providing sufficient space for the collection of various waste streams.

Waste management should be considered alongside other spatial planning concerns such as transport, housing, economic growth, natural resources and regeneration, recognising the positive contribution that waste management can make to the development of sustainable communities.

We hope you find the above comments informative. If you have any queries, please do not hesitate to contact us

We wish to respond to the proposed Infrastructure Plan - Draft as follows:-

1.
Section 4.2
Para 16

Preferred Options (Full Version) section 4.12 Par 11 is supported as enabling organisations to provide community infrastructure such as schools, and particularly in respect to future schooling needs.
NPPF Item 72 states regarding choice of schools that "Local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement" and "work with schools promoters".

NPPF Item 72 also states that The Government "attaches great importance to ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities"......."development that will widen choice in education".
This is witnessed to in the Government's current support for Free Schools.

Such organisations clearly include "Faith schools".

A request is made to include a reference to "Free Schools" in this section.


2.
Section 4.5

There are many items that could be included in the infrastructure and as an organisation responsible for the provision of Gospel Halls we are concerned that there is no reference to places of worship.
NPPF Item 70 shows that to deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should: plan positively for the provision......(of)... places of worship.
NPPF Item 171 Under Health and well-being states that "Local planning authorities should work with public health leads and health organisations to understand and take account of the health status and needs of the local population (such as ........ and places of worship).
Places of worship included at national level should be sufficient warrant to require specific inclusion at local level.
It is vital that this spiritual "well being" can be extended and made freely available throughout the whole community.
Every man has a responsibility to answer to God. "Thou shalt worship the Lord thy God, and him only shalt thou serve" Luke ch 4 verse 8.

NPPF Item 38 addresses "larger scale residential developments" and the need for "key facilities" within walking distance.
Representation was made to include Places of Worship in The Warwick District Local Plan 1993 and the following wording was amended and included:-
"It is of great importance that new development is of the highest quality and makes proper provision for such elements as infrastructure and community facilities, including places of worship. To this end, detailed development briefs will be prepared for all major housing allocations, prior to Outline Planning Permission being granted. The brief will be adhered to closely throughout the process of development of each site"

NPPF Item 28 also shows that places of worship contribute to a prosperous rural economy.

Places of worship are a vital part of the infrastructure and should be specifically included; without which this document is incomplete .

I wish to register an objection to the proposed Local Plan on the grounds that it continues unwanted urbanisation by stealth.

The claimed need for 10,800 new houses is not supported in the Plan and applies only to the period of the Plan. The next "Plan" is likely to want another 10,000 - and then another. It really means "another 500/600 extra houses a year" every year without end. However, the towns are already too big for their centres -- shown by traffic congestion, inadequate parking; the development of housing-estate satellite shopping areas and major out-of town shopping.

I appreciate that saying NO to any more houses is "not an option" but it should be. This so-called "Local Plan" is not really proper town planning at all but merely limited containment of year-on-year incremental urban sprawl that will diminish amenity and eventually destroy the attraction of living here. I come from South East England where creeping urbanisation is more advanced. I feel sure that you should understand this only too well.

The proposed developments south of Kenilworth and north of Leamington would diminish Green Belt and increment Urban Sprawl in direct contradiction of stated policy. In fact, Policy Objective 16 alterations to the Green Belt to allow development should be deleted as it is in direct conflict with the reason for retaining Green Belt.

The proposal to remove Leek Wootton from the Green Belt would be particularly damaging because the green space between Kenilworth and Warwick is narrow and necessary to keep the towns apart.

There does not appear to be a costing for this Local Plan nor a cost-benefit analysis nor even any explanation as to how it would be funded. I cannot help but suspect that there is minimal benefit for substantial cost to us ratepayers in order to accommodate imposed additional housing.

Full submission attached

As scanned.

As scanned.

New Local Plan Preferred Options Consultation
1. Thank you for your consultation dated 1 June 2012, which we received on the same date. Thank you for allowing additional time in which to respond. This enabled our submission to be compiled with the benefit of some input from locally based colleagues.

2. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Overview

3. There is much to commend within the consultation document in terms of protection and enhancement of the natural environment. We have relatively few comments to make but would like to raise a small number of potential areas of concern and possible improvement.

4. We assume the numbered preferred options presented in the mauve boxes foreshadow policies content rather than representing proposed policy wording. For that reason have not recommended any detailed changes to text but have confined ourselves to broader observations.

Detailed comments

Section 2.5 Strategy for the Future and Sustainable Prosperity of Warwick
District

5. We support the fourth bullet under "environment" and second bullet under "emphasis on infrastructure" which pick up on the importance of protecting and enhancing of the natural environment. It is important that the final version of the plan follows through on these important components of the vision. In line with the NPPF requirement (paragraph 157) that

Section 4.12 Enabling the district's infrastructure to improve and support growth

6. We welcome the reference (objective 14) to enabling improvements to be made to the built and natural environments which will help to maintain and improve historic assets, improve 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 (including the effects on habitats and wildlife) to a minimum, and support healthy lifestyles. This should help to translate the requirements of the NPPF into practice and is welcome recognition of some of the multiple ecosystem and other benefits that the natural environment and green infrastructure delivers for communities.

PO2: Community Infrastructure Levy

7. Natural England recognises that CIL has a part to play in providing the infrastructure that new and existing communities will need. Green infrastructure is a part of the essential necessary to support growth and we trust the Council will ensure that the need to make provision for key green infrastructure

PO3: Broad Location of Growth

8. Natural England is concerned that the overall level and spatial distribution of growth should be informed through detailed environmental testing. From that perspective we welcome the Sustainability Appraisal work undertaken so far and the fact that the allocations have avoided direct impact upon statutory biodiversity designations.

9. We do note that a number of preferred allocations (e.g. Whitnash East) incorporate, or are bounded by, Local Wildlife Sites and/or Local Nature Reserves and would encourage the Council to ensure that sufficient safeguards could be incorporated before confirming these allocations.

10. Similarly, a number of the preferred allocations (e.g. West of Europa Way) lie adjacent to Warwick Castle Park . This site is not subject to any natural landscape or biodiversity designation but is the subject of a Higher Level Stewardship agreement to maintain and improve its environmental value. We would like to ask whether the Council will consider the potential for indirect impacts on the Park (e.g. of increased recreational pressure) and degree to which these can be moderated before confirming these allocations?

PO10: Built environment

11. We welcome inclusion of the intention to protect, enhance and link the natural environment through policies to encourage appropriate design of the built environment. We also welcome the intention to set out a framework for subsequent more detailed design guidance to ensure physical access for all groups to the natural environment. The natural environment and access to it are important aspects of urban design that have been overlooked in some areas in the past.

PO13: Inclusive, Safe & Healthy Communities

12. The third and fourth bullet points are supported, provided a proportion of the new open spaces provided as part of new development are made up of accessible natural green spaces with all the associated health and wellbeing benefits. Natural England promotes an Accessible Natural Greenspace Standard1 that we encourage local authorities to adopt.

PO12: Climate Change

13. Natural England welcomes measures to tackle climate change which is the greatest long term threat to the natural environment. None the less, we look to plans to take full account of the local natural environment to accommodate such infrastructure. In particular, we encourage plan makers to identify areas for different forms of low carbon energy and to ensure that designated landscapes are fully protected.

14. The intention to require that new development is designed to be resilient to and adapt to the future impacts of climate change in welcome. We particularly support the reference to the use of greenspace and vegetation, (such as street trees) to provide summer shading and allowing winter solar gain.

PO15: Green Infrastructure

15. We support the preferred option relating to green infrastructure, which is consistent with the NPPF (paragraph 114). We particularly welcome the recognition that this exists and can be supported through planning at a variety of spatial scales.

16. We would expect the final pan to include more specific detailed policies on certain aspect of green infrastructure. For instance, we trust that policies for biodiversity will extend beyond offsetting to cover the landscape scale approach, net gain, ecological networks, designated sites and priority and protected species.

17. Similarly, the references to geology, soils and ecosystem services are welcome and we would expect that these matters will translate into robust policy content within the final plan.

PO16: Green Belt

18. We support the reference to positively enhance the beneficial use for the Green Belt, such as looking for positive opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity or to improve damaged and derelict land. This is an aspect of Green Belt that has not always been afforded an appropriate degree of attention in all areas.

Following a presentation of WDC's Local Plan in Bishop's Tachbrook, I have several objections and suggestions regarding the Housing Preferred Option and other matters.

Housing:
With reference to the map P04 Preferred Option sites for expanding housing include sites numbers 2,4,10, 11,12 & 6. These sites will provide land for a proposed 3800 homes. Extrapolating the number of people that will live in these new homes there will be an additional 14 to 15000 more people living South of Leamington and Warwick. These extra people will put a massive burden on the infrastructure such as roads/bridges to gain access to the Town Centres' and emergency services. The Bridge in Warwick and Leamington are already at maximum usage during rush hours and in my opinion would be overwhelmed by this massive increase in population. According to the Preferred option on transport infrastructure there is no provision to build more bridges over the Rivers Leam and Avon. What's more the entrance to Warwick from the south via the Banbury Road will be blighted by such a massive housing estate and will have detrimental effect on tourism.

Furthermore the development (Woodside Farm, Bishop's Tachbrook; area Number 11 on the Preferred Option map) would have a high adverse visual impact as it is prominent ridge and would impair the visual approach to Leamington.

The lack of infra structure provision was also a major objection to the last Preferred Option in the previous spatial framework housing plan. I agree there are now fewer houses envisaged 3800 as against 4500 but the same criticism applies Ie. the excessive strain on existing facilities.

Alongside new housing must be provision for upgraded infrastructure. When previous housing expansion took place, namely Warwick Gates, we in Bishop's Tachbrook, suffered lack of water pressure and problems with sewage because no pumping station was built for a number of years. Road infrastructure too was overlooked causing major problems at the
Tachbrook/Harbury Lane cross roads. Ditto the exit from Gallows Hill onto the Banbury Road. Improvements to these road junctions took many years after the houses and business park were built. Major expansion of the factories at Gaydon has created a huge traffic increase with consequent problems (and fatalities) by vehicles trying to exit Tachbrook on to the Banbury Road. In addition there is also a problem at rush hours caused by vehicles using Bishop's Tachbrook as a rat run.


The decision not to build a new infants school at Warwick Gates caused and still creates major problems with bus access to the school in Kingsley Road (Bishop's Tachbrook) because children have to be bussed here from Warwick Gates.
Infrastructure is either neglected all together or takes many years to implement; meanwhile existing residents have to live with the misery.

The new Preferred Option I believe will cause major problems owing to the bridge bottlenecks in Leamington and Warwick and lack of concrete plans to enhance infrastructure to cater for the increased population.

If more housing is required there must be adequate infrastructure built in parallel with housing construction. The proposed Developer Infrastructure Levy will certainly not pay for new bridges or better health provision etc. And waiting for the increased population tax revenues to pay for it will take far too long, leaving existing residents to suffer severe curtailment to the quality of their lives.

I would also question the need to build 555 houses per years from 2014 -2029. The ONS and economic projections based on historical growth rates do not take into account the envisaged stagnation in economic growth throughout the UK for the foreseeable future plus the negative growth effects of an ageing demographic. Apart from Jaguar Landrover at Gaydon most of the envisaged commercial expansion is planned for the Gateway area around Baginton/Ryton. This would entail commuting again from South of the Rivers to the North, further compounding traffic problems over the aforementioned bridges. Therefore it would be better to build more housing nearer the Gateway Area

Also there is a "Green" imperative that demands fewer commuting miles by car in order to reduce emissions etc.

In addition, building more houses attracts more people i.e. it is a self-fulfilling strategy, not based on projected growth grounds alone. As Leamington/Warwick is an attractive area more people will move here to take advantage of the new housing and the increase in population would in turn diminish the attractiveness that created the initial demand and further increase commuting miles out of the area to other centres of work.

If more housing is required (the number should be far less than the projected 555 per year) it would be best to maximize all available brownfield sites in the suburban areas. It was a great pity that yet another supermarket was granted permission to build a giant shed on the old Ford Foundry site when this entire area could have provided an admirable housing development.
Brownfield sites that would provide excellent housing are:
1. The old telephone exchange in Leamington
2. Garage opposite Covent Garden multi story (Leamington)
3. Quarry Street Dairy Milverton
4. Linen Street car park (Warwick)
5. Police station Warwick
6. Fire station (Leamington)



Housing continued...

Further sites
Land could be released for housing at Bubbenhall and Baddesley Clinton if they were classed as Category 1 or 2 villages


GREEN WEDGE
The proposed Green wedge stretching from Radford Semele, between Harbury Lane & Bishop's Tachbrook to Banbury Road should be extended Southwards to encompass Oakley and surrounding area.

In addition, I would like to reaffirm opposition to any plans to revive development between Harbury Lane and Bishop's Tachbrook as was proposed in the previous Preferred Option

Scanned representation

PO1 Preferred Option: Level of growth
I consider that the proposed level of housing growth of 555 homes per year is not supported by all the evidence available. The mathematics of the calculations are not shown so they cannot be checked easily.
The baseline population on which the future need is apparently calculated is the ONS estimate of 138,670. Since those calculations the 2011 census has measured it at 136,000.
The initial stage of consultation gave a range of growth possibilities and the clear majority of respondents opted for the lower growth levels which would more reasonably reflect the inevitable organic growth in our population due to increased longevity, better health and changes in birth rates along with some inevitable inward migration.
Residents made a clear choice to accept lower infrastructure gains in return for limiting growth and specifically avoiding more growth in excess of local need.
Approximately 250 homes per year would appear to be more than adequate to meet these need if more adventurous use of brownfield urban sites was made..

PO2 Preferred Option: Community Infrastructure Levy
The current market conditions demonstrate that because developers are not confident in the ability of customers to buy, and sites that already have planning approvals are not proceeding.
CIL should be used on a local benefit to relieve effects of or immediately related to development proposal areas.


PO3 Preferred Option: Broad location of Growth
I supports the dispersal of additional housing that cannot be located on urban brownfield sites so there is a small effect on a number of places, rather than a large effect on a few. In general, this will reduce travel and demand for traffic improvements, use existing educational, health and other community facilities where there is available capacity to do so.
The NPPF para 54 requires that in rural areas, local authorities should be responsive to local circumstances, planning housing development to reflect local needs. In para 55, to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities.

PO4 Preferred Option: Distribution of sites for housing
Location 1 Sites within existing towns. This is the best option. If it were possible, all the housing required should be in existing towns and dispersed therein, to make the least demand on support infrastructure and reducing traffic movements.
Location 2 Myton Garden Suburb. No objection.
Location 3 South of Gallows Hill/West of Europa Way. This development must not take place. It is a criminal intrusion into the rural southern setting of both Warwick and Leamington with important implications for the setting of Warwick Castle and its parkland. It will create a natural infill area for later development until eventually all the area south of Warwick and Leamington id completely filled.
The additional traffic from the proposed 1600 homes plus employment on a road system that is already struggling will impose even greater stacking effects back through the village of Barford which already suffers enormous amounts of rat-running from commuters trying to avoid the daily J15/Banbury Spur commuter
The numbers show that it is not needed and the council needs to bold enough to decide to continue the Green Wedge through to Castle Park.
Location 4 Milverton Gardens. 810houses + community +employment + open space.
and
Location 5 Blackdown. 1170 houses+ employment +open space + community.
These two sites may well be cases where the Greenbelt policy could be relaxed with limited overall damage whilst providing essential housing land. There would be limited damage to the settlement separation intentions of the Greenbelt policy.


Location 6 Whitnash East/ South of Sydenham. 650 houses + open space and community facilities
No specific comment but is this really required?
Location 7 Thickthorn, Kenilworth 770 houses + employment +open space + community
Use of this as part of the policy for dispersal of the housing required is supported.
It is, better to use this site than land of rural, landscape and environmental value elsewhere in the district. It is the only contribution to the preferred option plan located in or near Kenilworth.
Location 8 Red House Farm, Lillington 200 houses + open space.
This would seem to be a reasonable site to utilise if numbers demand it.
Location 9 Loes Farm, Warwick 180 houses + open space
This would seem to be a reasonable site to utilise if numbers demand it.
Location 10 Warwick Gates Employment land 200 houses + open space.
No objection.
Location 11 Woodside Farm, Tachbrook Road 250 houses + open space
There seem to be merits in using this site as it extends previously developed land towards a natural boundary (Harbury Lane) and is hence self-limiting.

Location 12 Fieldgate Lane/Golf Lane, Whitnash 90 houses + open space
No objection.
Locations 13 &14 Category 1 & 2 villages Category 1, 5 villages at 100 and category 2, 7 villages at between 30 to 80 in each plus 8 category 3 villages within the existing village envelopes.
These are very significant increases for many of these villages! Do the category One villages really NEED to take 500 in total or 100 each. In Barford's case this will be an 18% increase in the number of dwellings, and that on top of a recent development of approximately 70 homes. I would suggest that the total Cat One numbers should be significantly reduced and that numbers should then be spread pro-rata over all the Cat one villages according to current house numbers of population number to give a more equitable spread and certainly to keep the increases at or below the district wide increase.
Considerable attention should be paid to the Sustainability Assessments included in the plan where it should be noted that Barford, a Category one village based on its facilities scores the THIRD WORST Sustainability score of all the villages assessed (Cat one, two and three) with only Rowington and Norton Lindsey scoring lower.

Furthermore despite having a very successful school there is considerable doubt about how such numbers could be accommodated and the amount of harm that would be inflicted on currently resident families and pupils of such increases.


PO5 Preferred Option: Affordable housing
I have considerable concerns that the 40% requirement is considerably in excess of the real need for "social housing" and as such will drive up the costs of market homes to such a degree that all homes will become significantly less affordable. It is perhaps appropriate to consider what is trying to be achieved and to review the way in which Affordable Housing need is actually measured - specifically it seems that those in need are counted before their need is actually validated whereafter the real need is actually considerably less and they are re-routed to more conventional housing sources.
PO6 Preferred Option: Mixed communities and a wide choice of homes
Regarding retirement housing of various sorts must be provided as part of a whole-life

PO7 Preferred Option: gypsies and travellers.
The Gypsies and travellers remain and always will be a problem. Most tax-payers are at a loss to understand why they must be treated differently to everyone else when they could acquire land and pursue the planning process just like everyone else.
The proposal to "provide sites" will bring out the worst elements of the NIMBY culture and blight certain areas.
It is my opinion that the problem needs solving by primary legislation not the current soft PC approach. This is a job for central government, no doubt through "Europe".

PO8 Preferred Option: Economy
Employment need only be provided/attracted to match our population. The previous stage of the consultation gave a clear indication that the majority were preferring to accept lower growth rates of housing, employment and infrastructure. That choice must be selected and a focus on consolidation rather than growth should be the watchword. We are a low unemployment area and any extra employment provision will bring with it a proportionate housing demand and inevitably more houses, which is not required.
The Gateway project may still materialise and this will make extra demands as some of the jobs will no doubt be attractive to our residents in addition to bringing in new workers. Provision should be made for housing local to that site and not for such workers to be subsumed into the wider WDC area.

PO9 Preferred options: Retailing and Town Centres
The support retailing and town centres is welcomed and should be vigorously pursued by both planning policy and fiscal incentives. There must be adequate town centre parking provision to support town centre businesses.

PO14 Preferred options: Transport

Access to services and facilities.
Clearly, it is essential to provide sufficient transport infrastructure to give access to services and facilities. The amount of work required is dependent on the level of growth selected. If the low growth scenario is chosen in preference to the current preferred option, then the infrastructure improvements will be much less and probably not much more than is currently necessary to resolve existing problems. This would be less costly and less inconvenient to the public than major infrastructure improvements.

Sustainable forms of transport.
The best way is to keep as much new housing provision as possible in existing urban locations because people are then more likely to walk, bus, bike to work, shops, school etc.


PO15 Preferred options: Green Infrastructure

The policies set out in PO15 are supported


PO16 Preferred options: Green Belt

The NPPF states that once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. I believe that it may be a proper time to review the Green belt to ensure that it is appropriate to the current situation and not merely being carried forward, just because it has always been so. Some relaxation within villages and on the edges of the major settlements would make massive contributions to the housing need whilst doing little harm to the concept of ensuring separation between settlements.

Removing Green Belt status from rural villages would allow currently unavailable infil land to make a significant contribution to housing numbers whilst improving the sustainability of those villages. Barford, not in the Green belt has had considerable infil in the past and as such is relatively sustainable whilst actually scoring poorly on the WDC conventional Sustainability Assessment scoring system.



PO17 Preferred options: Culture & Tourism

The preferred option of medium growth seems to be totally oblivious of the value of the approach road from the south to the Castle. It proposes to materially downgrade the approach past Castle Park by building housing along the length of the road from Greys Mallory to Warwick, a distance of about 2.5 km. The views across the rolling countryside to the east of the approach road are an essential part of the character of the district and county about which books have been written.

The low growth option makes that loss unnecessary.

PO18 Preferred options: Flooding & Water

Flooding: Development should take place where flooding is unlikely to occur. The low growth option would make it easier to select sites for development that do not carry this risk.

See Attachments

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

Scanned representation

Attached

scanned letter

scanned form

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

Population Growth

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

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

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

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

Brownfield Sites

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

So why are we not making it a priority to develop brownfield sites first and regenerate poorer housing in urban areas? The Ford Foundry site is a prime example of revitalising an eyesore of a brownfield site to vastly improve the area and bring it back into good use. There are many more examples of brownfield sites in Warwick District which could be regenerated.

Gypsy Site

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

Green Belt

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

An incredible 37% of the 11,000 homes proposed for Warwick District are to be built on the land south-east of Warwick, covering nearly all of the green space between the Banbury Road, Greys Mallory, Europa Way, Myton and the Technology Park. This would mean estates more than three times the size of Warwick Gates, Woodloes Park or Chase Meadow!

The NPPF (76) states "By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances". "Once established, Green Belt boundaries should only be altered in exceptional circumstances." (NPPF 83) Yet your reason for allocating development on Green Belt is that "there is nowhere else to build" (your quote at the Warwick Society Meeting).

NPPF (88) states "When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.." The exceptions given in NPPF 89 and 90 do not apply in your proposed Local Plan. Our Green Space is already designated.and we are objecting to this scale of development which will undoubtedly impact negatively on the character of Warwick and the quality of life of existing residents. Why are we facing urban sprawl rather than the housing being spread equitably around the District as you stated was your aim? The previous Core Strategy stated that 90% of the population live in the urban areas and 10% in rural areas. Yet in the new Plan less than 10% of housing is proposed for villages, some of which, such as Barford, would welcome more homes including low-cost housing to build up sustainable communities with schools and facilities and meet the need for affordable rural housing. Those that grew up in the villages and wish to remain there would then have the opportunity to do so. We would propose that at least another 1,000 could be spread around the villages and the number proposed for Warwick reduced.

The area to the west of Europa Way was identified as an area of restraint at the time of planning the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa to prevent the two towns becoming one urban sprawl. The District has 85% green belt but 45% of this is to be built on, thus reducing the gap between conurbations. The green space threatened is valued rich agricultural land, essential for food self-sufficiency, environmentally precious landscape with many wildlife habitats and biodiversity including badger setts and also prevents coalescence which you declare is one of your aims. Our existing green space provides open space, sports and recreation and such land, including playing fields, should not be built on!

Alternative Sites

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

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

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

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

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

 
Flood Risk

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

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

Europa Way and an area to the south of Gallows Hill are in flood zones and at significant risk of flooding, yet housing is proposed in Flood Zone 1, adjacent to Zones 2 and 3. Areas at risk of flooding have always been designated areas of restraint but you are dispensing with these. More concrete on green fields here which currently soak up heavy rainfall must increase water run-off and impact on the areas of Warwick which already suffer from flooding, especially around Myton Road and Bridge End. This is contrary to NPPF 100 "Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere." The previous Core Strategy decided that this area may not be needed for development in the future being an area of restraint and the worst area for infrastructural needs. Development is not necessary in these areas of flood risk and should be avoided, certainly not put into the first phase for building. Home-owners would also face being turned down for insurance in postcodes where there is flood risk. This problem will possibly increase next year when the agreement between the Government and the Insurance Association ends. The Portobello development, built on a flood plain, is a prime example where many of the apartments are still unsold. This area you have designated for building is vital for flood alleviation and should not be built on at all. At the very least it should be the last designated site.

Density

Garden Town suburbs sound admirable but naiïve when you look at the number of buildings proposed and the impact on the environment. This concept did not materialise in Warwick Gates or Chase Meadow and developers will build at high density for increased profit margins. 1,100 houses were first proposed for Chase Meadow and now it is to be 1,600. WDC has no budget for tree maintenance and developers cannot be relied upon to carry this out, as we have seen in other recent developments. After 14 years Chase Meadow still has unadopted roads, only just received its link road to the local school and the prospect of a community centre for sports provision and social interaction. Developers will not be persuaded to build at 30 units per hectare and there is no means of insisting on this. This is just a red herring in our opinion, as are green wedges since you admitted that where these are proposed, you will be reliant on private landowners to permit their development. Once again, funding for this would be dependent on developers' contributions and these monies, being in short supply, would be diverted for other more essential infrastructure.

Why are we allocating housing for the Coventry Gateway project? It should be up to Coventry Council to provide for this. They should also provide more dwellings for Warwick University students which would free up hundreds of dwellings (including Station House with over 200 student flats) in the South of Leamington to private affordable starter homes and family homes. WDC have recently been forced to change their planning policy because of the problematic increase in HMOS in the District.

Infrastructure

The NPPF (17) states that strategies should "deliver sufficient community and cultural facilities and services to meet Local needs". Also (NPPF 162) "Local planning authorities should work with other authorities and providers to:

* assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demands and

* take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."

Yet you confirm that infrastructure will not be put in place before building commences but that you hope that infrastructure will be provided from developers' contributions, whilst admitting that this may not raise enough to cover escalating costs of new roads, bridges, schools, extra health provision, policing, fire service, community centres etc. If left to developers, history has shown this may not happen. Infrastructure needs will then be prioritised and some areas may miss out. You have admitted that infrastructure proposals will be prioritised and there will be a cut-off point when the money runs out. We have seen no architects' proposed site plans showing each area with all the necessary infrastructure in place. You have provided no idea of potential costs at all. You have provided no results of studies at all. Warwick has already lost its police station and fire station, roads are completely congested at peak times, schools are drastically oversubscribed and have no places (particularly Myton which is the catchment area), the hospital is at breaking point and cannot cope with the load, having day surgeries and evening clinics to clear backlogs and lack of parking leads to innumerable late attendance for appointments, and the police haven't a clue how they can cope with more communities. Utilities such as water, sewers, electricity provision will have to be provided at escalating massive cost.

CIL

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

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

 
Air Quality/Traffic

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

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

The traffic congestion that Warwick already suffers will increase by a possible 6,000+ extra cars from extra South Warwick housing alone, let alone the increase from 10,800 new homes, bringing with it increased pollution in areas where air quality is already over the limit. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. Air quality remains in breach of these regulations and will become toxically high with the 27% increase in traffic volume resulting from the Local Plan preferred options. There is no management plan to address these levels. The County Council admitted that air quality will suffer as carbon emissions will increase in surburban sprawl. You admitted that you did not know how the carbon emissions could be reduced by the 20% currently necessary. It therefore seems incredible that the large-scale housing developments on the edge of Warwick are suggested with a likely 40% increase in the town's population, over 15 years. This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?

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

Myton Road, Banbury Road and Europa Way are all highly congested with long queues or at a standstill at peak times including the Town centre and often emergency vehicles cannot negotiate a way through, even via the pavements. If the closed Warwick Fire Station were to be relocated at Queensway, their vehicles would experience increased problems and response times would be worsened. There is a suggestion that Europa Way could be widened but this would exacerbate bottlenecks when the traffic reaches the roundabouts. The County say they can mitigate but not contain the resulting increase in traffic and admit there are places where congestion will worsen.

Historic Environment

Pinch points at bridges cannot be alleviated and the 300-year old Castle Bridge already carries 20,000 vehicles per day and cannot sustain an increase in traffic without threat to its very structure. We should be trying to reduce this traffic to prevent the bridge collapsing, not increase it. The NPPF (112) states "As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional." The precious historic and listed buildings in Warwick are being damaged by traffic vibration and pollution and this problem will only worsen. Increased commuting traffic must not be funnelled through Warwick's congested urban centre. Danger to schoolchildren and others is currently problematic on our roads and will be exacerbated near schools such as at Woodloes and Aylesford/Newburgh.. We are given no concrete proposals for new roads, only ideas. A North Leamington relief road suggestion could cost £50million+ and the idea that the A452 could be routed to the Fosse - one of the most dangerous roads in the County is preposterous. The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and on to the M40 will have the opposite effect at the eastern end of Myton Road with the addition of Morrisons and the proposed trading estate and Aldi supermarket all exiting out on to the double roundabout system. The present Plan does not address these traffic problems sufficiently and should be "refused on transport grounds where the residual cumulative impacts of development are severe (NPPF 32).

Conclusion

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

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

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

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

Attached letter

Scanned representation

1 INTRODUCTION
1.1 RPS Planning and Development (RPS) has been instructed by Lenco Investments (Lenco) to
prepare representations to the Warwick District Council New Local Plan Preferred Options
consultation document, in respect of their land interests at Baginton.
1.2 Warwick District Council (the Council) has proposed their Preferred Options in terms of housing
and economic growth and their vision for the district generally over the plan period to 2029.
These are currently being consulted upon until 27 July 2012.
1.3 RPS has made representations on behalf of Lenco to the previous stages of both the Warwick
Local Development Framework and the Coventry Core Strategy, to ensure a suitable approach is
taken to cross boundary development led growth.
1.4 Lenco's land interests at Baginton relate to a site which lies to the south of Baginton village
situated within the Green Belt, as shown at Appendix 1. It is important to note that Lenco has the
controlling interest in the majority of this land.
1.5 The site Lenco has interests in lies to the south of Baginton village, and. The site extends to
approximately 50ha and is in a sustainable location within easy access to Coventry City Centre,
close to the perimeter edge of the airport, with excellent cycle, pedestrian access to the
surrounding areas, and vehicular access to major transport links such as the A45 and A46.
1.6 Whilst the site falls within the local authority area of Warwick District it remains very close to
Coventry's administrative boundary, as well as the major sub regional employment base centred
on Coventry Airport. RPS is aware of the current proposals to expand Coventry Airport, and a housing development at Baginton would support these expansion plans.
1.7 The representations, therefore, address the need for housing growth within Warwick
administrative boundary and suggest that large-scale growth should be situated within close
proximity of employment development to ensure that people can live and work in close proximity.
Such proposals will support the Government's objectives to encourage economic growth in order
to revive the economy. Furthermore, these representations address the need for cross-boundary
growth and for full and proper cross-boundary working to be established between, Warwick,
Coventry and Nuneaton and Bedworth Boroughs as required by the Localism Act and NPPF.
1.8 The following chapter provides details about the site at Baginton, and our comments in response
to the Preferred Options document are provided in Chapter 3 and are set out in the same format
as the Council's response forms.
1.9 RPS are willing to meet with Planning Officers from Warwick District Council again concerning
Lenco's land interests and the New Local Plan process to discuss the potential of the site in
meeting local housing needs.
2 LAND SOUTH OF BAGINTON
2.1 The site Lenco has interests in extends to approximately 50ha and lies to the south of Bagington
village. The site is in a sustainable location close to Coventry City's boundary and the urban
area, and within easy access to the City Centre, and major transport links such as the A45 and
A46. The site, being close to the perimeter edge of the airport, with excellent cycle, pedestrian
and vehicular access, provides an exceptional opportunity for the provision of balanced housing
growth in the most sustainable manner.
Planning Policy
2.2 The Local Plan Preferred Options promotes 10,800 new dwellings within Warwick District for the
plan period up to 2029, at an annual delivery rate of 600 dwellings a year.
2.3 Evidence advanced by the West Midlands regional assembly for the West Midlands RSS
Examination in July 2009 from the Cambridge Centre for Housing and Planning Research,
based on 2006 ONS Household Projections and allowing for the economic downturn, concluded
that Warwick District's housing requirement between 2006 and 2026 was 18,200 dwellings at a
rate of 910 dwellings/year. Whilst the RSS is not longer in place, the evidence base is still to be
taken into account by Local Planning Authorities in preparing development plan documents.
2.4 The 2012 Strategic Housing Market Assessment indicates a requirement of 698 dwellings a year
to meet the affordable housing needs of the District in addition to market housing needs, which
is significantly higher than the level of housing currently being proposed by the Council.
2.5 The 2008 ONS Household Projections predicted an increase of 17,000 households between
2008 and 2028, at a rate of 850 dwellings a year. This represents an additional 150 dwellings a
year than is currently proposed through the Local Plan, which clearly will not meet the District's
identified need for new homes.
2.6 RPS is also aware that the 2012 SHLAA indicates that the District has a supply of deliverable
sites to provide 13,385 dwellings between 2014 and 2029, excluding windfalls, which is greater
than the numbers proposed within the Local Plan. Therefore the Council has identified the
ability to deliver housing sites at a higher annual rate than is currently proposed through the
Preferred Option.
2.7 RPS, on behalf of Lenco, therefore believes that the proposed figure of 10,800 new dwellings is
insufficient and that a higher level of growth would better reflect the projected population
increase and ensure that identified housing needs can be met, as suggested within the evidence
base. The Council cannot meet a higher target without locating housing on greenfield of Green
Belt land, and therefore should consider sustainable locations outside of the urban areas to
ensure housing needs can be appropriately met.
Cross-boundary Growth
2.8 The NPPF states that Local Planning Authorities have a 'duty to co-operate' on cross-boundary
planning issues, in particular for strategic priorities including housing, to meet development
needs which cannot be met solely within their own administrative boundaries.
6 rpsgroup.com
2.9 It has been recognised in Coventry's SHLAA assessment that the Council cannot meet their
housing targets on land within their administrative boundary alone. It is considered, therefore,
that Green Belt locations on the periphery of the urban area should be recognised as
appropriate locations for accommodating future growth.
2.10 The Green Belt south of Coventry was recognised through the Warwick Core Strategy process as
being an appropriate location for accommodating future growth of the City. Although the site is
within Warwick District it lies close to Coventry's administrative boundary, as well as the major
sub regional employment base centred on Coventry Airport.
Coventry Airport
2.11 Whilst both Coventry Airport's major sub regional employment base and Baginton village are
located outside of Coventry's local authority boundary, they are socially and economically
associated and physically adjoin the Coventry urban area. Residential development in this
location at Baginton could balance the existing significant employment base on the southern
side of Coventry, such as those around the airport at Stonebridge Trading Estate and
Middlemarch Business Park, both of which are within a very short distance of the site, as well as
the air freight and terminal employment opportunities.
2.12 RPS is also aware of the current Coventry and Warwickshire Gateway Scheme proposals
(Appendix 2) to expand Coventry Airport, and a housing development at Baginton would support
these expansion plans. RPS recommends that housing supply is focused in those areas where
there are important benefits to be gained where future economic growth is planned.
Site at Baginton
2.13 A residential-led mixed use development at Baginton could contribute sustainably to crossboundary
growth as required by the NPPF, and to meeting both Warwick District and Coventry
City's housing needs by delivering approximately 1,000 new homes either in isolation or as part
of the wider regeneration proposals for the area. The location of the site in relation to the
Gateway proposals is shown at Appendix 3.
2.14 Development at this location would also allow for new facilities and services to be provided,
making the best use of existing and proposed infrastructure. The site can be appropriately
phased over the Local Plan period to develop an available, suitable and deliverable urban
extension proposal.
2.15 The promotional document 'Land south of Baginton: A Sustainable Urban Extension' prepared in
2008 has previously been submitted to the Council and provides further details of how the site
could be sustainably developed.
2.16 In addition to this, extensive technical surveys in relation to flood risk, noise, ecology,
conservation and heritage, landscape, and highways have been undertaken of the site and
submitted to the Council, to demonstrate the site's suitability for a significant residential-led
development either in isolation or in connection with proposals for the wider area. An Air Quality
Assessment will also be undertaken to demonstrate the site's suitability for development.
2.17 RPS, therefore, considers that to help deliver greater sustainable development opportunities, it is
important that sufficient housing land comes forward in areas of proven market demand, such as on this Green Belt site to the south of Baginton, to contribute towards delivery of additional
dwellings and higher levels of growth to meet the needs of both Councils.
2.18 Responses to individual policies and topics within the Preferred Options consultation document
are included in the following chapter

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.

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