PO1: Preferred Level of Growth

Warwickdc.gov.uk/newlocalplan
PO1 Preferred level of Growth Full version Whole District
SUPPORT
The Leamington Society considers the growth forecast to be realistic because of the excellent rail links, the good education and employment opportunities and the attractive environment of Warwick District.

The SHMA calculation for houses required is based on old informtion and estimates. If the correct data is used correctly, taking into account 2011 census result - population is 136,000 in 2011, based on ONS data for the last 10 years, then 254 homes/annum are required for the next 15 years, a total of 5336 including a 5% contingency. This is for the same projection1 in the plan, so the 10,800 homes is not correct.

I believe that the various interpretations of the surveys and projections for housing growth are very subjective and an overestimation.

This is a greater density of growth than was favoured in the public consultation

SUPPORT WITH RECOMMENDED AMENDMENTS TO PO1

Having regard to existing and forecast housing need, plus the latest identified capacity of potentially suitable, available and achievable housing sites within the District over the period to 2029 (as presented in the SHLAA, May 2012), we consider that the Preferred Level of Growth under Policy PO1 should be a MINIMUM delivery requirement, net of demolitions, and not an absolute target i.e. a housing requirement that may be exceeded where justified by evidence of need, demand, affordability and sustainability considerations.

The proposed Plan Period, 2011 to 2029, is supported and is considered consistent with advice in the NPPF which calls on local authorities to draw up their Local Plans over an appropriate time scale, preferably a 15-year time horizon, and to take account of longer term requirements.

I know that the council has published a Strategic Housing Market Assessment purportedly supporting anticipated growth levels, but I still have concerns that you are proposing to build too many houses in such a confined space. Do we really need that many houses? It is important to protect and maintain the character of the area for its existing residents - i.e. the current ratios of open land to built up residential areas. Part of the appeal of my family moving from Bristol to Warwick Gates was the "countryside feel" which you have living in and around so much open space. I am concerned that you will erode this quality and many will consequently think about moving back outside of the area to find it.

I have read your booklet 'local plan' preferred options summary May 2012.
Could you please, advise me as to how you are going to allow all these housing builds to take place? Warwick A&E department cannot cope as it is, as on most nights, there is a 4 hour wait and most cases re sent to Coventry NHS Trust. Warwickshire fire and rescue service is now under its greatest stresses, due to cuts to retained officers. Warwickshire police cannot cope with the amount of incidents they are having to attend.
There is also a lack of schools and dentists.
As a council you cannot even maintain the roads to a reasonable standard. You need to get the town back to a standard so it is proud to call its self Royal Leamington Spa.
The bottom of town is known as the Bronx. Areas like Fallow Hill and Lillington are more important to make a community proud to live in. Stop letting the pound signs in your eyes ignore the deprived areas already existing.
This town cannot cope with the amount of new builds. You don't have any concern on how the cost of car parking has driven away no end of trade within the town with the rediculous car parking fees charged. In Coventry where I now choose to shop for most of the day, it costs me £1.50. You constantly ask the publics view, but take no interest in what they say and ignore there views. All you are interested in is how much as a council you can claim of the households. You have no concern on how the emergency services will cope or hospitals.
I suggest you look into this before agreeing to allow more housing builds. Are you going to consider, with the amount of houses you are planning to allow to be built, that there will be a large amount of children and youths who will have no where to go and nothing to do causing even more potential antisocial behaviour.
As a council, I have never known one to waste as much money as you do on the most ridiculous resources as you do, then complain you have no money.
It is widely recognised that a large percentage of council house tennants do not pay council tax, therefore leaving us taxpayers to make up the shortfall. As the majority of the community are taxpayers and non benefit claimants, we already bear the brunt of you're economic failures. What percentage of the residents of these new developments will not have put one penny into Britains economy but deem to meet your criteria

We wish to register our objection to the New Local Plan for the following reasons:

1. The development of housing and associated infrastructure planned for the precious green belt land to the north of the town and the construction of a new link road from the A452 to the A46 through Old Milverton, when better alternatives exist involving less cost to the environment and most probably also in monetary terms.
2. We accept that new housing is needed in the district though the estimates of the numbers required look well in excess of reality. We think it would be a tragedy for future generations if Green Belt land is lost when other good alternatives exist such as:
a) Land between Whitnash and Radford Semele and South of Leamington towards Bishop's Tachbrook
b) Hatton where good rail and road access already exists
3. The development does not appear to cater sufficiently for pedestrians and cyclists.

The plan gives the impression that it was started from the premise of taking the Green Belt land and all the verbiage in the plan then sets about trying to justify it.

We very much hope there will be a fundamental re-think before lasting damage is done to our local heritage, which future generations will deplore.

I am writing to let you know that whilst I understand you believe the new proposition could be positive for Warwick DC, I strongly object to the proposals for the new houses on our North Leamington Greenbelt, the out of town shopping centre, new supermarket and the feeder road through the fields of Old Milverton on the grounds that: the very special circumstances cited to justify damaging the Greenbelt are invalid.

I also disagree with your statement "if a proposal is not approved, builders will be able to build anywhere they like." Planning permission will always be required and therefore could still be rejected if inappropriate.

I'm amazed that you were able to propose building on the Greenbelt when the Government has recently re-emphasised its protection for the GB in the new NPPF. Even Warwick District Council's objection to HS2, sited the unnecessary irriversable damage to the environment as part of your argument! Clearly the Council have double standards. Especially when you have already previously identified many suitable brown and white field sites, including the ones in your 2009 proposal. Why have these sites now been discounted?


New Out of Town Shopping Centre
The District doesn't need another out of town shopping centre. We already have one out of town shopping centre on the Shires Industrial Estate which is linked to a wonderfully adequate infrastructure. It currently has a large empty unit and room for expansion on the other units (by adding second floors, which some have already done).

What retail businesses do we expect to attract to North Leamington anyway? The usual out of town retailers like Currys, Outlet (inc DP, Topshop, Wallis, Burton etc), Mothercare already have locations in the Shires. Do you want the remainder of the town centre shops to move out and take up residence there, making them ghost towns?

In Leamington Spa town centre there are numerous empty retail units, including the large, not so old shopping centre - Regency Arcade. Shouldn't we be filling these up first? Town Centres used to be the hub of social activity. If you build more out of town shopping centres, you will no doubt kill even more of the local shops in our town centres and people will no doubt loose their jobs. If free parking in town was offered again, this would help jump start inner town spending.

We don't need a park and ride. If you go into town during the day, there are numerous spaces available on the streets - thanks to the parking meters. Also the multi story car parks are never full.

In addition to this, internet shopping is increasing all the time. At present, they say that £1.30 in each £10 is spent online. Shops will be effected and become less desirable should this trend continue, which it almost certainly will. With the above in mind, I believe we need to look at things that will not be effected by the internet like tourism, agriculture and services which we are already good at in Warwick District. Stoneleigh Estate are currently working on a proposition which will create employment and makes much more sense.


New Proposed Supermarket, Blackdown
How many Supermarkets does a town need! I looked on Yell.com and noticed that we already have at least 20 supermarkets in Warwick District.

Even if the new dwellings are built, we already have access to adequate supplies from the existing supermarkets. Tesco Warwick and Tesco Metro (on Leamington Parade) are both under 2 miles away from the proposed development. Tesco Cubbington Road is just over 2 miles away. We also have a huge new Morrisons being built on the old Ford Foundry.

Are we allowing them to build on our Greenbelt as part of a Section 106 agreement, to raise funds for the rest of your proposals? Raising funds is not an exceptional reason to build on Greenbelt land. It is a fact that the Supermarkets kill our local businesses. Greengrocers, butchers, bakers and pharmacies, even news agents are going out of business and our town centres are filled with empty units where they once were.

When I was younger, my mother travelled 3 miles to do her shopping. This was acceptable back then and the likes of Tesco, Sainsburys, Asda, Morrisons, Waitrose etc are killing the local businesses. Look at what's happened on Coten End after Sainsburys moved in! We are in danger of being taken over by the Superstores and killing the soul of our towns.


New Houses In North Leamington Greenbelt

The number:
I understand some new houses may be required but not on the scale you propose. I dispute your calculations on the number of dwellings required. You propose that we need 11,000 over 15 years in addition to the numerous new developments currently under construction which have not been sold or rented.

Since you produced the report, new planning permission has been granted for more and buildings, including the Dementia Unit on Milverton Road. I'm sure there will be more over the next few years in addition to these you are proposing. I would be pleased if the equivellent was deducted from your plan as this was not approved at the time of your plan making.

People extend their houses to make more bedrooms / granny annex's and build new houses on large back gardens all the time, thanks to new planning regulations. Some developments are unfinished because they cannot fund the final stage, due to lack of demand - eg Portabello.

Currently, a large percentage of rental properties in the district are inhabited by students of Warwick University. With tuition fees of up to £9,000 per annum, increasing, it is likely that the number of students are already reducing. Therefore there will be numerous houses and apartments available to rent.

The Government are looking at the housing benefit policy. If this goes ahead, the under 25s won't get benefits and will therefore not be able to afford to rent local houses and apartments.

To help local employment and to preserve our beautiful historic regency town of Leamington, I strongly believe the Council should be looking to improve Warwick District through Urban Regeneration in the very first instance. This would give small local building companies, plumbers and electricians work which is very much in short supply. Surely, we want to support our local businesses first over national building companies.

Currently, there are more houses on the rental market than meet our demands and numerous vacant properties for sale, vacant possession. As an example, there is a 12 bedroom property for a mere £800k on St Marks Road, Leamington. This would make an excellent Residential Home, several large flats or even a good home for several single parent families.

forget the 'big boys' who are not interested in small sites, but look to regional and local builders - who bring added sustainability benefits, such as keeping money local, reducing travel to site and providing jobs within the immediate locality.


The Location
The land you propose to build on in Old Milverton is "A grade" agricultural land which enjoys significant protection from development. It is referred to as 'Best and Most Versatile' land.

The old IBM site is huge and is already well linked to the bypass and services. You could fit over 1,000 family homes on there, even more homes for the elderly. I've heard rumours that ASDA (yet another Supermarket!!!) wish to develop it. Under the circumstances, it would be unethical when you say brown field sites are a priority for dwellings. There is also the old Hobsons Choice public house on Spinney Hill and several sites along the canal (Wharf St, Nelson Lane) which could be developed into desirable dwellings, whilst at the same time, making the area more attractive.

Why do the new developments in rural areas need to be so big anyway? Why not have small developments in each area and spread it out over the district where sites are available? Is it because the developers you have in mind aren't interested in this?

By building the houses, Old Milverton will no longer be a hamlet, which is inconsistent with 7 of 4.11 of your objective. It does not respect the integrity of existing settlements.

In your report, you state that most the employment is in South Leamington. With this in mind, surely the best position for the new houses, to avoid congestion in North Leamington would be South Leamington - Barford even Radford Semille way.

If new rural dwellings are required, they should be kept on a very small scale and in the character with the other dwellings in the settlement, maintaining the charm of each existing development. Large new developments on Greenbelt land are not the answer.

I mentioned the Stoneleigh Development earlier. Should this go ahead, isn't it sensible to find a location in that area for a small percentage of the houses, if only 50 of the dwellings, if you are trying to discourage reduce car usage?

New Proposed Road to Feed Into the A45 from Milverton Road
This proposal is a contradiction to point 7 of 4.11 of your objective. It does not respect the integrity of existing settlements, in particular, Old Milverton Village.
If you are making improvements to the A452, why is this road needed?

Should it go ahead, it will only reduce the distance for users by 2 miles, (2 minutes drive time) if they get off this junction instead of the Kenilworth junction so how can the reduction of valuable agricultural land and destruction of our Greenbelt be justified, financially or morally.

It also goes against objective 13 of 4.12. The road, leading up to the new proposed development is well used by cyclists, joggers, walkers and horse riders at present. Should the proposed road go ahead, the road will become a busy road making it unsafe for current users to enjoy. Especially because there is no pedestrian pathway alongside the road.

As I write, there are already daily traffic jams at the A45 exit by the Saxon Mill on Coventry Road, which will join the feeder road. Having a feeder road will only make this conjestion worse - a contradiction to point 4 of 4.11.

If the Council wishes to ease congestion on Kenilworth Road I believe the Council should provide better bus services in rural areas, especially during rush hours. It would be even more effective if busses had priority over cars on the roads. Also, if the road out of Hill Wooton onto Kenilworth Road was changed so it was left turn only, this would help congestion. Perhaps this could be done on the Kenilworth Road?
Who's going to use it? If it is to help people get to the proposed out of town shopping centre in North Leamington, it will not be required. People in Coventry, Stratford Upon Avon and Birmingham all have more than adequate shopping centres and certainly won't make a special effort to come to ours. Especially as all out of town shopping centres tend to be filled by the same shops.

The suggestion of a feeder road is a further contradiction to objective 4.11.4. The fields surrounding Milverton and Old Milverton (leading down to the Saxon Mill) is already, today, meeting the objective you set in this section and is a much loved and well used, safe route for cyclists, runners, nature photographers, walking groups and dog walkers. People like the route to get escape from urban life and it's important to have this close to North Leamington residents, without having to get into a car. There is nowhere else we can use within walking distance. If you make these changes, a big ugly bypass or any type of road running through this field will most definately make this an unattractive, unhealthy, unsafe option. If you really want to encourage people to be more healthy lifestyles, we need this area to remain untouched. If we loose our open land, we will have to get into our cars to find a similar option.

As a result of the feeder road, there will be additional traffic conjestion where the Rugby Road meets the Old Milverton Road and increased traffic through Milverton (not just from the new houses). It is hard enough now in the mornings to get in and out of the Old Milverton Road to / from Rugby Road. You will need to introduce a new traffic management on the entrance and the Old Milverton Road. Additional crossings will be required to ensure safe crossing for the walking school route for residents of Milverton and Old Milverton and it will become a busy main road.

Again, this will create the opposite of objective 13 of 4.12. The Old Milverton Road is also enjoyed by parents of children, and children attending Brookhurst and Trinity. We use this route to walk into Leamington regularly. It is a nice quiet, low traffic, pretty rural, safe road with a short cut under the railway bridge to Beverley Road. I would not be happy for my young children to use this road if it becomes a busy highway, which will happen if the new proposed road goes ahead. Improvements to this road will be required to keep it safe and so it doesn't become conjested.

Your plan states that Warwick District wants to be low carbon producing. We should look at building and improving cycle paths and public transport links / services. Not building new roads on our Greenbelt and on our limited grade A agricultural land.


Wildlife
We have a family of little owls who nest in our village every year and perch on our Victorian walled garden and surrounding trees throughout the day. Last year we were lucky enough to see a falcon in the garden. Although I don't think they are classified yet as endangered, the numbers are declining rapidly. I presume through over-development of rural areas. The other birds of prey like buzzards and eagles can be seen regularly too. Due to a previous builder's wildlife report not being published, some people believe there is a possibility of great crested newts in the area. I know we have some but as I don't know what crested ones look like, I can't confirm ours are or not. This would need to be verified.


Evidence Pack
Finally, after reading the evidence pack, the questionnaire used, I thought was leading so I think this should be discounted as evidence.


I hope the points raised have been useful and that my objection is registered appropriately. If I need to do this in any different format to make it valid, please let me know.

We have examined the above proposals with great interest and we write as residents of the Milverton area of Leamington Spa for over forty years. We, therefore, have some knowledge of local needs and conditions. We are restricting our comments to the proposals for North Leamington although we expect that there will be common ground with a number of the other sites.

We believe that the options as published are flawed on a number of fundamental grounds.

1. PO1. Past performance is no guide to the future. The projections for growth between 2011 and 2029 are overly optimistic and even if achieved there is no need to develop the green belt to the extent proposed.

2. The proposal to develop green belt land to the North of Milverton and at Blackdown is completely contrary to PO4 D. Furthermore, the paper does not provide the evidence required under NPPF to permit development in the green belt. Where are the 'exceptional circumstances'? The study appears to be highly subjective and indeed selective.

3. Insufficient use has been made of available, non-green belt land to the South of the town. This is also the area where the bulk of the potential employment for the new residents is already located.

4. The need for infrastructure development to service the Milverton/Blackdown proposal will be out of all proportion to any possible benefit. £28 million for a Northern Leamington Relief Road would divert scarce resources from other much needed public investment, let alone ruining the amenity value of space around Old Milverton.

5. There appears to be real risk, if these proposals proceed, of North Leamington and Kenilworth coalescing at some point in the future with the consequent loss of identity and in direct contravention of one of the basic tenets of local planning.

In summary, we object in the strongest possible terms to these seriously flawed plans. One of the goals of the NPPF is to protect communities and green belt land from unpopular local plans. The present proposals seem to flout that goal at almost every turn.

A great deal of time, money and energy has already been expended by the Council but that is no reason to proceed along the lines proposed and ruin the future amenity of many local residents.

Scanned Letter

Scanned Letter

1. Preferred Level of Housing Growth (Policy PO1)

Warwick District Council must ensure sufficient provision is made to meet population and household growth forecasts. Neither the Preferred Level of Growth of 10,800 dwellings nor the alternative options considered would meet population and household growth forecasts and so may put pressure on Nuneaton and Bedworth to provide additional housing to meet this unmet need. Such additional growth would have to be accommodated on Greenfield land.

2. Employment Land (Policy PO8)

The level of growth for employment land is not identified, and it is noted that a flexible approach will be taken. The housing target is justified, in part, on the grounds of matching jobs growth to the increase in homes. It is not clear how this match will be achieved when the employment land supply will be flexible. This is of particular concern given the potential shortfall in housing provision.

In relation to the Warwickshire Gateway site it is the view of the council that there is limited justification for this type of site, particularly given the newly emerging growth proposals across the area. We would welcome involvement in the ongoing discussions around this site given the potential cross border implications.

3. Infrastructure Plan

It is noted that further work needs to be carried out in relation to your infrastructure planning. Nuneaton and Bedworth Council would be interested in being involved in this work as it progresses, specifically to identify if there are any opportunities for joint working in this area. In relation to some of the proposed policies such as PO8 it is considered that there is the potential for cross border impact, for example as a result of supply chain impacts, and therefore we are keen to work together as part of wider infrastructure planning.


4. Duty to Co-operate

The final choice of a housing target option and employment land approach may have implications for Nuneaton and Bedworth or other neighbouring authorities. This will require co-operation between the relevant authorities.

Introduction

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

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


The Preferred Options (PO1 to PO18)


PO1 Level of Growth

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

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

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


PO3 Broad Location of Growth

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

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


PO4 Distribution of Sites for Housing

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

Sites:

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

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


PO5 Affordable Housing

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


PO7 Gypsies and Travellers

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

PO10 Economy

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

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

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

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

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

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


PO11 The Historic Environment

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

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


PO14 Transport

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


PO16 Green Belt

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




The Key Issues


1. Vision and Growth

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

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

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

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

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


2. Sustainability

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

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

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

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


3. The Projected Housing Requirement

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

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


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

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

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

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

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

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

3.3 We have other major concerns about the population projections.

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

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

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

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

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

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

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


4. Proposed Locations for Housing


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

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

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

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

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

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

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


5. The Green Belt.


5.1 In para 79 of the NPPF, it is stated that "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence."

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

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

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

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

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

5.7 NPPF para 88 states that "local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations".

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



6. Employment Land Proposals

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Scanned Letter

Scanned Response Form

Scanned Response Form

The main point that I wish to make in response to the consultation is that, with regard to your Preferred Option 1, I strongly support Scenario 1 and especially the assurance that there would be no building on farmland, with no potential increase in risk of flooding as a result.

Scanned Letter

See attachment

I am writing to you to object to your Proposed Preferred Option plans, because you could have adopted those prepared in 2009 for the Core Strategy Plan, which did not require the use of Precious Green Belt Land. These previous plans would have been much less expensive as they did not require the extravagance of a whole new infrastructure, which we do not need.

PO1 Preferred Level Of Growth

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

PO2 Community Infrastructure Levy

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

PO3 Broad Location of Growth

We support the Preferred option for Growth.

PO4 Distribution of Sites for Housing

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

PO5 Affordable Housing

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

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

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

PO6 Mixed Communities & Wide Choice Housing

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

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

PO16 Greenbelt

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

scanned submission

I have been reading the New Local Plan consultation document and I am in complete agreement with most of it.

1. Particularly important are that you have identified the need to protect Green Belt sites and historic areas, buildings etc.
2.My Preferred Growth Level would be Option 1.
3.Warwick & District should not become commuter overspill for the West Midlands Conurbation!
4.Strong resistance to out-of-town retail developments.
5.Inappropriate development will not be given planning permission.
6.The quality of the built environment is high but there are certain sites that would benefit from improvement.
7.Protect / enhance historic environment and ensure new development is in keeping with surroundings.
8.Some farm buildings could be converted for residential, employment & retail uses where appropriate as an alternative to greenfield development, as suggested.
9.Replace / enhance unattractive buildings and restore historic buildings to high standards.
10.Continue opposition to High Speed 2 rail link.
11.Agree with Green Infrastructure policies

I have 2 main areas of objection to the recently announced preffered strategy

1) The presumption for the need for growth. Land is put aside for jobs, which need more housing for the workers, who need more jobs, so more industry is catered for, which means more housing for workers etc... the cycle goes on.

In my opinion there are areas in the UK where it would be better to encourage more industry and have a surplus of either housing stock or brownfield land. Some of these places are not too far away in the west midlands.

It is also a false perception that new industry creates jobs for local people. Often new people move into the area for the new jobs using up the new housing stock. For instance a large percentage of Warwick gates residents are not originally from the local area.

By increasing housing the council will increase migration to the area and increase the urbanisation pressure.

It is also true that a lot of this housing will be taken up by commuters to Birmingham, London and other locations.

So in summary the vast majority of this expansion is not needed

2) I have particular objection to the Whitnash East proposal. I presume local authorities are still being offerred a new secondary school as part of the scheme in order to gain access to the area. I particularly object to this development because; (some objections presume the same ouline as previous schemes)

a) General traffic
In my opinion this site will generate a lot of traffic with only one obvious access point

b) Traffic on Golf Lane
With a pedestrian access point to the secondary school being located at the end of Golf Lane, many pupils will be dropped off by car in the morning in Fieldgate Lane causing a large amount of peak traffic on Golf Lane. This will be dangerous for pupils of Briar Hill and St Margaret's Primary trying to cross a road with no crossing point to go to their school. This will be increased by the additional fielgate lane proposal

c) Parking around Fieldgate Lane
Cars dropping off/ picking up children in Fieldgate Lane will create a very significant hazard and loss of quality of life for those residents. Again this will be increased by the additional fielgate lane proposal

d) Loss of wildlife habitat
Otters in the brook and foxes, hares, buzzards and other wildlife that is often in the field will lose their habitat.

e) Flooding
Some of the fields in question are often subject to flooding. Any work to reduce their flooding risk could lead to increased risk elsewhere.

f) Primary Schools
The development of Warwick Gates has already led to issues surrounding the shortage of primary school places in the local area. These new houses will be even closer to Briar Hill and St Margaret's Primary so there will be even more parents chasing few places.

g) Loss of community facility for Sydenham
The moving of Campion school will cause increased travel and a loss of a community facility for the existing residents of Sydenham

h) Why does Whitnash always get the new developments
The character of the Whitnash area has already been greatly scarred with the development of Warwick Gates, Dobson Lane, recent Chesterton Heights/Sydenham encroachment on the countryside and extension of the South Farm development. It is time that other areas of district share in the development (if indeed it is truly necessary).
i) Is it needed at all (please see point 1

j) In terms of access to the road network development south of Warwick Gates would be better. I assume this was dropped as a response to the residents organised and vocal objections and political consequences.

I was impressed by Cllr Caborn's presentation at last night's meeting in Lapworth Village hall, because it seems that his department is doing a very competent job in working out a plan to satisfy HMG's demands for new developments to accommodate an increase in population during the coming 15 years.

Having said that, it seems to me that the Government's instructions are unwarranted, because I do not believe that there is a need for such an increase in population, nor do I believe that there is a need for the new HS2 railway. I understand that it is not in WDC's remit to question either of these fundamental requirements, so it is essential that the general public should question them; they must not be taken as read.


In preparing the Local Plan, WDC have been instructed to take no notice of HS2, but the new railway line will have a major impact on the environment and on the transport services available in the region, for which WDC must offer credible plans. WDC cannot prepare a credible plan with this constraint.

It is grossly unfair to expect any planning authority to carry out a long-term plan without questioning at least these two major points. If sensible action were taken to restrain immigration and to design a rail service which is accessible to ordinary people (as distinct from HS2, which will only be used by the well-off) WDC's plan would be very different.

We represent the West Midlands HARP Planning Consortium which includes all the leading Housing
Association Registered Providers (HARPs) across the West Midlands. Our client's principal concerns are
to optimise the provision of social / affordable housing and to ensure the evolution and preparation of
consistent policies throughout the region.
PO1: Preferred Level of Growth
The preferred level of growth identified would fail to meet even the basic level of affordable housing need
identified in the 2012 SHMA of 698 affordable dwellings per annum. For this reason Preferred Option 1 is
not supported. Our previous representations to the 'Helping Shape the District' consultation indicated that
the preferred options should be based on a full, robust evidence base, and the Council now has this to
rely upon.
The decision to bring forward a very basic level of housing growth across the District is likely to result in a
much lower level of affordable housing being brought forward over the Plan period than is necessary due
to significant viability constraints on development. The SHMA notes:
"Given the viability of residential development within the District and the availability of funding for
affordable housing, it is unrealistic to assume that all housing needs can be met. ... the supply of
affordable housing is likely to fall short of identified needs. The Council should look to maximise provision
of affordable housing where possible, including in working proactively with developing RPs ...." [Our
emphasis]
The implications of providing just 4,320 affordable dwellings over the lifetime of the plan needs to be
considered as part of the wider housing target. This reduction in the general housing target, and
subsequent reduction in the deliverability of affordable dwellings is very significant and will have a further
detrimental impact on housing waiting lists and affordability across the district. A single affordable
dwelling was completed in the monitoring period 2010/2011. With significant uncertainty as to general
development viability and the Affordable Housing Viability Assessment indicating variable viability across
the district, it is important for the Council allow sufficient flexibility in the housing land supply target to
secure affordable housing.
The Local Plan should be aiming for a much higher figure to take account of the need not only for
affordable housing delivery, but also to plan for economic growth across the district. We recommend that
a minimum target should be that set out in the SHMA, of 11,900 dwellings; the SHLAA indicates a more
substantial 13,385 dwelling capacity across the District to 2029 which could accommodate that minimum
target.
Unit 2 Eclipse Office Park Staple Hill Bristol BS16 5EL
T: 0117 956 1916 E: all@tetlow-king.co.uk
F: 0117 970 1293 W: www.tetlow-king.co.uk
2
PO2: Community Infrastructure Levy
We support the Council's intention to bring forward CIL.
PO3: Broad Location of Growth
We support the Preferred Option for growth. We do however recommend that the Council clarify that the
hierarchy will allow for development at smaller villages. The NPPF states:
"In rural areas, exercising the duty to cooperate with neighbouring authorities, local planning authorities
should be responsive to local circumstances and plan housing development to reflect local needs,
particularly for affordable housing, including through rural exception sites where appropriate. Local
planning authorities should in particular consider whether allowing some market housing would facilitate
the provision of significant additional affordable housing to meet local needs.
To promote sustainable development in rural areas, housing should be located where it will enhance or
maintain the vitality of rural communities. For example, where there are groups of smaller settlements,
development in one village may support services in a village nearby." (NPPF, paragraphs 54 and 55)
By the use of this minor textual change, the Council will signal flexibility to development at villages with
housing need but where there are no infill opportunities. As shown above, this approach is in line with the
NPPF and the Council's own commitment to meeting housing need across the district. The Council can
control the extent of development at rural villages by requiring this to be proportionate in scale to the
settlement size and housing need.
PO4: Distribution of Sites for Housing
B. Category 1 and 2 Villages
We support the establishment of new village boundaries to enable development to come forward at rural
villages. In addition to discussion with Parish Councils, Warwick District Council should also ensure
consultation with local landowners and developers, including HARPs, to support development in the most
sustainable locations. We support the removal of land within village envelopes from the Green Belt.
D. Development on Greenfield Land
We support the proviso that affordable housing development will be permitted on greenfield land.
PO5: Affordable Housing
A. Affordable Housing on Housing Development Sites
We support the Council's intention to seek 40% affordable housing delivery from new residential
developments, as this is supported by the Affordable Housing Viability Report. The thresholds for urban
and rural areas are also supported, as this strikes the right balance between seeking affordable housing
from a high number of developments, whilst still making allowance for viability considerations.
We note the Council's intention to require affordable housing be retained in perpetuity. The NPPF
requires only that affordable housing delivered on rural exception sites be subject to this condition and we
advise therefore that the Council adopt this approach.
3
B. Affordable Housing on Rural Exception Sites
As per our comments above, we recommend a word change to state that rural exception schemes will be
permitted at village locations where housing development would not normally be permitted. This would
support the provisions already set out under this Preferred Option.
We strongly support the allowance of some market housing under this Preferred Option to support the
delivery of affordable housing. This is in line with NPPF definition of rural exception sites which states:
"Small numbers of market homes may be allowed at the local authority's discretion, for example where
essential to enable the delivery of affordable units without grant funding."
We are however concerned by the imposition of a 30% cap on the level of market housing to be permitted
to cross-subsidise affordable housing delivery. The reason for the level of the cap is not explained in the
justification section, nor is it discussed in the Affordable Housing Viability Report. It would be useful for
the Council to set out its reasoning for the cap figure as without this the policy is unjustified.
PO6: Mixed Communities & Wide Choice of Housing
B. Lifetime Homes
Whilst we support the Council's intention to seek a proportion of new residential developments as
meeting the Lifetime Home standards, a formal policy in the next draft of the Local Plan should recognise
the potential for those standards to change, as new standards could be implemented at a later date,
rendering the Local Plan outdated and ineffective.
C. Homes for Older People
We strongly support the Preferred Option for all strategic sites to include an element of Extra Care
housing. We also support the Council's intention to make allowance for Retirement Villages and
Continuing Care Retirement Communities (CCRCs). Locational factors, such as proximity to local shops
and public transport, should not be as strict as for general market housing, as Retirement Villages and
CCRCs typically provide a suite of on-site facilities which reduce the need for site residents to access
local services and facilities, as well as having a nil requirement for services such as local schools.
PO16: Green Belt
We support the Preferred Option for the Green Belt. The requirement however for affordable housing to
be brought forward "through a Neighbourhood Plan" removes the ability for development to be brought
forward on an ad hoc basis - for example where a community does not wish, or have the capacity, to
develop a Neighbourhood Plan. We recommend instead that a formal policy sets out the ability for
affordable housing to be brought forward, including through a Neighbourhood Plan, or otherwise where
there is evidence of need.

Thank you for the preferred Option summary and the work that has gone into a detailed plan of this complexity. The fact that it is so far reaching covering the areas of Kenilworth,Warwick, Leamington, Whitnash and surrounding areas makes it more difficult to respond to. For what its worth I give a few general and specific points.
In general it is difficult to see how the vision can be achieved by such a large increase in the number of dwellings to be built in some green belt areas. If we do need to provide for this expansion in our population which the current census indicates then it would be more honest to simply say that the vision is to do the best we can in an overcrowded town with all that implies to transport,services,safety,green areas and quality of life. It is difficult to believe things will be better when the plan is completed. The second general point is that new homes are required in a growing local and nationwide economy. We therefore need a much more detailed economic and financial plan to stimulate business development before we have a plan to build the houses. We might have a growing population but do we have a growing local economy to provide the wealth to buy those houses. This economic plan is touched on in the report but requires more infrastructure spending to attract business first. We will then know where to build the houses. It may be that a new town is required rather than filling in the empty spaces in towns with no jobs.
Clearly this report has been prepared with a lot of study and thought and therefore assuming you are correct in your prediction of a big increase in demand for houses in the area I can only contribute a few specific points in relation to the development at Thickthorn,Kenilworth which is were I live. This is the request to maintain the wooded copse or buffer on the land .Also to provide a new direct access to the A46 for the new estate.This will go some way to achieve in one area of the plan your objective to "make Warwick District a Great Place to Live, Work and Visit " It is at the moment it would be a tragedy if this plan achieved the opposite.

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

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

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

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

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

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

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

Now that the national economic model based on bank fraud has been found wanting and despite our inglorious politicians attempts to revive this model, it would be criminal to sacrifice any agricultural land where it was unnecessary or possible to do otherwise. In the not too distant future I foresee the need to provide a larger proportion of the nations food resources from our own land. Therefore the destruction of farmland to build houses should not be an option and I do not believe it to be necessary.

I have noted that the development at Portobello the site of the old Potterton facility is some way off being fully occupied, so I would question the need for large additional amounts of housing. Nor do I see any great draw pulling people into the area as I see that businesses are closing for example Pottertons and Fords have closed sites employing large numbers of people. Perhaps it would have been more appropriate to build houses on the old Ford site rather than another supermarket? The requirement for another supermarket is doubtful to say the least even though I personally have a preference for Morrisons. They do not create jobs as is often claimed, they just move them around.

Developers are always keen to build on green field and hence green belt sites because they can sell these properties at a premium and they can be easier to construct once permission is obtained. Decisions should not be made by democratically elected persons that favour the short term interests of the few at the expense of the long term interests of the many. However this frequently happens and it leaves the motives of the elected persons open to question or suspicion.

I therefore conclude that all plans involving incursions into the Green Belt or destruction of farmland should be rejected.