PO1: Preferred Level of Growth

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I wish to vigourously object to the building on green belt land in Blackdown and Old Milverton.

The Government's National Planning Policy Framework requires there to be "very special circumstances" for development in the Green Belt and for the harm created to the Green Belt to be outweighed by the benefit of the development. Those special circumstances are apparently that there is nowhere else for the homes to be built. In the "2009 Core Strategy" (the previous plan adopted by Wawick District Council) land South of Leamington was identified, and is still available, for development. This land is east of the A452 Europa Way and south of Heathcote towards Bishops Tachbrook. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure to support it. It is close to the M40 and there are existing employment opportunities South of Leamington.
* The previous plan is direct evidence that there are alternative areas for development other than the Green Belt. Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because the concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt. The policy of "spreading it around" again is not planning policy but a political one. Thus the legality of the councils desicion making process comes into serious question.
* The proposals ignore Warwick District Council's Green Belt Study of the land at Old Milverton and Black Down which concluded that these areas had high Green Belt value.

* Green Belt land is specifically set aside to prevent urban sprawl, stop towns merging together and protect the country side setting of historic towns. The proposals will reduce the" Green Lung" between Leamington and Kenilworth to less than 1 1/2 miles encouraging the merger of these two towns and their loss of independent identities.
* Turning the A452 between Leamington and Kenilworth in to dual carriage way will not help traffic flows. At peak times the delays on the A452 result from commuters wanting access to the Town centres.
* The proposals will have a detrimental effect on the picturesque northern gateways to Leamington and Kenilworth, it will change the character of Leamington for ever,.
* A "Northern Relief Road" (budgeted cost £28m) is not required. The traffic flows tend to be north; south rather than east; west. The road will serve no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns.
* A "Northern Relief Road" will form a natural barrier and encourage further development in the green belt up to this new road. It will need to be built across the flood plain (at considerable cost) and will violate an important nature corridor along the River Avon.
* The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area attractive places to live. Further "out of town" shopping will take trade away from the Towns.
* There will be a loss of a significant amount of high quality agricultural land in Black Down and Old Milverton
* The land at Old Milverton and Blackdown has substantial amenity value and is presently enjoyed by a great many walkers, runner, riders, and cyclists.
It provides a countryside environment close to the centres of Leamington and Warwick. Both the proposed building development and the "Northern Relief Road" would substantially reduce the amount of land that is available to enjoyed and have a detrimental impact on the ambience and hence the amenity value of the land. Turning some of it into a maintained park would detract from rather than enhance its value. There is no infrastructure problems to the previous chosen development sites in South Leamington.
* Warwick District Council has included a "buffer" of 1400 homes in the number of houses that it believes will be necessary between now and 2026. If this "buffer" is removed from the assumptions there is no need to include the land at Old Milverton and Black Down in the proposals. There has been in recent years an exceptional growth in Leamingtons population partly because of Europe. However this has now levelled of. There are not hundreds and thousands of homeless people sleeping in the streets of Leamington at night, so I seriously question the need for development of such a scale. The prime minister recently stated that people should no longer except free housing there friends and family should assist, by carrying out such a development the council is not working to the spirit of what the Prime Minister is saying, I for one will be writing to him to inform him of this. Further more there has been an extra approximately 500 student beds places created/about to be created in Leamington in purpose built buildings this year alone. This means talking to local agents that small houses are now not being rented by students and about an extra 100 5 bed homes are sitting empty this year, they are going to be either rented out to private tenants or DSS tenants or sold of private individuals or families, I feel the council has missed the point that about 500 extra beds spaces houses will be available this to the community, as student population is down by about 10% this year nationally, furthermore with the increase in fees this year, there is likely to be an even further decrease in the student population freeing up more housing.


To summarise I am objecting on the below grounds

1. Local amenity taking away our local open public space
2. Green belt, not adhering to policy when you have already suitable land for development.
3. Over provision of housing, as the sires previously declared suitable will inevitably be still developed, and student houses becoming available.
4. Coalescence of urban sprawl, towns will soon be close together losing their identities, which makes Leamington so special
5. Infrastructure. No need to spend £28 million on new road when there is infrastructure in place at the previous south Leamington sites declared suitable

I vigourously object to the building on green belt land in Blackdown and Old Milverton.

The Government's National Planning Policy Framework requires there to be "very special circumstances" for development in the Green Belt and for the harm created to the Green Belt to be outweighed by the benefit of the development. Those special circumstances are apparently that there is nowhere else for the homes to be built. In the "2009 Core Strategy" (the previous plan adopted by Wawick District Council) land South of Leamington was identified, and is still available, for development. This land is east of the A452 Europa Way and south of Heathcote towards Bishops Tachbrook. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure to support it. It is close to the M40 and there are existing employment opportunities South of Leamington.
* The previous plan is direct evidence that there are alternative areas for development other than the Green Belt. Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because the concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt. The policy of "spreading it around" again is not planning policy but a political one. Thus the legality of the councils desicion making process comes into serious question.
* The proposals ignore Warwick District Council's Green Belt Study of the land at Old Milverton and Black Down which concluded that these areas had high Green Belt value.

* Green Belt land is specifically set aside to prevent urban sprawl, stop towns merging together and protect the country side setting of historic towns. The proposals will reduce the" Green Lung" between Leamington and Kenilworth to less than 1 1/2 miles encouraging the merger of these two towns and their loss of independent identities.
* Turning the A452 between Leamington and Kenilworth in to dual carriage way will not help traffic flows. At peak times the delays on the A452 result from commuters wanting access to the Town centres.
* The proposals will have a detrimental effect on the picturesque northern gateways to Leamington and Kenilworth, it will change the character of Leamington for ever,.
* A "Northern Relief Road" (budgeted cost £28m) is not required. The traffic flows tend to be north; south rather than east; west. The road will serve no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns.
* A "Northern Relief Road" will form a natural barrier and encourage further development in the green belt up to this new road. It will need to be built across the flood plain (at considerable cost) and will violate an important nature corridor along the River Avon.
* The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area attractive places to live. Further "out of town" shopping will take trade away from the Towns.
* There will be a loss of a significant amount of high quality agricultural land in Black Down and Old Milverton
* The land at Old Milverton and Blackdown has substantial amenity value and is presently enjoyed by a great many walkers, runner, riders, and cyclists.
It provides a countryside environment close to the centres of Leamington and Warwick. Both the proposed building development and the "Northern Relief Road" would substantially reduce the amount of land that is available to enjoyed and have a detrimental impact on the ambience and hence the amenity value of the land. Turning some of it into a maintained park would detract from rather than enhance its value. There is no infrastructure problems to the previous chosen development sites in South Leamington.
* Warwick District Council has included a "buffer" of 1400 homes in the number of houses that it believes will be necessary between now and 2026. If this "buffer" is removed from the assumptions there is no need to include the land at Old Milverton and Black Down in the proposals. There has been in recent years an exceptional growth in Leamingtons population partly because of Europe. However this has now levelled of. There are not hundreds and thousands of homeless people sleeping in the streets of Leamington at night, so I seriously question the need for development of such a scale. The prime minister recently stated that people should no longer except free housing there friends and family should assist, by carrying out such a development the council is not working to the spirit of what the Prime Minister is saying, I for one will be writing to him to inform him of this. Further more there has been an extra approximately 500 student beds places created/about to be created in Leamington in purpose built buildings this year alone. This means talking to local agents that small houses are now not being rented by students and about an extra 100 5 bed homes are sitting empty this year, they are going to be either rented out to private tenants or DSS tenants or sold of private individuals or families, I feel the council has missed the point that about 500 extra beds spaces houses will be available this to the community, as student population is down by about 10% this year nationally, furthermore with the increase in fees this year, there is likely to be an even further decrease in the student population freeing up more housing.


To summarise I am objecting on the below grounds

1. Local amenity taking away our local open public space
2. Green belt, not adhering to policy when you have already suitable land for development.
3. Over provision of housing, as the sires previously declared suitable will inevitably be still developed, and student houses becoming available.
4. Coalescence of urban sprawl, towns will soon be close together losing their identities, which makes Leamington so special
5. Infrastructure. No need to spend £28 million on new road when there is infrastructure in place at the previous south Leamington sites declared suitable

PO1 Preferred level of growth
Representation: The Council is ignoring the opinion of the majority of respondents to the March 2011 questionnaire. Instead it is opting to use one isolated exceptional period of growth to substantiate its preference for unacceptably high development, apparently in the mistaken belief that housing growth would promote economic growth. We only need look at what has happened to the property market in Spain to see how catastrophic this would be.

Changes: The projection for growth should be based on a much lower, more balanced and reasonable expectation of level of growth.

PO3: Broad location of growth
Representation: It is essential to avoid development of Green Belt land, which affords essential open spaces and recreation opportunities where little else exists for public use nearby. Even if the highest level of projected growth were to be adopted, there is adequate land available elsewhere (eg in the Heathcote area) without encroaching on Green Belt land. The Council has, therefore, no grounds on which to justify the use of Green Belt land. Furthermore, to develop the areas of Green Belt land included in the proposals would necessitate a whole new infrastructure to the north of Leamington, which would in turn eat up even more Green Belt land - with disastrous consequences for one of our few remaining areas of untouched rural character, Old Milverton - whereas to the south the necessary infrastructure is already in place. If the Council it were to proceed with the current plans to decimate our countryside unnecessarily it would contravene national guidelines on the use of Green Belt, lose credibility, and as a consequence it would suffer severely in the next round of local elections.

Changes: I would urge the Council in the strongest possible terms to reverse its recommendation to build on Green Belt land, and to resist pressure from developers who are waiting poised to destroy our precious countryside. Instead I would urge the Council to concentrate development in logical, sensible locations, such as the Heathcote area.

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I write to offer comments on the New Local Plan, for the development of new housing in the Leamington and Warwick District area.

I object to the proposed development in Old Milverton and Blackdown contained in Warwick District Councils' Preferred Options for the Local plan.

I do not believe the re-drawing of Greenbelt boundaries is either necessary or appropriate for housing development. I believe the Council has failed to adequately demonstrate the validity of their planning assumptions, and that the number of new houses required is significantly overstated.
The greenbelt land at Blackdown and Old Milverton fulfils all five objectives for Greenbelt, as laid out in the National Planning Policy Framework, to which Government attaches great importance. This should have been key to the Council's assessment of their proposals, yet appears to have been widely over-looked or purposefully ignored.

The maintenance of the existing greenbelt is essential, not only to prevent Urban Sprawl to the north of Leamington and the merging of the two distinct towns of Leamington and Kenilworth, but to prevent the destruction of the individuality and character of the hamlet of Old Milverton. This would be destroyed for ever if the development of land at Old Milverton were to be allowed, let alone the addition of the proposed relief road to be driven along the route of Milverton Lane to the A46. I have no confidence that, were such development to be allowed it would only be a matter of time before the suggested 'green wedge' to the west of the development would also receive planning permission, destroying forever the individuality of Leamington, Old Milverton, Leek Wooton and Kenilworth.
In its' current form, the plan also fails to safeguard the countryside from encroachment. The land in question at Old Milverton is Grade 2 agricultural land in productive use. As food security becomes ever more important socially, environmentally and economically, it is folly to allow development of productive farmland in the greenbelt when no extraordinary circumstances are present to warrant such action.
The greenbelt also helps to preserve the unique setting of Leamington, an historic Spa town of special character which has been preserved and nurtured until now.
The preservation of Greenbelt also promotes innovative regeneration of derelict and other urban land within the existing developed areas.

I am also concerned that the new plan differs widely from that proposed in the 2009 Core Strategy. In the 2009 proposals land to the south of Leamington was used, which is adjacent to existing infrastructure and not designated greenbelt. This land, identified as capable of sustaining more homes than those currently proposed for the Blackdown and Old Milverton greenbelt, is no longer utilised in the Council's 'New Plan'. Why not? The reason presented at a recent meeting I attended with planners and councillors was that it was not possible to re-route high pressure gas mains running through the area, and that we should 'spread the pain'. This is not a planning strategy. I find such justification shallow and completely unfounded.

The greenbelt land north of Leamington is also of huge local amenity value. I have used the land recreationally myself for over 30 years, and at present barely a day goes by when I do not traverse and enjoy the amenity of this land. Furthermore, even in the depths of winter, it is an unusual day if I do not encounter others using the land, watching and photographing the abundant and varied wildlife, walking, cycling, running, horse-riding and dog-walking.

The New Local Plan is ill-conceived, based on flawed housing requirement projections, and ignores the key principles of the National Planning Policy Framework in relation to the redefining of greenbelt boundaries.

The National Planning Policy Framework states that Greenbelt boundaries should only be altered in exceptional circumstances. There are alternative sites available to the Council, which are of a lesser amenity significance and are not designated greenbelt. For these and many further reasons, some of which I have alluded to in this letter, I suggest that there are no exceptional circumstances which outweigh the irreversible harm which would be caused to the whole area, and in particular to ancient and distinct towns and hamlets, by allowing the alteration of greenbelt boundaries in Old Milverton and Blackdown and by allowing development on this land.

I urge that this unwarranted destruction of greenbelt land be rejected outright.

The Council has failed to demonstrate the exceptional circumstances required to warrant the use of greenbelt land for development and the preferred options should be redrawn omitting the use of greenbelt land.

I am writing to raise my serious concerns about the proposed inclusion of current
green belt land to the north of Leamington in your housing development plans, and wish to formally object to these proposals.
My objections to this plan are based on the following;
-A current lack of open green space in the local area, as there no parks or
recreation grounds nearby and hence removal of any of the open countryside
would have a dramatic impact
-Development plans proposed are based on excessive population growth
projections which will likely result in an over-provision of housing
-The Proposed Options paper does not demonstration the 'exceptional
circumstances' required under the NPPF to build on green belt land, especially
considering alternative suitable and available sites have already been
identified by your team to the east of A452 and the south of Heathcote and
does not support the NPPF statement that Greenbelt protection is vital in
preventing urban sprawl.

Whilst I accept that new housing is required in the area, the projections as to the level of housing have been based on a period of exceptional growth, which is highly unlikely to be sustained and results in a 'false' target of housing required.
The land identified to the South of Leamington surely provides a far better solution to this housing demand, because;
- it removes the need to build on any Green Belt land at all;
- it would saves the council a significant amount of money in developing and
building new infrastructure and roads in the north of the town. In North
Leamington existing roads are insufficient to cope with the new level of traffic
this would bring, whereas those to the South have been more recently
developed for more traffic use;
- there is also a high level of local employment in the Heathcote area, which it
would appear sensible to site new housing near to for ease of access.

I was present at the public meeting last night at Milverton Church.

The officers of the County Council and District Council were listened to at great length as they attempted to state their case but they have not convinced me at all to be in favour of this plan.

1. Green Belt is supposed to be inviolate, except in exceptional circumstances. There are NO exceptional circumstances in this case, particularly as there are white belt sites to the south. These were the proposed development sites in the earlier plan. When the officers at the meeting were asked," What has changed?" they were totally unable to give the meeting a satisfactory reply.
2. The area in question contains prime agricultural land, valuable for food growing .Are we not all supposed to be backing home grown production in these difficult times?

3.The area under threat is much used by local residents for recreational activities. Aren't we supposed to look after and cherish these areas on the borders of urban development or have we learnt nothing from the past?

I am not against further house building in the locality, but I have severe reservations about the accuracy of the estimate of the number of houses needed for the future and certainly where those houses and associate developments should be situated.

We live in a democracy, so I sincerely hope that the planners will rethink their proposals in the light of all the public opinion in this neighbourhood ,the vast majority of which is totally against these proposals.

as local residents, living in the Milverton area of Leamington Spa since 1982, we appreciate, and are privileged to enjoy, the amenity of the Green Belt land which the council propose to develop North of Leamington.

We would like to express our extreme objection to the proposed new Local Plan to destroy this Green Belt land. Whilst we understand there may be a need for development, although little reliable evidence for this has been presented, we strongly object to the proposed development for the following reasons:

a) The National Planning Policy Framework requires "Very Special Circumstances" before such development should be considered, However, the fundamental aim of Green Belt policy as set out in the Government's National Planning Policy Framework is to prevent urban sprawl by keeping land permanently open.

b) The Government's National Planning Policy Framework requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development. According to Warwick District Council the "special circumstances" are that there is nowhere else for the homes to be built. However, in the "2009 Core Strategy" (the previous plan adopted by Warwick District Council) land south of Leamington (not in Green Belt), was identified and is still available, for development. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure (roads etc) to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities South of Leamington as well as existing out of town shopping facilities and good access to the town centres.

c) Therefore, the previous plan (the 2009 Core Strategy) is direct evidence that there are alternative areas for development other than the Green Belt and that the "special circumstances" put forward by Warwick District Council are wrong. It is not clear what has changed since 2009.

d) Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt, and indeed calls into question the motives and modelling assumptions used to underpin the argument for new development. The public has a right to be reassured that those in local government with the power to drastically alter the fabric of a community are truly independent, and have no interest, direct or indirect, personal or professional, in who the developers are, or how much profit they might make.

e) The proposals ignore Warwick District Council's study of the Green Belt land at Old Milverton and Blackdown, which concluded that these areas had high Green Belt value

f) The National Planning Policy Framework sets out five purposes for Greenbelt land. In summary these are, to prevent urban sprawl of built up areas, to prevent neighbouring towns merging, to protect the countryside from encroachment, to preserve the setting and special character of historic towns and to assist urban regeneration by encouraging the recycling of urban land. The Greenbelt land identified for development in the Preferred Option does carry out these purposes and its development would therefore be contrary to the NPPF.

g) The proposals will reduce the" Green Lung" between Leamington and Kenilworth to less than 1 1/2 miles encouraging the merger of these two towns and their loss of independent identities.

h) The land at Old Milverton and Blackdown is enjoyed by many walkers, runners, riders, and cyclists, ourselves included. It provides a countryside environment close to the centres of Leamington and Warwick.
Both the proposed building development and the "Northern Relief Road"
would substantially reduce the amount of land that is available to be enjoyed and have a detrimental impact on the ambience and hence the amenity value of the land. Turning some of it into a maintained park land would detract from, rather than enhance its value.

i) Old Milverton is one of the last surviving villages close to Leamington that has not been absorbed into the greater conurbation. It contributes greatly to the character of the area. If the proposals go ahead it is only a matter of time before it is also absorbed by Leamington.

j) Turning the A452 between Leamington and Kenilworth into dual carriage way will not help traffic flows. No matter what the planners say, and no matter what 'modelling technique' or assumptions they use, A452 traffic will be a nightmare at peak times

k) Building nearly 3000 houses north of Leamington will simply increase the congestion.

l) The dual carriageway will have a detrimental effect on the picturesque northern gateway to Leamington and southern gateway to Kenilworth.

m) A "Northern Relief Road" (budgeted cost £28m) is not required.
Traffic flows tend to be north to south rather than east to west. The road will serve no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns.
If the development does not go ahead the road will not be required.

n) A "Northern Relief Road" will form a natural barrier and encourage further development in the green belt up to this new road. It will need to be built across the flood plain (at considerable cost) and will violate an important nature corridor along the River Avon.

o) If the proposed development is concentrated in the South of Leamington there is an existing road network that could be upgraded at considerably lower cost than the £28m allocated to construct a "Northern Relief Road".

p) The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area an attractive place to live, deliver diversity and make it possible to shop without owning a car. Further "out of town" shopping will take trade away from the Towns.

q) There will be a loss of a significant amount of high quality agricultural land in Blackdown and Old Milverton at a time when the nation's future food policy is questionable

r) Warwick District Council has added nearly 1400 homes to the number that it anticipates will be required so as to include a "buffer" in the forecasts. If this "buffer" is removed from the forecast there is no need to include the land at Old Milverton and Blackdown in the proposals.

s) Warwick District Council has presented a preferred plan rather than consulting on options, making a mockery of the 'consultation process'.
No options have been presented for consultation, and it would appear that some of those involved have already made up their minds, at a time when they are supposed to be listening to residents' concerns. Are developers' concerns about profits more important?

Please will you ensure that our objections are noted and considered during this period of consultation, and addressed specifically during your deliberations on the future shape of this historic area. We are trusting you to make the right decision for the area, the residents, the community and the local environment. A bad decision will be impossible to put right and all of our children and grandchildren will pay the price.

I have studied the facts and was present at the public meeting last night at Milverton Church.

Firstly I would like to say that the officers and of the Council were listened to at length and given every opportunity to state their case but they have not convinced me at all to be in favour of this plan.

I am not against further house building in the locality at all, but I have severe reservations about the estimate of houses needed for the future and certainly where those houses and associate developments should be situated.

In brief:
1. It became clear from an elderly speaker from the audience, that the projections of so many houses being required is not based on any proper use of statistics and something better has to be done than just extrapolate current and recent population ingress into the area as a straight line upwards. In fact I understand that trends in the recent past have indicated that there will not be such a need for more houses in the area.
2. Green Belt is supposed to be inviolate, except in exceptional circumstance. These are not exceptional circumstances and there are white belt sites to the south of Leamington that are available. These I understand were earmarked for development in the earlier plan (2009/2010 was it?). At the meeting the supporters of the plan said that there was no infrastructure there or that it could not be put there. I find that hard to believe and from the floor of the meeting we were told that the developer concerned has stated that the infrastructure can easily be put in. I think that the infrastructure for the developments you propose to the north of Leamington would be much more difficult and expensive.
3. The areas proposed for development contain prime farmland that would be lost for ever. Furthermore, we all know the importance of this for the continuance of food supplies for future generations. One of the proposers seemed to look down on objectors, telling them that "Green Belt" is not the same a "Farming Land". A lot of us knew that anyway but such statements show a lack of respect for the knowledge and intelligence of the objectors
1. The area concerned is much used by local people, and other Warwick and Leamington residents, for recreational activities and this would be lost for ever. Assertions by proposers at the meetings that there would be some sort of arrangement with green corridors is not the same at all.
2. Flooding :The proposed new road (£29 million was it at current estimates ?) and all the rest of it will upset the current balance of water dispersal in the are with consequent damage to properties. I thought we had learnt, but obviously not.
3. The development will upset the current balance in size between Warwick, Leamington and Kenilworth and will tend towards forming a large conurbation, with Coventry.
4. The assertion was made that if this scheme is not approved then a "Government Inspector" will not allow a smaller one. I find that hard to believe given the aforementioned points, especially point 1 above: How do we know as many houses as are envisaged would be required. The idea that if no agreement were reached then developers could "pick off" individual site does not ring true. They would still have Green Belt rules to deal with , and of course, the local people affected.
In fact if this scheme were to go ahead it would give no incentive to developers and others to make use of what other, more suitable land, we have got available for any development required.

The Council needs "exceptional circumstances" to build on Green Belt land. These exceptional circumstances do not exist.
I have grave doubts about the validity of the model used to project future housing needs. This is especially so given the parlous economic state that we are in and will be in for some years.
While some more housing must be planned for, it is a grave mistake to go this far. Once it happened there would be no going back.
What is envisaged clearly goes right against the requirements of the National Planning Policy Framework and I object most strongly

I wish to respond to the Local Plan Preferred Options Summary. The paragraphs listed refer to the booklet, although I have read the full version.
PO1 Level of Growth
It is my understanding that during the last 12 years Warwick has undergone a large increase in population, indeed 12% since 2000, which is approximately twice the rate of increase for Warwickshire and twice the national average, and indeed three times the increase for the West Midlands. I would therefore strongly question the need for this level of growth and object to it.
PO3 Broad Location of Growth and PO 14 Transport
I object to the urban fringe development of sites 2 and 3. As no doubt you are aware Warwick has geographical limitations because of the river and the historical centre. Traffic from the Myton Road area is funnelled onto the Banbury Road Bridge and through the constricted town centre. The Preferred Options would necessitate that perhaps an extra thousand cars per day would need to cross Warwick in order to reach the A46. I foresee massive irresolvable problems with traffic by increasing the number of cars on roads which cannot be improved or widened. I have included photos from the past few weeks of occasions where traffic was excessive on the road (dated), and parking at Leamington train station was at capacity when I had arrived.
As a commuter, and resident in Warwick for the past 14 years, I have been shocked at the huge increase in traffic volume over that time period. The vast majority of new residents in the proposed new dwellings would also commute, since there are not 3000 new jobs in Warwick to sustain that influx, so will add intolerable and irresolvable strain on the saturated road networks in Leamington and Warwick at peak times. Therefore new dwellings need to be situated not in the central Myton area, but included in villages and developments such as Hatton Park where the transport networks will easily expand and support increased volume of cars and train commuters, without funnelling those increased traffic through the heart of Warwick town.
If new employment is being created in Coventry and Gaydon, the sustainable planning option would be to build dwellings there. Alternatively, 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. Hatton Park has a station and easy access to the A46 and Barford has immediate access to the M40 and A46. Greenbelt should be acquired to support this growth as opposed to compromising the transport infrastructure, water and drainage utilities, and the unique historic character of the town.
PO11 Historic Environment PO15 Green Infrastructure
I object specifically to the development of zone 2, the area west of Europa Way. It was designated an area of restraint when building work on the Technology Park took place. The notion that the Myton area will be some sort of 'garden suburb' seems to be nonsense when you look at the number of buildings proposed and the impact on the environment. Rather, Warwick is currently a green suburb and as such our green spaces should be protected.

PO12 Climate Change
Warwick town centre road network is in breach of Nitrogen Dioxide levels. This problem has been in existence long before the Preferred Options have been set out (Warwick District Air Quality Action Plan 2008), and remains in breach of these regulations in May 2012. During the period of expansion and urban development that Warwick has already endured from 2000 to date, air quality has deteriorated further and the area of air quality in breach of regulations expanded to now encompass the entire town centre. Areas that have not endured the sustained development rates of Warwick do not show the same extent or progressive degradation of air quality. I object to the increased public health risk which adding more cars to the centre of Warwick at peak times will certainly contribute to.
I conclude by quoting your statement 'Your Views Matter'. I remember that approximately 3 years ago the Council received a large number of objections to plans which were very similar, and there was an enormous number of objections received about development zone 2. The current preferred options are a rehash of those previously rejected by the majority of south Warwick residents.

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The County Council, under the Localism Act 2012, has a "duty to co-operate". The duty to co-operate requires councils to 'engage constructively, actively and on an on-going basis' on issues relevant to statutory plans. Therefore, we will assist in the plan making process and infrastructure planning on an on-going basis.

We welcome the vision and direction of the local plan to create sustainable communities and a quality environment for all those who live and work in the District.

As well as our statutory duties our view is also set out in the context of the County Council's vision contained in the "Going for Growth" paper approved in April 2012. The purpose of this paper was to identify how the County will embrace the coalition government's twin primary aims of reducing deficit and securing growth in this challenging period of public sector austerity. The "Going for Growth" paper sets out how we will assist in stimulating and influencing the business and economic environment (with the necessary educational, skill development and community ambitions) to deliver 'growth' for Warwickshire.

In respect of indicating support for any particular development Option: our view is that there should be a right balance of sites that support growth. Therefore, it is a matter for the District Council, to satisfy itself and strike the right balance, in respect of deliverability, viability and sustainability and supporting infrastructure required to deliver each option.

The planning issues and policies contained in the "Preferred Options of the Local Plan" will impact at differing levels on the County council's corporate responsibilities, particularly economic, transport, support for the elderly and extra care housing, library services public health, gypsies and travellers and education. The Director of Public Health has already responded directly to you on the consultation and evidence.

The key values contained in the "Going for Growth" paper are stated below in emboldened text and their implications for planning and landuse policy is explained in the embolden text below:

* Our social investment will contribute to a county where the will compare well to other British communities.

We will look for planning policies that support technological Infrastructure and in particular in rural areas. We will support the strategic employment sites of the strategy.

* With a sense of mutual ownership of public services (the Warwickshire Shareholder).

We will support positive planning policies that embed co-location of services with the voluntary sector, private sector providers and other public bodies.

* We will achieve a discernible reduction in inequalities in social, economic, health and well-being regardless of age disability or culture.

This applies to access to goods and services for local residents including adequate provision for gypsies and travellers.

Planning policies on extra housing and affordable is provided with the necessary long term supporting services. We will support proposals and policies for co-location of services.

* A vibrant economy will produce high quality job offers in Warwickshire, raising the skill levels in the overall workforce so that we are as productive and competitive as the best in the Country.
* Warwickshire will be a place which looks actively at the best practice from other places - international as well as national - to develop innovative and entrepreneurial solutions. Our economic well-being will be measured by international comparison not simply against "West Midlands" regional standards. Our urban town centres will punch above their weight when compared with similar sized English town centres and our rural infrastructure will be amongst the best in the Country.

We will support planning policies that support a competitive economy for inward investment.

Warwick and Stratford upon Avon are international destinations and make a significant contribution to the economy of the region and sub region.

Therefore, we will support planning policies that support and sustain the key town centres.

* Our growth plan will attract people to live and work in Warwickshire as a specific choice. There will be a strong brand image, underpinned by a recognition that this as one of the best places in the Country to live and work.

Our strategic policies contained in the Local Transport Plan and Growth strategies support the improvement and the provision of strategic infrastructure such as junction improvements to strategic highway network and provision of new railways stations.

* There will be a strong Health and Well-being ethos about the quality of lifestyle we are encouraging.....where the brand "Warwickshire" will be directly associated with a health-focussed lifestyle supported by the health infrastructure to match.

The National Planning Framework requires Local Plans to include policies for health and well-being. The County Council is also responsible for Public Health and we would seek overarching planning policies in the Local Plan that support health and well-being as part of new developments in the District.

We are committed to delivering the best possible health and wellbeing outcomes for everyone, helping people to live Warwickshire.

Planning for health is important not only from a legislative perspective, but
also in relation to costs. Promoting healthy lifestyles, avoiding health impacts
and tackling health inequalities throughout the planning process could result
in major cost savings to society. There is significant evidence on the effect that spatial planning has on community health and well-being and spatial planning policies can address local health inequalities and social exclusion. Some local authorities have adopted planning policies to promote the health and well-being of residents through development management. The Local Plan can contribute to health and well-being in the following way:-

* The quality and opportunities of the local environment is a contributory factor in shaping health.
* Transport and traffic, access to public transport, lack of open space and where we shop for food are just a few examples of how the built environment influences our physical and mental health.
* Planning can positively affect the health of residents by shaping and influencing the layout and the open spaces in between developments and securing investment for the public realm.
* For example, planning policies can include; design requirements for housing layouts to encourage safe and pleasant walking short distances to amenities and services.
Developer obligations can be used to build infrastructure such as healthcare facilities, parks or cycling routes. There should be an overarching policy that promotes health and welling for communities in the District area. Spatial planning policies can promote and provide opportunities for healthier lifestyles.

It is against the above background that the comments are made to the specific questions. This letter contains an amalgamated response from various services. Whilst we have endeavoured to bring together as many responses as possible to assist you in the development of your Core Strategy, please be aware that there may be other services that may have comments to make at subsequent consultation periods as the process moves forward.

We wish to make detail comments on the Infrastructure Delivery Plan by mid-September. However, our general comments are set out below:

Comments in relation to adult social care and specialists housing needs.

Preferred Option 6 (PO6) Mixed Communities & Wide Choice of Homes

Para 7.5.3.
C. Homes for Older People should also include homes that include the needs of local older people, adults and children with disabilities and other local vulnerable people who need care and support. Therefore, this policy should include provision for; extra care housing and supported living accommodation suitable for adults/children with disabilities.

Para 7.5.8.
The Local Plan should provide clarity on the difference Use class C2 and C3 Usage Class. All too often we are seeing the C2 Usage Class applied to individual dwellings, which seem to become institutional if they are providing independent living solutions to vulnerable adults, e.g. McCarthy Stone development in Southbank Road, Kenilworth.

Extra care housing and use class C2 and C3

There is currently some uncertainty about the precise the definition of the different care market sub sectors, including that of 'Extra Care'. Extra Care may be defined as a scheme where occupiers have their own self-contained apartment or living space(s), and generally do not wish to live entirely by themselves without access to care, but do not require either, constant care. Such occupants would have the option of purchasing, as their needs require or are determined varying degrees of domiciliary care.
In terms of which use class order Extra Care falls within, its widely recognised definition, particularly regarding the varying degrees of care provided to residents, has led to debate over whether it comes under C2 Residential Institution or C3 Dwelling Houses.

The issue here is that care homes and extra care housing - both offer long term care solutions - but the preferred model (and this is the view of older people) is independent living (use class C3) with access to 24/7 care rather than admission to residential care (use classC2). We are seeing the market over providing ie residential care homes delivered ahead of extra care housing. If the number of residential care beds introduced to the market hits the predicted number of overall required care places (extra care housing and residential care), planners are likely to argue that there is little need for extra care if the residential care market has already delivered the required/reported numbers

Housing polices within the Local Plan should, therefore, clearly set the distinction between the class uses and also address how those needs will be met.

Demand for Extra Care housing
Based on the 2001 census Warwick District Council will need to provide 1197 units of extra care housing of which 299 should be "social rented" extra care housing. The latter figure should be form about 10-15% of the affordable housing numbers for the District.

Draft Infrastructure Plan
4.4.1.
The first sentence could be re-written to read as "Adult Social Services are mainly concerned with adults and older people with physical and/or learning disabilities and/or mental health problems"

4.4.4.
The last sentence should read as "Residential care accommodation is..."

4.4.5.
May be better to refer to "older people and adults" rather than "...elderly and non-elderly people..."

4.4.6.
This needs to reflect the current 50/50 service model promoted by the County Council, i.e. a model where 50% of people who would normally go into residential care are diverted into extra care housing.

4.4.13.
The suggestion that "Housing accommodation...for people with learning or physical disabilities will be met as the need arises" needs to be clearer.

At present only a limited number of people with learning disabilities are afforded the opportunity to live independent and meaningful lives with choice and control over where and who they live with. Instead, many have their lives constrained by having to live in residential care where individual outcomes do not generally improve. With approx. 300 people with learning disabilities currently living in residential care in Warwickshire, the overall programme intention is to deliver no less than 200, 1 and 2-bedroomed apartments that are suitable for adults with learning disabilities, including an initial short term target of an average of 25 apartments per annum between 2011 and 2015 in line with the County Council's Transformation agenda.

There are about 227 people with learning disabilities in the Warwick District, some are living in extra care accommodation and the others with their main carer (this could be parents or partner). Some residents are living in "hard to let" properties and can be victims of abuse and hate crime. These specialists accommodation would provide suitable and safe accommodation for these vulnerable residents.

General comments:
The District Council needs to include both anecdotal and specific needs analyses from a range of partners, such as local GPs, CCG, NHS Warwickshire and WCC. All these partners directly support and commission services for vulnerable people with a range of health and social care requirements, and these factors need to be considered when looking at overall housing provision.

Development Management and the consideration of planning applications for Care homes.

It is the joint view of the South Warwickshire Clinical Commissioning Group and the County Council as the Public Health and Adult social care providers that the District Council should consider bringing forward a Supplementary Planning Documents ( SPD) to secure the proper distribution of housing and the implications the potential residents have for supporting care and clinical services.

We are therefore request that a moratorium on C2 applications placed. We also recommend that there should be an introduction of a two-stage process to assess planning application on behalf, i.e. a preliminary panel at Pre-Application stage. This could be made up of WDC, WCC, CCG (inc. local GPs) and NHS to consider any specialised accommodation, particularly as the District continues to attract interest from private developers who are seeking to provide specialised accommodation clearly geared to attracting the private pound and/or an imported population. This has implications for both Health and Social Care as follows:

1. NHS Continuing Health Care budgets are being used to fund services for an imported population rather than local residents. These new (and expensive) care homes or housing developments provide an attractive solution to meeting the needs of the private funder, however, we are still seeing those who cannot afford these prices being moved away from their local communities to where services are available. There will also be a drain on local GP and Nursing resources as these new and sizeable care homes come on stream.
2. Extra Care Housing delivery is complex and continues to struggle when reaching planning and enabling stages as it becomes embroiled in local policies. Therefore there should be planning policy guidance to create the proper balance of C2 and C3 housing for the District.

Subject to the input from the "specialist care and clinical services" panel, a development proposal could then progress to formal application for planning consent.

Heritage and Culture matters

We support the District Councils Local Plan direction in safeguarding and enjoyment of our natural and historic environment together with the district's rich heritage and visitor economy. Our specific comments are:-

Section 4, we would welcome specific reference to the interdependency between the district's tourist offer and the safeguarding of its natural and historic environment, and the provision of heritage and cultural activities and venues.

Section 7, we welcome reference to the need to maintain and develop the heritage and cultural infrastructure to support the needs of new residents and to support new communities in developing a sense of identity and social cohesion.

Section 10 tourism and the quality of the built and natural environment are linked, therefore, the contribution of the high quality of the environment should be specifically stated in any policy to maintain the role of towns as visitor destinations.

Section 17, we feel that the introductory list of cultural venues should include museums and archives. The paragraph on "Seeking contributions" should include heritage and cultural facilities; as communities grow, the cultural infrastructure and activities programme needs the opportunity and financial framework to grow accordingly.

Archaeology
We welcome the acknowledgement given to the importance of the District's historic environment in para. 11.1. However, archaeology and the historic environment in some cases should be joined up.

The document refers to the 'built and natural environment', (e.g. para. 4.11.7, 4.12.14, 10.4, 10.6, 11.2). 'historic areas' or the protection of 'historic assets', these terms appear to be used interchangeably. We recommend that the references to 'built and natural environment' throughout the document be re-worded to reflect that the historic environment is made up of a wide range of different types of heritage assets (including archaeological features, historic landscapes etc), rather than just historic structures.

Para. 11.1 describes the historic environment in terms of statutory protected, designated sites, such as Listed Buildings, Scheduled Monuments etc, and locally important historic assets. There are also a number of archaeological sites across the District that are of national or regional significance but may be undesignated and the local plan should also recognise this
There are also several instances where references to the protection of historic structures (such as the references in PO11 to the submission of nationally important historic assets for listing, and the bringing back of Listed buildings into use), could be expanded to take into account other, non-built, heritage assets. For example, PO11 could be expanded to include the putting forward of nationally important archaeological sites for protection as Scheduled Monuments, not just historic structures for listing.

Further clarification is needed in PO11 by "support the understanding of the significance of Heritage Assets, by: There should be provision for appropriate research for all applications relating to the historic environment".

Further clarification is needed about the reference to the Planning Authority undertaking research for all applications relating to the historic environment, or reference to requiring any planning applications relating to the historic environment to be accompanied by an appropriate assessment of the likely impact that the proposal will have upon the historic environment, as per para. 128, of the National Planning Policy Framework (NPPF). We recommend the re-wording of this section of the document and assistance from the County's specialists can be provided.

Further clarification is needed about the term 'locally designated historic assets' in PO11. It is not clear whether this is referring solely to designated historic assets such as those included on 'Local Lists', or whether this is also referring to historic assets recorded on the Warwickshire Historic Environment Record (HER). We would recommend that reference is made to appropriately considering (and protecting if appropriate) all heritage assets as part of the planning process, whether designated or not, and that reference also be made to heritage assets recorded on the Warwickshire HER. We would also recommend that this policy acknowledge that there may be as yet unidentified heritage assets across the District which may be worthy of conservation, and which may also require protecting during the planning process.

The terms 'heritage assets' and 'historic assets' are used interchangeably throughout the document. We would recommend that the term 'heritage assets' be used in preference to 'historic assets' as this is the term used throughout the NPPF and other policy documents.

We support the reference in PO11 to the use of Article 4 directions to help protect the historic environment.

PO11 proposes protecting the historic through the submission of nationally important historic assets for listing. Not all heritage assets of national importance are listable, some may be better protected by being statutorily protected as Scheduled Monuments or included on the English Heritage 'Register of Historic Parks and Gardens of special historic interest in England'. This policy should reflect this.

We also suggest that indirect impacts of development on heritage assets should also be added to any criteria based policy, for example, the impact that a proposed development may have upon the setting of a heritage asset which may be outside of the planning application site. Whilst there is reference to setting in para. 11.9, this is only referring to the setting of Conservation Areas.

Chapter 11, Para. 11.6 should read 'putting them to viable uses consistent with their conservation'

We also note the intention to draw up Local Lists of heritage assets (PO11); There should be clear methodology for identification of appropriate sites on the basis of our Historic Environment Records data. There should be acknowledgement throughout the Local Plan that open space can support conservation of the historic environment as well as the natural environment.

The list of areas of historic or environmental importance in the District should include reference to "41 Scheduled Monuments". We would also recommend that reference be made to the significant number of undesignated heritage assets within the District which are recorded on the Warwickshire Historic Environment Record.

We welcome that Chapter 15: Green Infrastructure makes reference to the Warwickshire Historic Environment Record (including the Historic Landscape Characterisation and Historic Farmsteads studies) (para. 15.21), however, it is disappointing that no reference is made to these within chapter 11, which specifically deals with the Historic Environment. It should be noted that whilst para. 15.21 states that the District Council has the Historic Environment Record

Proposed development sites
The Strategic Housing Land Availability Assessment (which has informed the choice of preferred development sites included in the proposed Local Plan) should also assessed the impact that the proposed development of these sites could have upon the historic environment.

Whilst the assessment has identified statutorily protected sites on and within the vicinity of the potential development sites, however these have not considered a number of known un-designated heritage assets which the Council may also wish to consider. . These undesignated, heritage assets are of national significance and worthy of conservation. The assessment should also consider the historic landscape character of these areas.

In addition, as noted in our previous responses to the earlier Options paper of July 2008 and the 2009 "Proposed Submission Core Strategy" consultation, there will also be archaeological sites as yet undiscovered which will not be recorded on the HER, and even in areas where no archaeology has been recorded, evaluation may be required to confirm the presence/absence of remains. Consultation on a site by site basis will remain the best means of identifying archaeologically sensitive areas on the basis of current knowledge, as well as areas where archaeological potential will need to be assessed through more detailed work.

Since the individual allocations will need to take account of the impact upon historic environment we recommend that further work be undertaken to identify the issues in respect of the historic environment.

The selection criteria for the major development sites should also include for a thorough consideration of Historic Environment, and proper appraisal is undertaken and allowance made where necessary for preservation of sites of national Importance (in the sense of the 1979 Ancient Monuments and Archaeological Areas Act and the National Planning Policy Framework). We perhaps need a separate meetings to work on a systematic assessment of potential sites being put forward.

Tourism policy - general comments
We support the tourism policy of the Local Plan. Tourism is a significant sector of the overall economy within Warwick District and is recognised as a strategic priority within WDC's emerging Economic Development and Regeneration Strategy, it is recommended that Local Plan polices. Therefore, the District Council should also consider to referencing tourism as part of policy no P0 8 Economy and vica versa.

PO 8 Economy
We support the preparation of the Economic Development and Regeneration Strategy to provide a clear direction for growing and sustaining the economic position of the District Council area.

PO 17 Culture & Tourism
Rural broadband policies and policies for Culture and tourism should be cross referenced to promote the quality of the offer in the District.

It is therefore recommended that an introductory statement along the lines of Weston-Super-Mare might be more suitable:

"The Council will work with partners to support the development and retention of new and existing tourism facilities, for both business and leisure markets and promote their sustainable expansion across the District, whilst maximising their co-locational and cumulative benefits to:

* assist in regenerating our town centres by supporting growth of their retail, evening and night time economies by offering facilities and functions that could encourage spending within the wider areas;
* assist with development of green infrastructure corridors linking destinations and attractions for the benefit of both residents and visitors;
* improve the range, quality and distinctiveness of the District's tourism destination;
* provide high quality hotels and serviced and non-serviced accommodation formats and conferencing facilities;
promote the image and reputation of the District to attract visitors and secure investment."
Town centre tourist accommodation
We support the "town centre first" sequential approach for the further hotel accommodation. To support this and as an alternative, it is recommended that the Council consider the following policy wording:

Within the existing urban settlements of Warwick, Kenilworth and Leamington Spa, proposals that would result in the change of use hotels and tourist accommodation will be permitted unless:
* the proposed use or uses would reduce the overall capacity and attractiveness of Warwick, Kenilworth and Leamington Spa as tourism hubs and result in the loss of an otherwise viable hotel or tourist facility which would consequently harm the provision of tourist accommodation;
* the proposed use or uses would be incompatible with the surrounding area and businesses and would harm the character of the town centre;
* there would be no clear, additional benefits from the proposal in terms of improving the character of the area, the vitality and viability of the town centre and the economic and, cultural and environmental impact on the town as a whole.
Applicants seeking change of use away from existing hotel or tourist accommodation use will need to submit detailed evidence relating to the viability of the business and details of how the business has been marketed.

Rural accommodation

We support tourism in rural areas and we recommend that the Local Plan should have a specific policy to address expansion and re-development of existing tourism accommodation and tourism facilities within the Green Belt.

Accommodation not in permanent buildings
The District Council may wish to consider an additional policy to cover accommodation not in permanent buildings (i.e. camping, caravan and chalet parks). This type of accommodation can be damaging to the character of landscapes, and in rural areas the added light pollution can be intrusive. It is recommended that small scale developments should be supported in areas of open countryside or next to small settlements provided they are not prominent in the landscape and have high quality landscaping. The policy may choose to exclude locations in sensitive landscapes and areas prone to flooding.

Ecological & Geological
We welcome and support the strategic direction outlined in the Preferred Options document in relation to the Natural Environment and would like to make the following suggestions:

4. Spatial Portrait, Issues and Objectives
4.7 - Sites of Importance for Nature Conservation are now referred to Local Wildlife Sites. It is suggested that Local Geological Sites are also listed. You may wish also to consider using the Habitat Biodiversity Audit and the State of Biodiversity Report to provide a Spatial Portrait of the District's Biodiversity.
4.8 - You may wish to add climate change as a pressure in bullet point 9

7. Housing
7.5 - You may wish to add within the important issues a reference to the natural environment such as "Maintain access to the natural environment in both urban and rural settings to reap social, economic and well-being benefits".
PO4 Distribution of Sites for Housing: (A) Allocated Sites - we are aware of the habitat evidence submitted for the previous work on the local plan, but would suggest that a new model has been produced to measure Habitat Distinctiveness and Connectivity throughout Warwickshire, Coventry and Solihull. This approach is placed at the heart of the National Planning Policy Framework as a way to indicate 'sensitivity' of habitats within potential allocated sites and how the site acts within the ecological corridors. We would recommend that this approach is investigated as partners to the Habitat Biodiversity Audit with the knowledge that the habitat data is current and sound.

PO4 Distribution of Sites for Housing: (C) Development of Brownfield Sites - we welcome the comment relating the development having 'no serious impact on the amenity and environment of their surroundings'. However, brownfield sites can be e very important ecological sites in their own right so suggest that this aspect is noted in the future policy.

8. Economy
There is no reference to the relationship between a healthy environment and the economy. It is suggested that this link is made in the introduction to add weight and substance to subsequent paragraphs within the policy such as 8.15. For example a statement could be, "There are proven links between the natural environment and economics (National Ecosystem Assessment, 2010) through an Ecosystem Services approach. It is essential that these links are maintained and enhanced through both the placement and setting of commercial activities coupled with the retention of agricultural and silvicultural practices." Further pictorial reference to explain Ecosystems Service can be found in the National Ecosystem Assessment documentation.

9. Built Environment
We support the 'Sustainable Garden towns, suburbs and village' design guide as well as the Relevant Issues and Strategic Objectives.

10. Climate Change
It is recommended that more be added in relation to Climate Change Adaptation within the introduction to support the last bullet within the box titled PO12 Climate Change.
12.25 - 12.26 These paragraphs outline the impacts and issues relating to Climate Change Adaptation, however, it is felt that this topic could be expanded upon within future documents, e.g. an addition Supplementary Planning Document or equivalent. This additional document could promote green roofs, green walls and other ways to promote urban cooling etc. WCC Ecological Services is able to signpost you to a couple of other Local Authority documentation on this topic.

11. Transport
It is recommended that reference be made to the Natural Environment White Paper (2011) and the importance of transport networks and ecological connectivity assets.

12. Green Infrastructure
In our opinion we suggest that this chapter is well balanced and support its approach. It is suggested that additional references to Ecosystem Services, the Warwickshire Biological Record Centre and the importance of using up-to-date ecological and geological / geomorphological data is used is the assessment of development proposals. These should be added to the future policy and the Ecological Services are able to assist you with this advice, subject to resources.
By the time the future policy is formed the Sub-regional Green Infrastructure Strategy will have been produced for consultation and can be more fully referenced as a mechanism to deliver your objectives outlined in this chapter.

18. Flooding and Water
In relation to ecology it is recommended that there is future referenced to the safeguarding or promotion of natural flood alleviation areas at strategic sites within the district as short, medium and long term aspirations to assist with flood risk measure. We are aware that this may form part of the Catchment Flood Risk Management Plan (18.9) or fall within the Sustainable Urban Drainage Approving Body's remit, but would suggest that these strategic potentials should be particularly noted within the future policy. These sites could then be potential delivered through the biodiversity offsetting metrics (15.16).

It is also recommended that a further discussion be held regarding the assessment of allocated sites using latest modelling of habitat data.

Comments regarding minerals safeguarding
Para. 143 of the National Planning Policy Framework (NPPF) requires that in preparing Local Plans, local planning authorities should define Minerals Safeguarding Areas and adopt appropriate policies in order that known locations of specific mineral resources of local and national importance are not needlessly sterilised by non-mineral development, whilst not creating a presumption that resources defined will be worked; and define Minerals Consultation Areas based on these Minerals Safeguard Areas.

The British Geological Survey's 'Guide to Minerals Safeguarding in England' (October 2007) provides the following advice:

"A district DPD could include policies that set out the general approach the district will take when determining proposals for non minerals development within or close to MSAs or existing mineral workings. Such policies should acknowledge the procedures for consulting the MPA on the existence and extent of mineral resources present and considering the case for prior extraction of mineral where appropriate."

In June 2009, the British Geological Survey (BGS) completed a piece of work to delineate Warwickshire County Council's Mineral Safeguarding Areas (MSAs)/Minerals Consultation Areas (MCAs). The BGS identified the extent of individual mineral resources in Warwickshire and these, in turn, were used to develop safeguard areas for each mineral. WCC would suggest that these MSAs/MCAs are either identified on WDC proposals maps and/or a link is provided in the Local Plan to Warwickshire's Minerals Safeguarding webpages. This will help to ensure that minerals implications are taken into account as part of decision making for District planning applications.

We would request that where certain applications may potentially sterilise minerals deposits within an MSA, the District Council consults the County Council. If the County Council concludes that minerals reserves may be sterilised, the applicant may be required to submit a Minerals Survey to establish whether the reserve is economically viable. In some cases, the County Council may insist that prior extraction of the minerals is undertaken prior to the non-mineral development being carried out. It is considered that the inclusion of this procedural information will improve the effectiveness and deliverability of the policy.

In assessing the Preferred Options, it is noted that there appear to be sand and gravel deposits under the 'Whitnash East', 'West of Europa Way' and 'South of Gallows Hill' sites - see attached map (appendix A). It would be beneficial if a minerals survey was undertaken by the developer to determine the quality and depth of the resource and to establish the feasibility of prior extraction.

Waste
Policies for the development of major residential development sites should include waste management issues as part of the overall design of larger residential/retail developments. For example, provision for waste recycling/composting on site will ensure that waste is managed in accordance with the principles of proximity, self-sufficiency and the Waste Hierarchy. Furthermore, there is a need to provide adequate waste facilities for flats and apartments - see WRAP's 'Good Practice Guidance - recycling for flats' WRAP, available at http://www.wrap.org.uk/content/recycling-collections-flats.

It should also be noted that policy CS8 of the Warwickshire Waste Core Strategy (due for Submission in September 2012) seeks to safeguard existing waste management sites. At this stage, it is considered that none of the preferred option sites are likely to prevent or unreasonably restrict any waste sites. However, if necessary the Council may object to other proposals which may sterilise important waste facilities (e.g. those delivering significant waste management capacity to meet the County's landfill diversion targets). To prevent this, WCC intends to supply each District/Borough Council with its latest waste site information, possibly in GIS format, so that the County Council can be consulted on any proposals within reasonable proximity (e.g. 250m) of existing waste management facilities.

Customer Services/One Front Door/services that support communities and families.

The County Council is open to co-location, co-access, and co-servicing of support services including support for the elderly, vulnerable adults, and families , however, these services should be located or are accessible to communities they serve. Further for new development these key services should evolve with the phasing for large developments. One solution could be providing lay-bys with " electric hook up points" for mobile services (including a mobile shops) this would build up sufficient demand before most of the dwellings are built. Consequently, make communities and developments sustainable.

Transport and Planning matters
The key transport strategies are contained in Warwickshire Local Transport Plan 2011-2016. The County Council is already working with the District Council to assess the transport impacts of various development scenarios as part of our Strategic Transport Assessment work and will be responding directly on this and other relevant transport matters. The key matters are access and sustainability of the pattern of development for homes and jobs.

We support the direction and economic strategy of the Local Plan and we need to undertake further work on some key matters ie transport, archaeology and ecology matters.

Thank you for consulting with the Home Builders Federation (HBF) on Warwick's local plan preferred option.

The HBF is the principle representative body of the housebuilding industry in England and Wales and our representations reflect the views of our membership of multinational PLCs, through regional developers to small, local builders. Our members account for over 80% of all new housing built in England and Wales in any one year including a large proportion of the new affordable housing stock.

We would like to submit the following representations on the draft Local Plan.

Plan period

It would be helpful if the local plan clearly stated the period of time over which it is intended to operate. This should be stated on the front cover and in the first paragraph of the introduction, as well as elsewhere in the document, including the section that addresses the housing need over the plan period. We assume that the plan period proposed is 2011 to 2029 although this is not altogether clear.

Section 5: Preferred Level of Growth

It is encouraging to see the Council taking the correct approach to establishing a housing requirement that is in conformity with the NPPF (hereafter referred to as the Framework). It is the function of the SHMA to assess the full housing needs of the district over the proposed plan period.

We note the three scenarios for setting a future housing requirement. Inevitably, given the uncertainties regarding the economy, relying on any one employment-based scenario as the basis for setting a housing requirement could prove too inflexible in the event that the district (or adjoining districts) experience higher levels of employment growth than projected by a particular scenario. We note that option 1 allows for 600 homes a year, while option 2 allows for 700 homes a year. Option 3 has been discounted because the projected increase in jobs would not be matched by the increase in homes (paragraph 5.19).

We do have some qualms about assuming that there is a direct relationship between new jobs in the district and the demand for new homes. The relationship may not be as strong as the Council thinks, and to some extent, the demand for housing in the district will come from people who work elsewhere, typically in the larger employment centres of Solihull, Coventry, Birmingham etc.

We note that the Council's preferred level of housing growth is for 10,800 homes over the plan (PO1: preferred level of growth). This is inadequate since it is lower than the most recent household projections and the evidence from the most recent SHMA (2012). It also fails to take into account the decisions of adjacent local authorities.

SHMA (2012)

The SHMA indicates that the annual need for affordable housing will be 698 homes per year (paragraph 7.50). This exceeds the proposed option, and, significantly, only addresses the affordable housing need, not the demand for market housing. The report does not appear to have assessed what the market need will be in the district in addition to this affordable need. As such, the SHMA does not satisfy the requirements of the Framework, paragraph 159.

It is unclear how the three modelled housing scenarios relate to the requirement of the Framework for the SHMA to identify the scale of housing needed over the range of tenures, including housing demand (paragraphs 47 and 159). It is unclear whether the figure of 698 affordable homes per year relates to the three scenarios since it exceeds two of them and is almost comparable to the third. The SHMA needs to set out what the quantity of need is for market housing and affordable housing over the plan period.

The Council has not explained in its Preferred Option why it is choosing to discount the evidence of need identified by the SHMA. It would appear that the Council is relying upon the argument that because the SHLAA can only identify land for 11,410 homes (paragraph 5.18). This, however, would be to pursue an capacity-based approach to determining the future housing requirement of the district, rather than using the new plan as an opportunity to review the efficacy of existing policies and constraints and consider the possibility of removing these in order to meet the level of housing need identified in the SHMA. A capacity-based approach would be contrary to the Framework, as the expectation is that the Council will do all it can to meet objectively assessed needs (see paragraphs 14, 17, 47, 179 and 182).

Household projections

The 2008 based household projections indicate an increase of 13,000 households over the period from 64,000 in 2013 to 77,000 in 2028 - a period that is approximately comparable to the proposed plan period of 2011 to 2029. This is a figure that approximates to option 2 - the projected employment rate scenario of 12,888 homes. The Council suggests that this employment projection is likely to be optimistic (paragraph 5.22) owing to the most recent ONS GDP forecasts. Nevertheless, the Council may be surprised, and economic growth, and consequently housing demand, may be stronger than it expects. If this is the case the plan will need to have the capacity to respond to rising demand. This would be in accordance with the Framework which expects local plans to meet objectively assessed needs and have sufficient flexibility to adapt to rapid change.

Furthermore, while we would not dispute the Council's current pessimistic economic prognosis, it is important to remember that housing demand is not solely related to employment. Warwick will continue to experience many more affluent households moving into the district who may work elsewhere and non-economically actives households will continue to consume housing in the more desirable locations. The Council will need to cater for these tastes, but also increase the overall level of supply in order that those on low to medium incomes are not priced out of the district by affluent incomers. Citing the recession as a reason to scale-back plans to accommodate more housing would also be contrary to the Government's new, more positive, planning agenda, as set out in the Ministerial Statement Planning for Growth which sees planning has playing a pivotal role in facilitating greater levels of growth.

Duty to cooperate

There is also the matter of the duty to cooperate to consider and how Warwick's plan will provide for its own unmet needs that cannot be addressed through the plan (paragraph 179 of the Framework) as well as potentially the unmet needs of adjoining councils (paragraph 182). If the council is unable to meet its objectively assessed housing need through its plan (once it has properly identified this, and once it has reviewed existing policy constraints) it will need to plan to ensure that these needs can be met elsewhere without the district. To do so, it will need to plan in concert with adjoining councils.

The draft plan appears to be silent on this question. We note that at least two of Warwick's neighbours - Solihull and Stratford Upon Avon - are advancing plans that will not meet their own 'objectively' assessed housing needs (although there is an issue with the soundness of their own SHMA assessments when judged against the NPPF). Solihull is proposing only 525 homes per year when its SHMA indicates a need for 904 affordable homes. Stratford is proposing a plan requirement of 7,500 homes yet its own housing requirements study recommends between 11 and 12,000 homes over the plan period. Clearly if Solihull and Stratford are not proposing to meet their own requirements then it is very unlikely that they will be willing to accommodate any of Warwick's unmet needs. This suggests that Warwick will need to fully accommodate it own housing requirement since it cannot rely on anyone else to pick up the tab.

The location of new housing

It is unclear why the Council feels it needs to phase the delivery of sites (paragraph 7.20). Surely, if all the sites have been assessed as being suitable for housing, and thus sustainable in terms of the Framework, it should be immaterial when these sites come forward for delivery.

PO5: Affordable housing

I am concerned that the Council is disregarding the evidence of its own viability study in setting an affordable housing target of 40% when the study would appear to indicate that a figure of 35% may be more appropriate. The Council maintains that it can ignore the evidence since it will be flexible in how it applies its policy to ensure viability. This would be contrary to the approach of the Framework which now requires that the cost of affordable housing policy and other policy requirements of the plan are deliverable and to ensure that these do not render developments unviable and thus the plan undeliverable.

This will require the Council to ensure that all its policies applied to be applied to sites, especially those earmarked to contribute in the first five years from the date of adoption of the plan are subject to a reasonable level of policy demands and planning obligations. The onus should not be placed on the developer to demonstrate viability but for the Council to ensure that the cumulative impact of all its policies and demands will ensure that the majority of sites, and especially all those earmarked for the first five years, are viable (see the footnote to paragraph 47 of the NPPF and pages 26 and 27 of the Viability Testing of Local Plans report).

We are also concerned that the study has not modelled-in properly the true costs of development, including those costs to be added to development by the proposed local plan. We note that the study has only factored-in the cost of building to Code 3 and Code 4, but building to the Part L Building Regulations (equivalent to Code 5) will be a requirement from 2016 onwards. This will represent a significant additional cost. The Council should refer to the most recent DCLG report: Cost of Building to the Code for Sustainable Homes: An update cost review, August 2011. This is a significant future but known cost that will impinge upon the viability of sites over the plan period but also in first five years, and must be factored into a new viability assessment (see page 26 of the Viability Testing of Local Plans report).

The viability assessment has also not taken into account the cost of building Lifetimes Homes which is a requirement of policy PO6. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of the requirement of policy PO12 for developments to provide on-site renewable energy plant to provide a 20% reduction in carbon emissions. A revised viability assessment will need to take account of the costs of doing so.

The viability assessment has not accounted for the cost of biodiversity offsetting which is a requirement of policy PO15. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of flood mitigation measures as stipulated by policy PO18. A revised viability assessment will need to take account of this.

The report uses BCIS costs, but this is based on Gross Internal Area and does not account for external and landscaping costs and local site works (see page 34 of the Viability Testing of Local Plans). A revised viability assessment will need to take account of this.

The figure for site acquisition costs is rather low at 5.75%. This is more likely to be between 6.5 to 7.5%. We would refer the Council to page 35 of the Viability Testing of Local Plans report.

The viability assessment also assumes a total planning gain package (S106 and/or CIL) of £6,650 per unit. This seems modest. I have commented previously on this in my letter to the council dated 20 September 2010 in which I recommended an average of £15k per dwelling is applied as a more realistic figure. Ideally the Council should prepare a CIL Charging Schedule alongside the Local Plan to ensure an integrated viability assessment and avoids the risk of the CIL setting an unrealistically high charge that has not been reflected in the viability assessment for the local plan. Under the current arrangement, if the plan was adopted, then the Council would need to ensure the levy of any CIL introduced after the plan, in combination with S106, exceeded no more than £6,650 per dwelling otherwise the plan would immediately be rendered undeliverable.

We are also unconvinced by the interpretation of the evidence. We do not feel that the council's conclusions are legitimate ones to reach since the evidence does not support the assertion that either 35% or 40% affordable housing is viable. However, this is really a matter of secondary importance compared to the need for the Council to undertake a Framework compliant viability assessment that takes into account the costs of development, local policies and plan requirements.

Thank you for consulting with the Home Builders Federation (HBF) on Warwick's local plan preferred option.

The HBF is the principle representative body of the housebuilding industry in England and Wales and our representations reflect the views of our membership of multinational PLCs, through regional developers to small, local builders. Our members account for over 80% of all new housing built in England and Wales in any one year including a large proportion of the new affordable housing stock.

We would like to submit the following representations on the draft Local Plan.

Plan period

It would be helpful if the local plan clearly stated the period of time over which it is intended to operate. This should be stated on the front cover and in the first paragraph of the introduction, as well as elsewhere in the document, including the section that addresses the housing need over the plan period. We assume that the plan period proposed is 2011 to 2029 although this is not altogether clear.

Section 5: Preferred Level of Growth

It is encouraging to see the Council taking the correct approach to establishing a housing requirement that is in conformity with the NPPF (hereafter referred to as the Framework). It is the function of the SHMA to assess the full housing needs of the district over the proposed plan period.

We note the three scenarios for setting a future housing requirement. Inevitably, given the uncertainties regarding the economy, relying on any one employment-based scenario as the basis for setting a housing requirement could prove too inflexible in the event that the district (or adjoining districts) experience higher levels of employment growth than projected by a particular scenario. We note that option 1 allows for 600 homes a year, while option 2 allows for 700 homes a year. Option 3 has been discounted because the projected increase in jobs would not be matched by the increase in homes (paragraph 5.19).

We do have some qualms about assuming that there is a direct relationship between new jobs in the district and the demand for new homes. The relationship may not be as strong as the Council thinks, and to some extent, the demand for housing in the district will come from people who work elsewhere, typically in the larger employment centres of Solihull, Coventry, Birmingham etc.

We note that the Council's preferred level of housing growth is for 10,800 homes over the plan (PO1: preferred level of growth). This is inadequate since it is lower than the most recent household projections and the evidence from the most recent SHMA (2012). It also fails to take into account the decisions of adjacent local authorities.

SHMA (2012)

The SHMA indicates that the annual need for affordable housing will be 698 homes per year (paragraph 7.50). This exceeds the proposed option, and, significantly, only addresses the affordable housing need, not the demand for market housing. The report does not appear to have assessed what the market need will be in the district in addition to this affordable need. As such, the SHMA does not satisfy the requirements of the Framework, paragraph 159.

It is unclear how the three modelled housing scenarios relate to the requirement of the Framework for the SHMA to identify the scale of housing needed over the range of tenures, including housing demand (paragraphs 47 and 159). It is unclear whether the figure of 698 affordable homes per year relates to the three scenarios since it exceeds two of them and is almost comparable to the third. The SHMA needs to set out what the quantity of need is for market housing and affordable housing over the plan period.

The Council has not explained in its Preferred Option why it is choosing to discount the evidence of need identified by the SHMA. It would appear that the Council is relying upon the argument that because the SHLAA can only identify land for 11,410 homes (paragraph 5.18). This, however, would be to pursue an capacity-based approach to determining the future housing requirement of the district, rather than using the new plan as an opportunity to review the efficacy of existing policies and constraints and consider the possibility of removing these in order to meet the level of housing need identified in the SHMA. A capacity-based approach would be contrary to the Framework, as the expectation is that the Council will do all it can to meet objectively assessed needs (see paragraphs 14, 17, 47, 179 and 182).

Household projections

The 2008 based household projections indicate an increase of 13,000 households over the period from 64,000 in 2013 to 77,000 in 2028 - a period that is approximately comparable to the proposed plan period of 2011 to 2029. This is a figure that approximates to option 2 - the projected employment rate scenario of 12,888 homes. The Council suggests that this employment projection is likely to be optimistic (paragraph 5.22) owing to the most recent ONS GDP forecasts. Nevertheless, the Council may be surprised, and economic growth, and consequently housing demand, may be stronger than it expects. If this is the case the plan will need to have the capacity to respond to rising demand. This would be in accordance with the Framework which expects local plans to meet objectively assessed needs and have sufficient flexibility to adapt to rapid change.

Furthermore, while we would not dispute the Council's current pessimistic economic prognosis, it is important to remember that housing demand is not solely related to employment. Warwick will continue to experience many more affluent households moving into the district who may work elsewhere and non-economically actives households will continue to consume housing in the more desirable locations. The Council will need to cater for these tastes, but also increase the overall level of supply in order that those on low to medium incomes are not priced out of the district by affluent incomers. Citing the recession as a reason to scale-back plans to accommodate more housing would also be contrary to the Government's new, more positive, planning agenda, as set out in the Ministerial Statement Planning for Growth which sees planning has playing a pivotal role in facilitating greater levels of growth.

Duty to cooperate

There is also the matter of the duty to cooperate to consider and how Warwick's plan will provide for its own unmet needs that cannot be addressed through the plan (paragraph 179 of the Framework) as well as potentially the unmet needs of adjoining councils (paragraph 182). If the council is unable to meet its objectively assessed housing need through its plan (once it has properly identified this, and once it has reviewed existing policy constraints) it will need to plan to ensure that these needs can be met elsewhere without the district. To do so, it will need to plan in concert with adjoining councils.

The draft plan appears to be silent on this question. We note that at least two of Warwick's neighbours - Solihull and Stratford Upon Avon - are advancing plans that will not meet their own 'objectively' assessed housing needs (although there is an issue with the soundness of their own SHMA assessments when judged against the NPPF). Solihull is proposing only 525 homes per year when its SHMA indicates a need for 904 affordable homes. Stratford is proposing a plan requirement of 7,500 homes yet its own housing requirements study recommends between 11 and 12,000 homes over the plan period. Clearly if Solihull and Stratford are not proposing to meet their own requirements then it is very unlikely that they will be willing to accommodate any of Warwick's unmet needs. This suggests that Warwick will need to fully accommodate it own housing requirement since it cannot rely on anyone else to pick up the tab.

The location of new housing

It is unclear why the Council feels it needs to phase the delivery of sites (paragraph 7.20). Surely, if all the sites have been assessed as being suitable for housing, and thus sustainable in terms of the Framework, it should be immaterial when these sites come forward for delivery.

PO5: Affordable housing

I am concerned that the Council is disregarding the evidence of its own viability study in setting an affordable housing target of 40% when the study would appear to indicate that a figure of 35% may be more appropriate. The Council maintains that it can ignore the evidence since it will be flexible in how it applies its policy to ensure viability. This would be contrary to the approach of the Framework which now requires that the cost of affordable housing policy and other policy requirements of the plan are deliverable and to ensure that these do not render developments unviable and thus the plan undeliverable.

This will require the Council to ensure that all its policies applied to be applied to sites, especially those earmarked to contribute in the first five years from the date of adoption of the plan are subject to a reasonable level of policy demands and planning obligations. The onus should not be placed on the developer to demonstrate viability but for the Council to ensure that the cumulative impact of all its policies and demands will ensure that the majority of sites, and especially all those earmarked for the first five years, are viable (see the footnote to paragraph 47 of the NPPF and pages 26 and 27 of the Viability Testing of Local Plans report).

We are also concerned that the study has not modelled-in properly the true costs of development, including those costs to be added to development by the proposed local plan. We note that the study has only factored-in the cost of building to Code 3 and Code 4, but building to the Part L Building Regulations (equivalent to Code 5) will be a requirement from 2016 onwards. This will represent a significant additional cost. The Council should refer to the most recent DCLG report: Cost of Building to the Code for Sustainable Homes: An update cost review, August 2011. This is a significant future but known cost that will impinge upon the viability of sites over the plan period but also in first five years, and must be factored into a new viability assessment (see page 26 of the Viability Testing of Local Plans report).

The viability assessment has also not taken into account the cost of building Lifetimes Homes which is a requirement of policy PO6. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of the requirement of policy PO12 for developments to provide on-site renewable energy plant to provide a 20% reduction in carbon emissions. A revised viability assessment will need to take account of the costs of doing so.

The viability assessment has not accounted for the cost of biodiversity offsetting which is a requirement of policy PO15. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of flood mitigation measures as stipulated by policy PO18. A revised viability assessment will need to take account of this.

The report uses BCIS costs, but this is based on Gross Internal Area and does not account for external and landscaping costs and local site works (see page 34 of the Viability Testing of Local Plans). A revised viability assessment will need to take account of this.

The figure for site acquisition costs is rather low at 5.75%. This is more likely to be between 6.5 to 7.5%. We would refer the Council to page 35 of the Viability Testing of Local Plans report.

The viability assessment also assumes a total planning gain package (S106 and/or CIL) of £6,650 per unit. This seems modest. I have commented previously on this in my letter to the council dated 20 September 2010 in which I recommended an average of £15k per dwelling is applied as a more realistic figure. Ideally the Council should prepare a CIL Charging Schedule alongside the Local Plan to ensure an integrated viability assessment and avoids the risk of the CIL setting an unrealistically high charge that has not been reflected in the viability assessment for the local plan. Under the current arrangement, if the plan was adopted, then the Council would need to ensure the levy of any CIL introduced after the plan, in combination with S106, exceeded no more than £6,650 per dwelling otherwise the plan would immediately be rendered undeliverable.

We are also unconvinced by the interpretation of the evidence. We do not feel that the council's conclusions are legitimate ones to reach since the evidence does not support the assertion that either 35% or 40% affordable housing is viable. However, this is really a matter of secondary importance compared to the need for the Council to undertake a Framework compliant viability assessment that takes into account the costs of development, local policies and plan requirements.

The Parish Council support the Local Plan in principal; we have made reference as detailed below to the areas we feel directly impact our Parish.

The Parish Council would request the housing demand produced by the original survey be revisited to take account of the latest data available, such as the 2011 census results, the later figures from the births and deaths register and inward migration figures.

Also the Parish Council would like WDC to reconsider whether they have given sufficient weight to the unprecedented development in the area over the last few years, which, would make extrapolation of recent figures unreliable.

Comments on Preferred Options

P05 Affordable Housing
The Parish Council are unaware of any demonstrable need for local affordable housing, we do not have an infrastructure to support this type of development, such as public transport and community facilities, however, we are in the process of compiling a Parish Plan. With survey results from the local community imminent, we would wish to revisit our comments should results show otherwise

P07 Gypsies and Travellers.
The District Council has to identify a site for travellers within the district, which it has not yet done.
We currently have one unauthorised traveller site within our Parish, which is subject to an enforcement notice, the unauthorised site does not meet the specification laid down in the new Planning Policy Framework, nor does it meet any of the criteria set out in the Preferred Options. We need to emphasize this point so the Kites Nest site, does not become the default option for WDC in the absence of another site being identified. The Parish Council take the view that the whole area, including Coventry and Rugby, which currently have underused Traveller capacity, is taken into account in identifying potential Traveller sites.

P08 Economy
The Preferred Options has identified the old Honiley Airfield as an employment site; we would insist any new development be restricted to the existing planning consent - potential for currently 2,000 jobs.
We request WDC in analysing the need for employment development consider the recent changes at Haseley Manor, which as an employment site could not attract business to the area and is now in the process of being redeveloped as housing.

P01 Greenbelt
The whole of our Parish lies with in the Greenbelt and we would wish it to remain so, if appropriate we would also wish our Parish to be designated as a "green wedge", providing a significant buffer between the conurbations of Kenilworth, Warwick, Coventry and Solihull.
We have a myriad of extremely well used Footpaths, Bridleways and Cycle routes; we wish these to be preserved as an important area for leisure and recreational activities.

We do not wish housing development forced upon us with the removal and restructuring of the Greenbelt boundaries, but we would support some sensitive infill development within our existing settlements.

P018
As a Rural Parish, we do not have any provision of storm drains to alleviate excess surface water and local road floods. We would wish WDC to revisit their strategy on the maintenance of ditches and gulleys and to also ensure landowner responsibility is enforced.

Document scanned.

Document scanned.

The Town Council of Royal Leamington Spa broadly welcomes the Plan, and below gives a more detailed response on particular items of the Plan. We expect to incorporate our vision for Leamington Spa into a Plan for the Town in due course.

Delivering Growth (PO1 & PO3)

We welcome the broad location of growth. We agree that an annual average increase of 600 new homes for the next 20 years is a reasonable and fair target. Many of the Wards in the Town are already densely populated, and we note that the Plan anticipates some growth in these areas.

Affordable housing (PO5)

We approve the requirement that 40% of new homes on developments of 10 or more dwellings, and 5 or more dwellings in the rural areas, should be affordable housing.

Mixed communities (PO6)

We approve the option for a mix of housing, and note that strategic sites will include Extra Care Housing. We believe in a balanced and mixed population and welcome families and single people in all our Wards.

Whilst the Town Council is proud of the diverse population in Leamington, we would request the District Council introduce a policy to restrict the number and density of Student Houses and Houses in Multiple Occupation to ensure that they do not adversely impact on the character of neighbourhoods to the detriment of family households. The Town Council requests close involvement in the input into the policy on mixed communities.

We would also welcome developments that demonstrate a more imaginative provision for students, that are not simply converting existing family housing.

Economy (PO8)

We welcome the proposals to ensure a wide range of employment. We particularly support the regeneration and enhancement of existing employment areas.

The Town Council believes that the Local Plan needs to encourage the continuing growth of the already successful Computer Games industry and the further development of Silicon Spa as the primary UK centre of excellence for the industry. The Local Plan also needs to support further growth in the innovative automotive industry much of which is based in the District or on the edge of the District as this is likely to provide future employment in the Leamington and Warwick conurbation.

Retailing and Town Centres (PO9)

We welcome the support for Town Centre retailing and a Town Centre first message. We believe that the `Town' includes the whole town, and that developments should be considered in the area south of Regent Street, in the Parade and in Old Town.
The Town Council believes that we should promote and support Fair Trade initiatives.

We are committed to strategies that promote the town for retail provision, leisure, entertainment and eating establishments. We can promote our parks and green spaces as important attributes of the Town Centre.

However, we see that `shopping' also includes local shops. The Town Council would prefer there to be a policy on where supermarkets should be located, and that local communities should be consulted about any new proposals for supermarket development.

Historic Environment (PO11)

We welcome the intention to protect the historic environment. We see that this includes the historic areas of the Old Town, and would be pleased to work with the District Council in listing the historic assets, and reviewing the Conservation Area. We are pleased to note the District Council's encouragement of regeneration of appropriate sites within the historic environment. We strongly affirm that the historical integrity of the area is threatened by sex entertainment establishments and oppose any such establishment, which we see as an inappropriate development.
The Town Council supports the Blue Plaque scheme, and the Guild of Guides Walks.

Climate Change (PO12)

As a Transition Town, the Town Council welcomes the intention to include a policy on climate change.

Transport (PO14)

We support the option to minimise the need to travel, and to promote sustainable forms of transport. In addition to the proposals in the Plan, we believe that a higher priority should be given to cycle provision, and to ensuring that all new developments encourage ease of access by bicycles between areas of the District. This includes cycle lanes and provision to park cycles.

Residents should also be encouraged to travel by bus for work and leisure with the encouragement of more quality bus routes into and across Leamington.

Encourage the co-ordination of different forms of transport to encourage more residents to travel by foot, bus, train and bicycle.

Green Infrastructure (PO15)

We welcome the intention to protect and enhance the assets as identified in the Plan. We are pleased to see the introduction of "Green Wedges" as an alternative to areas of restraint.
We would also be in favour of consideration of a policy that considers garden preservation. We support greener neighbourhoods through our tree planting scheme, and through our support of Allotment Societies.

Culture and Tourism (PO17)

We support the intention to develop this appropriately and would welcome opportunities to share ideas on promoting the cultural facilities of Leamington. We believe there is scope for improving the visual impact for visitors to Leamington who arrive by rail or canal.

We are proud of the assets of the Town and are committed to maintaining them as welcoming and friendly venues for residents and visitors.


ADDITION

Evening Economy

The Town Council is concerned that the District Council's Policy on the Evening Economy has not yet been completed and so is not available for consultation. The evening economy is important to Leamington, but unless it is carefully considered it can produce public dangers, so it is important to the Town that there is a well-considered policy in place that takes account of the needs of residents, visitors, the businesses and public safety.

I wish to register my views regarding the WDC Local Plan - helping shape the district - Preferred Options in relation to Kenilworth.
PO1 - I feel Kenilworth is unsuitable for an increase in housing without a considerable amount of extra funds being found. Both medical centres are stretched and schools full.
PO3 - The preferred site for new housing and commercial development would be I believe on unsuitable green belt land. Acient woodland, trees with preservation orders, the noise from the nearby A46 and local road congestion.
PO4 - I fail to see the point of including commercial premises within the Thickthorn plan when the town was unable to get any interest in the empty site on the junction of Common Lane and Dalehouse Lane and it was made into housing.
PO7 - Kenilworth suffers from gypsies and travellers meetings and horse fairs at lease three times a year. The event is held on part of the proposed Thickthorn site. Chaos reins. The nearest pub to the gathering quite often has to close. I understand there is petty crime. The most police you will see in a year in the town appear. Normally there is a lack of police presence and there is no longer a police station in the town. I feel it would be hard to attract anything/one to come to Kenilworth if such a realatively small town had to accommodate such a site.
PO8 - See PO4.
PO10 - Let us hope that the proposed Thickthorn site does not consist of a large number of three story dwelling which would be totally out of keeping with the rest of the houses in the vicinity.
PO11 - Has the Grade II listed house and nearby ancient woodland and roman site been taken into account with the Thickthorn site? Other proposed sites seem to have been given more credence than they deserve. (Can you really see Kenilworth Castle from the proposed Rouncil Lane site?).
PO14 - I would suggest that building houses and commercial buildings on the Thickthorn site will greatly increase congestion in Kenilworth and on to Leamington. I would be interested in what plans could possibly improve situation which developes even before the traffic lights on the Warwick Road at Sainsburys. You can alter the island at the Jet filling station, widen the top of Birches Lane and alter the A46 island but whether you put a road out of the new development into Birches Lane or out on to the A452 Leamington Road it still doesn't alter the fact that there will be 770 new homes a good percentage of which will have cars who will be joining these roads.
PO16 - I feel strongly that it is wrong for WDC to alter greenbelt boundaries.

As a resident of Warwick I wish to object to the expansion plan to build new homes in and around Warwick.

The infrastructure in the area cannot handle any increase in population.
All road leading into the town at peak times suffer long delays.
The river bridge by the Castle is the only river crossing, building more houses will create further traffic problems and increased pollution.

Since the 1960's Warwick populaton has increased dramatically with large estates being built on: The Woodleos, Myton Grange, Chase Meadow, Warwick Gates, Hampton Magna & Hatton Park plus many smaller developments. These developments have already caused problems with the traffic, pollution and flooding.

There is no justification in increasing the population in this area.

Warwick should remain a small and pleasent County town.

Please do not approve this over development.

See attached

Scanned Representations

Scanned Letter and Response Form

As a resident of the district I am against any significant new housing development that will put an increased strain on the infrastructure, especially the roads. In the feedback on the plan options that the Council has gathered it is clear that the majority of residents do not support the level of housing that is planned. In theory at least, the Council exists to represent the best interests of the residents, so I fail to understand why the Council is ignoring them.

The proposed figure of 600 new houses per year appears like a rabbit out of a hat - I've failed to find where this figure comes from or how it's justified. In the Preferred Level for Growth, section 5.6, figures of 250, 500 and 800 are offered, and 90% of respondents were against more than 500, so where did 600 come from and why is it being considered when it is contrary to residents wishes?

Arguments revolving around population increase and increased housing are somewhat circular - the two are linked and neither drives the other. What drives the need for new housing is the desire for growth - the plan refers to the "Government's policies of encouraging local authorities to embrace growth and that housing growth would support economic growth". It is assumed that growth is good, and desirable.
But perhaps the community doesn't want this. I for one value less traffic, less noise, less pollution, less housing built on agricultural land, less water run-off causing potential flooding, less light pollution. This is already a prosperous part of the country, we need only minimal growth to support our existing population (PROJ 4 of the Warwick District Council Strategic Housing Market Assessment).

In relation to the proposed Gallows Hill developments of 2700 homes, while this is an obvious location for new housing (whilst of course, not agreeing that it's needed), the route into Leamington is at a standstill twice a day already, as is the Myton Road which I live near. I cannot imagine how much worse it will be as a result of this development.

I studied the Strategic Traffic Assessment - Modelling Results document. I noted that the input to the analysis (figures applied to all housing sites) was based on the housing distribution of the Cape Road development in Warwick. I'm concerned that the mix of housing types for this development does not reflect what would be found in out-of-town developments, specifically those at Gallows Hill. A quick calculation based on the figures given on page 7 of the report gives an average per-household trip rate of 0.39 (for both AMPeakHour &
PMPeakHour) - based on the housing distribution of the Cape Road development. However, for the proposed housing distribution for Gallows Hill, (based on information received from WDC Planning Dept) - then the average per-household AMPeakHour trip rate rises to 0.69, and the PMPeakHour rate to 0.79. These figures are an increase of 62% and 100% respectively over the figures used for the modelling exercise. When you take into account that this discrepancy applies to the largest development in the area, which connects to roads that are already at a standstill at peak times, it questions the validity of the whole modelling exercise and I would say renders it meaningless. I have sent these observations to the WDC Planning Dept.

Secondly, one thing I've not found in the whole traffic strategy is any sort of limit to the traffic on a road. The traffic modelling exercise seeks to minimise traffic queuing but places no limit on it.
I see queue lengths of 50 to almost 100 in the modelling results, but what does this mean? 1/2 mile queue? 30 minutes wait? There must be a point where the amount of traffic becomes unacceptable in terms of delay, quality of life, pollution etc, such that it would be irresponsible to put plans in place knowing that this limit would be exceeded. What is this limit? In the absence of such a limit, it would seem that new developments can generate new traffic in a completely unconstrained way, potentially to the point of gridlock. Such unconstrained growth would appear to contradict the National Transport Policy's goal "To improve quality of life for transport users and non-transport users, and to promote a healthy natural environment."

Scanned letter and Response Form

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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.