PO1: Preferred Level of Growth

See attached

GREEN BELT - National Planning Policy Framework requires "very special circumstances"
The Green Belt covers only 13% of the area of England. This preferred plan is for 10,800 dwellings and 43% of land used will be green belt. How can this be justified when there is still plenty of white field land available south of Leamington? Presumably the "very special circumstances" come into effect when the 57% development on white fields has been used. This growth is scheduled to take 15 years at a constant annual rate of 555 houses per year. 57% of 15 is 8.55. So it will be eight and a half years before these "very special circumstances" (ie. white field sites are filled and green belt is needed) comes into effect. By then another plan will have been made!
I disagree strongly with any relaxation of the green belt which is there to stop conurbations merging. This plan will leave less than 1 1/2 miles between Kenilworth and Leamington.
Why does Kenilworth need to expand? It has always been in the past a much smaller town than Leamington and Warwick and mushroomed massively in the 1960s, and also in the 1980s when Knights Meadow estate was built. Why should we let this happen again to keep pace with the other towns? Councillors tell me that the Green Belt is strangling Kenilworth. This is precisely its purpose. We should be grateful that our town has these safeguards in place to protect it.
770 dwellings equates to about 1770 people which is almost a 10% increase in Kenilworth's population in an area which is quite detached from Kenilworth and is not likely to make its inhabitants feel a part of the community. The town centre should be in the middle of the town. Far too much development is on the east side and it should now be the turn of the west, if the Green Belt has to be sacrificed, where there is no risk of it merging with other towns and which would be a short walk to the centre of town without cars needing to be used.
THICKTHORN.
How was the Thickthorn site chosen?
Surely not because it abuts the A46 which is noisy both day and night. Was a site visit made to see just how noisy it will be for all the inhabitants? Were decibel readings taken at various points up the hill to ascertain the suitability of this site? The noise is particularly bad on a hot sunny day with the prevailing south-west wind. What about HS2? The boom will be heard at Thickthorn as it passes 18 times per hour in both directions on the EAST side? This estate will be on the flight path of Coventry International Airport where there is no restriction on night flights and jets scream over the proposed development land and at a very low level on their way to Baginton as they have to avoid the Birmingham flight path, (which is also noisy) as this is the crossover point of the two flight paths.
It would be a very selfish decision to commit people to a life of misery with all this noise even through double glazing. This is not the same scenario as the Woodloes where houses abut the road, which at that point is 4 lanes instead of 6, where there the A46 is the other side of the natural sound barrier of Primrose Hill. At Thickthorn noise is impossible to stop owing to the contours of the land which is a basin causing the noise to be trapped and sweep up the hill towards dwellings. The noise is incessant both day and night. It is an ideal location for the sports fields which are already there, where people can go away at the end and not have to endure it 24 hours a day. Office buildings along it will not dissipate the sound.
TRAFFIC
Having 1200 cars discharging from the estate each morning will be a nightmare and cause even longer queues up Birches Lane and into Glasshouse Lane. It will be a worse effect than the horse fair there every day of the year. Updating St Johns gyratory presumably means traffic lights which will cause long tailbacks into the town centre as they have priority under the give-way scheme.
I cannot understand how a dual carriageway between Kenilworth and Leamington will help as all the traffic will have to funnel in at either end and will just result in 4 lanes of slow moving traffic instead of 2. Creation of bus lanes will in any case limit traffic flow to one lane in each direction to speed up a bus every 10 minutes if you're lucky, and nothing will be gained in terms of traffic build up.
There are no points wide enough along Glasshouse Lane for the junction of a spine road, as the corner with Rocky Lane is on a dangerous bend. In any case, Glasshouse Lane is a unique and attractive feature of 1930s period landscaping, a Kenilworth gem, which should be preserved and which junctions along its length will destroy.
NUMBERS
Where do these figures come from for 10,800 houses?
It is in the interest of the District Council to have as many new houses as possible, as they receive 6 times the Council Tax from the New Homes Bonus Scheme for every new dwelling completed and more than that if they are affordable housing.
This plan is not led by suitability but the interest of landowners to sell off their land for housing.
These are not sufficient grounds for this massive increase in population concentrated in a small area as the plans make little use of rural area development. Lots of villages need regenerating. Radford Semele has had no growth since the 1960s and has a school in place already. It has good transport links to the M40, Fosse Way and Leamington Station and IT IS IN A WHITE FIELD ZONE. If such a large number are needed, they should be put in the South Leamington area on white field sites as Leamington already has all the amenities (parks, department stores, nightclubs, cinemas) jobs to support it. This is a Warwick District Council plan not a Kenilworth plan and there are plenty of other places where housing could be built.

CONCLUSION
Population figures should be challenged.
Green belt should be protected.
Consideration of the effect on the HEALTH of people living alongside a motorway with NOISE and POOR AIR QUALITY owing to constant fumes and directly under a flight path with NOISE due to very low flying aircraft should be made.
DISTRICT COUNCIL
Having looked extensively at your website, I note that according to feedback from the public there is low satisfaction with the way you communicate with people.
I note that you are consulting the people of Kenilworth on Friday 20th July in Kenilworth Library. As the consultation is of 2 months duration, why do you choose to liaise with the people of this town just 7 days before the cut off date for written responses?
Every household in the town should have been notified by post (why not with the Electoral Role info) and notices should have been placed in relevant places about the town as happens for a single house alteration. Instead, the local press is left to do the job for you. You are reaching a small minority. Ask the KWN for circulation figures.
In order to improve this during the further consultation in March / April, I hope you that you will consult everyone by means of a written communication to every household.

See attachments for full text of representations.

Providing sustainable levels of growth :
The levels of growth envisioned are not sustainable- in that the level of infrastructure, its
distribution, housing location and jobs, do not match the population growth forecast.
A 40% increase in Warwick's population over 15 years is clearly unsustainable and will cause
immense damage to the the character of the County Town
Level of Population Growth and demand for housing assumptions:
These are flawed because:
Given that more than 50% of national population growth has been from immigration over the
last two decades, and the government has publicly stated it wishes to greatly reduce this
future net immigration, why is Warwick District planning for an even greater level of growth
over the next 15 years, than has been experienced in the recent past?
* Housing demand growth in England is from a combination of net immigration and
changes in household demographics towards smaller households.
* However the impact of a prolonged recession which the Prime Minister says could last
another decade, will impact on the ability of individuals to afford housing.
* This is manifest in the rapidly rising age of first time buyers and the profound
demographic change since 2008 in more young adults living at home with their parents
for much longer than in the past.
* So why is the plan still assuming a rapid increase in demand for single occupancy
households; when the actual demographic trend is away from this?
* Is the modelling based on current data, or is it simply looking at the demand during the
decade of rapid growth and easy availability of mortgage loans pre the 2008 crash?
* This in turn could mean that in fact far less individual units are required for the District
as a whole, but a greater emphasis should be given for multi generational living , with
semi independent adults?
Distribution of housing within the District
The plan talks about the need to distribute housing across the entire District , but then in fact does
not do this!
A starting point should be that EVERY ward has the same level of housing growth during the plan,
i.e. A 20% across the board increase.
* It appears that most housing will be again concentrated within Warwick and parts of
Leamington Spa, with very little in the large villages or in Kenilworth
* This is curious, as it also points out the lack of affordable rural housing but then basically
ignores any provision for it!
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* The inexplicable lack of housing growth in and around Kenilworth is most odd given that the
job growth is likely to be around the University and Coventry Airport, and the town already
has a lot of facilities.
* 830 houses over 15 years in the villages is clearly inadequate to meet their housing needs
or the lack of affordable housing, this is only 55 houses per year spread across a wide
geographical area.
* I suggest as a minimum 2500 of the 10800 houses in the plan be developed in the
village areas spread evenly across the district.
* This provision WOULD meet the need for affordable rural housing projected, at 55
per year if 33% was "affordable".
I suggest two areas which have been overlooked for large scale housing provision are Radford
Semile and Lapworth.
* Both are ripe for large scale "garden suburbs", supported by business parks. This would
support and make more viable their existing shops and schools.
* I suggest that at least an additional 1000 to 1500 houses are considered for each ward, and
therefore the significant benefits of population growth extolled by this plan are met, coupled
with local affordable housing and retail provision
* I note they both have existing primary schools, and good proximity to public transport and
roads, and Lapworth has a commuter railway station.
* There is also the opportunity in Lapworth to build a business park to tap into the proximity
to Solihull and at Radford Semile to build a business park dedicated to engineering to tap
into the expertise and supply chain associated with Ricardos.
* This in turn would mean much smaller developments around Milverton and Warwick would
therefore by required.
Transport
For the plan to be actually sustainable, there needs to be a lot more vision for integrated public
transport.
Cycle ways:
It would be a good objective to work with the County Council to ensure that EVERY community is
served by a dedicated cycle way, especially within the urban areas, where short lengths of cycle
way often just stop.
This should be funded by developers of the new housing as a priority via the Community
Infrastructure Levy
Commuter Rail and Bus Routes:
The plan envisions much new low cost housing, yet this is concentrated mainly around Warwick,
and the new job provision is in the north of the District.
HOW are those in low paid jobs who will presumably be the beneficiaries of the "low cost" housing,
be able to commute to where the jobs are if they cannot afford their own cars?
For the plan to be sustainable surely it would be better to have more smaller housing
developments within walking/ cycle distance of the new job provision; i.e. small estates near small
business parks?
* IF this is not possible a commitment to provide and subsidise long distance inter nodal
commuter bus routes is essential.
* Low paid workers will need to be able to commute quickly and cheaply to where the jobs
actually are!?
* This can be achieved, by developing inter town express bus routes to link together;
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Warwick, Leamington, Stratford, Coventry, The University, Nuneaton, Rugby, Kenilworth
and the larger villages; integrated with mini bus services which will THEN serve the local
housing areas. Funded by the Community Infrastructure Levy.
* NOT the farcical situation as now when it take between 90 and 120 minutes each way to
get between towns , which IF a direct town centre to town centre route could be achieved in
20 -30 minutes, (existing buses take very circular routes).
* This lack of effective public commuter transport compounds inequality and creates greater
dependency on state subsidies, as those able and willing to work cannot afford the
transport to get to the jobs, and the bus services are simply too slow and too infrequent to
be a viable alternative.
* Similarly regular local new commuter train services linking together ALL the major
Warwickshire Towns and Coventry should be a priority, funded by the Community
Infrastructure Levy,.
* The "virtual" park and ride scheme, seems like a lot of hot air political spin. Does it
effectively mean NO park and ride , but a slightly extended bus route?
Air Pollution
Parts of WDC already do not meet the Nox emissions EU Directive, including large parts of the
centre of Warwick.
This is likely to be tightened up in the near future with harder targets and lower permissible
emissions, possibly wit fines for non compliance.
It therefore seems curious that the large-scale housing developments on the edge of Warwick are
suggested with a likely 40% increase in the town's population, over 15 years.
This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?
Historic Distinctiveness
* I believe the plan should do more to promote good design in housing.
* It is should also seek to unambiguously protect the historic buildings in the area and their
settings, as this is one of the major "draw" factors for population growth and economic
vitality
* The plan has some very vague and bland statements, it needs a clearly articulated
"heritage vision", backed up with detailed planning guidance and then an appetite for
rigorous enforcement.
* Our towns are special, BUT only if the key historic and architectural elements and values
are protected, otherwise they risk becoming a sprawling new town reminiscent of Milton
Keynes.
* The existing open spaces, sports fields, allotments and parklands should unambigiously be
protected from development, including their settings.
Definitions of affordable Housing
I suggest that the definition of what is affordable housing needs broadening.
The plan highlights the need for housing for the elderly and the growth of the elderly as a % of the
population.
One solution to their needs and the obvious trends in semi independent adults living much longer
with their parents because they cannot afford to get on the housing ladder, would be to classify
"granny flats" or semi separated apartments within houses as going towards the "affordable
housing" targets.
Multigenerational living should be encouraged as it meets housing need, is sustainable and reflects
changing land-use patterns. There is the opportunity to boost this by incorporating it into the plan's
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housing targets and helps meet the need for "mixed" housing.
Gypsy Site:
I suggest the land adjacent to the Junc 15 of the M40 might be a suitable site.
There is little nearby existing housing, but a public bus service and good road access
Employment Land
I support the use of green belt land to expand employment opportunities on well designed business
parks at Stoneleigh and around the University. BUT there must be good public transport links to
allow potential workers to access these jobs from the existing WDC Urban areas.
HS2
HS2 could open up significant advantages for the West Midlands by improving links to London &
Heathrow, but more importantly Northern English cities and direct rail links with northern Europe.
I support HS2 and would suggest that rather than opposing a strategic transport plan which cannot
be blocked by WDC due to existing legislation, the Council concentrates in obtaining maximum
benefit for the District, by getting subsidies for improving the transport links to meet the HS2
stations.
Conservation Areas and Historic Environment
* WDC must commit to protecting the existing listed buildings, open public spaces and
conservation areas, from encroachment by development.
* Particularly as most development needs - as defined by this plan-will be met by building on
greenfield and brown field sites, there is therefore less pressure to damage the existing
historic town buildings?
* I suggest the English Heritage Guidance published in May 2011 in "Seeing History in the
View" should be incorporated into the plan.
Climate Change
Flooding and SUDS. Given the recent patterns of heavy rainfall and the long history of local
flooding, great care should be given to the sitting of all new developments.
Claims of 1000 year flood modelling should be treated with extreme scepticism as reliable data
only exists for the past 90 years.
Especially in existing urban areas a conservative approach should be given to any large new
buildings and their impact on surface water drainage.
Consideration should be given to more local flood defences and helping individuals to flood proof
their homes.
Fear of Crime
* No sex clubs or night clubs should be allowed near housing- they should only be built in
non residential areas.
* No new pubs, bars or hotels should be built or change of use in areas of predominately
residential nature, to protect existing residential amenity.
* There should be the presumption that in residential areas new businesses will not increase
the background ambient noise levels. If this cannot be achieved these businesses should
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be located in designated areas such as retail or business parks.
Good Design:
The plan highlights good design and sustainability, this should be supported but defined
All new housing should be built to Parker Morris standards
http://www.singleaspect.org.uk/pm/index.php
* These standards are based on ergonomics of the minimum space needed to meet "a
functional approach to determining space standards in the home by considering
what furniture was needed in rooms, the space needed to use the furniture and move
around it, and the space needed for normal, household activities."
As these were the minimum set for UK 1961 social housing it is not unreasonable that they should
be the very minimum acceptable in WDC for the next 15 years. OR we run the risk of creating
housing that CANNOT meet the needs of the occupants and risks becoming dysfunctional or
slums, which by definition is hardly "sustainable".
Public Space:
Existing open space, sports and recreational buildings and land, including playing fields, should
not be built on !
Any new developments should have additional public space.
Tourism
* Any new visitor accommodation -over a small number of bedrooms- should be examined to
see if it would have a negative impact on the existing providers locally as a material
planning consideration.
* Small independent providers of accommodation tend to support far more local jobs and
have a bigger local economic impact by their use of local suppliers.
* It is desirable to have a diversity in type and location of accommodation providers.
* New budget chain hotels which have a similar impact on existing hotels and guest houses,
to that of supermarkets on independent retail traders. They should only be permitted where
it can be demonstrated there is an unmet demand or capacity need. And there will not be a
detrimental impact on existing buisnesses.
Green Wedges
This seems to be a meaningless concept.

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

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

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

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

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

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

See attached

Full submission attached

-PO1 Levels of Growth
The WDC Housing needs assessment and inward migration figures appear incorrect, the arguments are flawed and the assumptions false. The Council must use due diligence to study the paper submitted by Ray Bullen from Bishops Tachbrook which re examines the migration and population data. It also provides updated figures using the newly published Census information which proves that the WDC conclusions are incorrect.
Mr Bullens report provides a much more realistic conclusion of only 5,336 houses needed over the plan period.

PO3 Broad Location of Growth
I am concerned about the over concentration of development in villages along the B4439 corridor to the west of Warwick. This proposal places far too much strain on this rural area and its infrastructure. Any attempt to 'improve' the infrastructure will adversely affect the rural character of this area. Why is development not being spread to also include villages to the East and North of the District ?

PO16 green Belt
I profoundly disagree with proposals to remove Green Belt status from certain villages.
The principles of creation of Green Belt land are still valid today and provide a valuable protection from inappropriate development.
There are many contradictions between the WDC plan proposals and the National Planning Policy Framework which says that Green belt must be protected unless exceptional circumstances exist. PO16 item B directly conflicts with PO16 item C. (page 17).

If any small scale development is allowed in village locations, the type of housing must not be dictated by developers. The local community must be able to determine what is required for local need.

Any development must be planned in a priority order using Brown Field sites first, secondly developing areas close to existing infrastructure, and only allowing any developments in rural and Green Belt areas as a last resort.

As scanned.

At a recent Parish Council meeting, The Chairman and Councillors of Leek Wootton & Guy's Cliffe Parish Council discussed the Local Plan. Their views are below -

The Parish Council are particularly concerned with the following proposals in the draft Local Plan:

1) [PO16] We are opposed to any Village Envelope and Green belt boundary changes within Leek Wootton.
It is felt strongly that this creates a significant erosion of the boundary and development protections in our area, and it is contrary to the recently adopted Parish Plan.

2) [PO1] We believe that the basis upon which projections of future population and housing needs are not realistic or supported by proven evidence, and that the housing development plans for Warwick District should be much smaller than those proposed.

3) [PO4] The proposal for 30-80 new dwellings in Leek Wootton is contrary to our Parish Plan (fully backed by residents survey responses) which states that any large scale development is precluded and individual new property proposals possible only within the current building envelope.

4) [PO14/PO15] The proposed 'Leamington Northern Relief road' will unavoidably cause excessive environmental damage, having to cross a railway line, river and a flood plain.

5) [PO1/PO14] The large developments proposed in the surrounding area particularly Kenilworth will inevitably increase significantly the traffic through Leek Wootton unless these developments are kept to a more manageable size.

See attached.

I wrote to the Development Officer earlier, 14 July 2012. In the meantime I have consulted with others and as a result of this have additional concerns which I wish to draw to your attention. Please see letter in pdf format as an attachment which refers.

At the Parish Council Meeting held in Old Milverton Church on Monday 16 July it became apparent that the Preferred Options Plans, nominally open for consultation and discussion were nothing of the sort. The strong impression given in the presentation was that in the minds of the presenters, the 'only option' open is the one presented, even though the key argument for what constituted the justification for the Green Belt Land Grab was not made. Insult has been added to injury in freely admitting that the 2009 consultation, presumably based on sound 'Planning Criteria' is replaced by the 2012 consultation which clearly is not. The principle of 'Equalising the Misery' is scarcely a sound basis for planning.

This meeting has prompted me to make further comment, particularly when at the end of the meeting the Chairman Jonathan Lander encouraged those attending to make written submissions to WDC and copy their MPs if they felt there was merit in this course of action.

This was made the more poignant when Michael Doody immediately stood up and stated it was in no one's interest to copy the MPs, as there was a risk of repercussions and Local Government loosing control of planning decisions. He elaborated on this theme but found no support for his assertions.

Bill Hunt (Deputy CEO Warwick District Council) gave the WDC presentation at the Church meeting and also present were :

Councillors J.M.Lander (in the Chair), Mrs.A.Kelsey, J.McDonagh, L.J.Sant-Cassia and M.A.L.Tansey; County and District Councillor M.Doody; District Councillors J.S.Hammon and N.Pratt; and Mr. Bill Hunt, Deputy Chief Executive of Warwick District Council; together with some 150 members of the public, including Councillors Margaret Cashmore, David Cox and Peter Delow of Cubbington Parish Council.

There is also the matter of the WDC website, where 'contributors' are encouraged to force their submissions into 'boxes'. This looses the personal touch and is in danger of a total loss of context; the practise is certainly inhibitive. There is no satisfactory substitute for free form written letters ! To give an example of the anger and frustration this sort of thing can cause I refer you to the decision to ask for questions to be submitted in writing at Trinity School 'consultation' meeting, failing to address those questions at the meeting and providing only a summary of responses to 'subject areas raised' did not endear WDC to those taking the trouble to attend the meeting and try put a stop to this apparently politically motivated charade.

The handling of the change of plans to the newly 'Preferred Options' is certainly not in the public interest; and all those I have spoken to, have been greatly irritated by this lack of courtesy and consideration. A significant lack of trust certainly appears to have been generated.

This poses the question When and How do WDC propose to make available copy of letters of comment, objection and support in order to assure the public that letters/submissions are being properly addressed and the content properly taken into consideration; and enable interested parties to see the nature of submissions just as WDC do routinely for the more private and delicate subject of Planning Applications. I should be grateful for your written reply.

Letter detail

When I came to Old Milverton 35 years ago, L.Spa enjoyed an enviable reputation as a
Shopping Centre and was recognised as having a thriving 'community spirit'. Latterly,
much of this has been lost. Independent retailers appear to have lost confidence in
trading in the town. In places empty shops and offices show a town in decline.
By implementing the plans now proposed, the two plots of sequestered Green Belt land in
the Parishes of Blackdown and Old Milverton are set to become 'housing in isolation',
which will result in a 'Dormitory Development'; some say a 'ghetto'. The outcome can only
be a feeling of isolation and a huge increase in unnecessary commuting across L.Spa,
adding to the existing congestion at well known bottlenecks which so far WDC have found
impossible to resolve.
This is particularly pertinent as there is no detail admitted of the proposed infrastructure
intended to service this development. It might not even materialise - for example, if the
sale of the housing proposed founders; a not unlikely outcome in view of the land value
and expected high market value of the new housing in this area. If on the contrary, a
major and inspired infrastructure component is built in and it is successful, it can only be to
the detriment of L.Spa town Centre as shops, offices, services and places of work are
dispersed away from the Town Centre.
By developing a transport hub based on the Railway Station and the commercial/
recreation and services already in place to the south of the town; and locating new
housing development as laid out in the 2009 plan south of the town, it may still be possible
to retrieve much of what has been lost. To develop at Old Milverton & Blackdown can only
have the reverse effect. Our political representation appears to have completely lost sight
of this important consideration.
Why has it not been possible for Warwick District Council to take a grip and reverse the
deterioration experienced in Leamington Spa and exploit the many assets and advantages
associated with the existing infrastructure, services and trading opportunities south of the
town. Significantly, in the first instance, build Affordable Housing where they are needed,
upgrading the empty/derelict buildings and return the many houses originally built for
families to live in but no longer in family occupation.
In summary, It seems the social and cultural life of L.Spa is about to be finally
ripped out of the town and be dispersed into isolated units on the northern
periphery. WDC should be regenerating L.Spa by concentrating its development
from the town centre to the south and not fragmenting it by developing to the north
of the town. What a prospect for legacy !
At the Parish Council Meeting held in Old Milverton Church on Monday 16 July it became
apparent that the Preferred Options Plans, nominally open for consultation and discussion
were nothing of the sort. The new plans have been presented as the 'only option' even
though the key component of what constituted, 'Very Special Circumstances' for the
justification of the Green Belt Grab, was not made. It was agreed even by the DCEO that
the plans lack this very necessary robust argument.
Robert Solt demonstrated further weaknesses in the case for the Preferred Options Plans
by explaining that the numbers did not add up, on several counts. Mainly that the model
used was outdated and most of all, the input data was flawed being based on earlier
projections which are no longer valid, resulting in a very considerable overestimate of
housing need. No allowance appeared to have been made for the recent changes in the
nature of the local work force from manual to blue and white collar and a very significant
increase in numbers of professionals and academics.
It follows that a contemporary detailed audit is outstanding and is required to quantify
housing need, specifically to include the changes outlined above. An audit of similar rigor
is required to establish the total availability of development options to include all sites
Whitefield, Brownfield and Windfall (for which a particularly rigorous assessment is
needed and with inducements offered up to encourage this process). An explanation for
the 'apparent loss' of development sites since the previous assessment (see 2009 plans)
would not go amiss.
Missing from the report is a statement covering the impact of changes which must be
taken far more seriously such as the austerity measures and other significant events in
process, including the fate of the Euro and our EU member States and our Trading Status
as a nation committed to the practice of a disproportionately large scale Food Importation
Policy. Food Security has simply not been considered. In large conurbations this could
become the single most important consideration for Local Government.
If Climate Change and an increasing demand for western living standards are to be
aggressively pursued by Indians Chinese and Africans etc., we have the makings of 'the
perfect storm' in the ability of these countries to feed their own people, let alone export.
The UK is one of the more densely populated countries, at least in the EU and perhaps the
one at greatest risk from global food shortages. A consideration not to be taken lightly
when seeking to destroy Green Belt and good quality Agricultural Land.

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

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

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

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

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


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

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

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

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

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

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

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



Housing continued...

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


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

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

See scanned response forms

Scanned representation

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

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


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

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


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

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

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


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

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

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

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

PO14 Preferred options: Transport

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

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


PO15 Preferred options: Green Infrastructure

The policies set out in PO15 are supported


PO16 Preferred options: Green Belt

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

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



PO17 Preferred options: Culture & Tourism

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

The low growth option makes that loss unnecessary.

PO18 Preferred options: Flooding & Water

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

Scanned submission

Scanned Representation

See attached Response Forms

See attached documents

Scanned representation

Scanned representation

Scanned representation

Scanned representation

See Attachments

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

Letter attached

Scanned representation

See Attachment

Scanned representation