12. Climate Change

Norton Lindsey is a small village with limited transport facilities. Most house have two vehicles of necessity and any increased housing will make carbon emmissions worse.
There are no bus services to Warwick and only 4 Buses aweek 2 to Stratford and 2 to Solihull hardly suitable for commuting.

Norton Lindsey is a remote village with no public transport other than an infrequent bus service. Any housing development would significantly increase car use in and out of the village with the resultant increase in carbon emissions.

The Leamington Society supports the assertion (para. 12.26)

* The use of green space and vegetation, (such as street trees) to provide summer shading and allowing winter solar gain.
More street trees and vegetation will not only satisfy national and global Climate Change requirements but will also enhance the realm of Warwick District, making it a more pleasant area for everyone who lives or works here, or visits the district.

I do not believe in 'man made' climate change however if I am to be made to pay for measures to control this I expect Local Govt. to take action in limiting emissions. Increasing the number of cars in Norton Lindsey, a village with virtually no public transport, will not do this .

Electronic attachment

Thank you for your email dated 01/06/2012 inviting Warwickshire Wildlife Trusts
comments on the above development plan. The Trust welcomes the opportunity to
participate in the ongoing development of the Warwick District New Local Plan and
would like to submit the following comments and recommendations for your
consideration.
PO4. Site Allocations
Warwickshire Wildlife Trust believes that further information is needed to inform and
justify the preferred housing allocations detailed in the new local plan. We are
concerned that the current evidence base and assessment criteria has not fully taken
account of all ecological constraints and opportunities for each allocation and
therefore cannot identify and isolate those housing options that offer the greatest
benefits for, or least impacts on, the natural environment. We recommend that the
local authority undertakes the following:
Update the evidence base
It is recommended that the Warwick District Habitat Assessment is updated to include
the additional 3 sites that were not initially reviewed under the 2008 assessment.
These sites are the land at Blackdown, Warwick Gates Employment Land and a site
that forms part of the Thickthorn allocation. The habitat assessment should aim to
ensure that up-to-date information on habitats, local sites and protected species
considerations are available for these additional three sites at this stage of the
planning process so that the relative constraints and opportunities of all preferred site
allocations are available to inform decision making. The National Planning Policy
Framework (NPPF) requires planning policies and decision to be based on up-to-date
evidence about the natural environment of the area so that the sustainability appraisal
can 'consider all the likely significant effects on the natural environment'. Therefore,
without comprehensive data for all preferred site allocations, it will be difficult for the
local authority to justify the conclusions of the sustainability appraisal process and
thus the preferred options during examination in public.
The Trust is aware that additional habitat assessment is underway for the land at
Blackdown and the site at Thickthorn; however we also recommend this is extended
to the Warwick Gates Employment land. Whilst we acknowledge that this site has
been previously allocated as an employment site in a previous local plan, we believe
that the site is still a preferred option and therefore needs to be supported by, and
assessed against up-to-date ecological evidence to justify its inclusion in the local
plan.
Clarify the Sustainability Assessment Criteria
The Trust recommends that the Sustainability Appraisal (SA) includes greater
transparency about the criteria used to assess different options and site allocations.
At present, it is not possible to determine how each site allocation was scored against
the 16 sustainability categories, which in turn raises questions as to how these
conclusions were formulated. In particular, we are concerned that for category 6: To
protect and enhance the natural environment of the SA, almost all the site allocations
have scored either a negative or strongly negative scoring, implying one of the
following:
- All site allocations are highly detrimental to the natural environment, in which
case the preferred housing options are collectively not an effective strategy to
deliver sustainable development in the district
- The environmental gains and benefits that new development can bring to a site,
through for example the protection and enhancement of valued ecological
features, green infrastructure delivery or habitat management, have not been
factored into the scoring assessment.
- The current criteria used for the natural environment is not sensitive enough to
differentiate between sites that can, on balance, provide opportunities for the
natural environment and those that can't. This could have occurred for example
by strong weighting towards factors such as the loss of the green belt, which will
always score negatively where development in the green belt is proposed.
The Trust would therefore like to see more information in the SA to justify why the
preferred development strategy has consistently shown negative scores for the
natural environment and how this development strategy can in turn contribute towards
the pursuit of truly sustainable development.
We believe the SA should detail a standardised and objective criteria for which all site
allocations should be assessed. This will give relevant stakeholders the opportunity to
review and comment upon the factors that influence the scoring for each site
allocation; helping to differentiate between the sustainability of different sites and
giving greater weight to the SA process overall. Using this feedback, the local
authority can then be confident that their chosen strategy represents the most
appropriate strategy when compared to all reasonable alternatives.
We believe that any scoring criteria for the natural environment should be inclusive of
both constraints and opportunities. This would ensure a more balanced approach to
scoring the natural environment category as impacts of each site allocations can be
considered in the context of other benefits and wider contributions to ecological
networks and biodiversity targets in the district. This approach is also more consistent
with the NPPF which requires local authorities to plan positively for ecological
networks in order to halt the loss of biodiversity by 2020. Subsequently, when scoring
site allocations for the natural environment, we recommend that the following factors
are taken in to consideration.
- Does the site impact on statutory and non-statutory wildlife sites
- Does the site impact on Local Biodiversity Action Plan (LBAP) habitats and
species and other important ecological features such as river corridors.
- Does the site have potential to impact on populations of protected species?
- Is there an ability to provide ecological mitigation to avoid or reduce long-term
impacts
- Are there opportunities for habitat enhancement, buffering statutory and nonstatutory
sites or introducing a management plan for sites, features or species of
ecological importance
- Are there opportunities to create, link-up or restore biodiversity and green
infrastructure assets across the district?
The Trust recommends that the impact on natural resources and ecosystem services
should also be considered within category 5: to ensure the prudent use of land and
natural resources of the SA. Currently this category is understood to be scored only
on whether or not the site allocation is on greenfield or brownfield land. However, this
does not take into account impacts on soils, air quality, natural resources or
ecosystem services. Nor does it consider what opportunities are available to mitigate
and enhance current natural resources and ecosystem services within site allocations
and how proposals could contribute to national targets and ambitions, such as those
listed in Biodiversity 2020: A Strategy for England's Wildlife and Ecosystem Services
for maintaining healthy and well functioning ecosystems and restoring degraded
ecosystems services. The Trust believes the impact on natural resources and
ecosystem services is a significant consideration in choosing site allocations and if
inadequately assessed could compromise the ability to achieve key objectives in the
plan or even the effectiveness of policy provisions. We subsequently recommend that
the site allocations are reviewed accordingly to account for these points.
Review Conclusions of Sustainability Appraisal
In light of our concerns above, we believe the local authority should review the scores
and conclusions given for category 5 and 6 of the sustainability appraisal. To aid this
process the Trust has briefly summarised a number of factors which we believe
should be considered for each preferred housing allocation. This summary is included
in appendix 1.
PO8. Economy
Warwickshire Wildlife Trust believes that it will be important for the local authority to
explore the case for including the proposed Warwickshire and Coventry Gateway
development area in the local plan. We are broadly supportive of the approach
detailed in paragraph 8.33 of the consultation document to review the impacts of the
proposal and believe this work will be essential if it is to be a justified allocation in the
plan. The Trust also recommends that in reviewing the impacts of the scheme, the
local authority should also take full account of the environmental and social
implications of including the allocation in the preferred options so that the economic
incentives of the scheme can be considered in the context of wider sustainability
objectives for the district. The evidence base for the natural environment will therefore
have to be reviewed and updated in order to inform the sustainability appraisal for this
site and any other reasonable alternatives that come forward as part of this review
process.
When considering the implications of all potential employment sites it will be
necessary to consider both the constraints and opportunities for the natural
environment. Having engaged in discussions about the Gateway proposals so far, the
Trust has identified numerous adverse effects on ecological assets but have noted
that the site also offers opportunities to deliver environmental enhancements in
strategic areas for green infrastructure and biodiversity, such as the River Avon LWS.
We believe the local authority needs to acknowledge and balance these factors so
that the impact on the natural environment on all site options can be more accurately
determined and assessed within the sustainability appraisal. Criteria for assessing the
constraints and opportunities of employment scheme on biodiversity should therefore
refer to the detailed criteria outlined above for housing allocations.
Any policy that favours a potential employment site of regional importance should
ensure that the enabling provisions reflect and are supportive of other themes in the
new local plan. The allocation should therefore embody the principles of sustainable
development by ensuring it contributes to wider economic, environment and social
objectives jointly. This should include improvements to green infrastructure and the
natural environment that are equivalent to the site's strategic importance so that it can
be seen as an exemplar for sustainable design and construction within the plan. In
order to optimise the potential for high quality environmental improvements, the Trust
strongly recommends that the policy wording should seek enhancements in line with
the district's ecological and green infrastructure networks, LBAP objectives for priority
habitats and species and Water Framework Directive objectives.
PO10. The Built Environment
The Trust is broadly supportive of the preferred option for the Built Environment. We
welcome the acknowledgement of the need to protect, enhance and link the natural
environment and would further support policy wording that recognises and promotes
the benefits of incorporating green infrastructure and suitable features for biodiversity
in and around development proposals. We believe that including these provisions,
together with links to other themes within the local plan, will help to underpin the
delivery of the Garden Suburbs prospectus and thus secure the district's ambitions to
promote high quality and sustainable development through the local plan.
PO12. Climate Change
The Trust is supportive of preferred option PO12 and in particular the local authority's
commitment to include a policy that promotes climate change adaptation. We
recommend that in wording this policy, due consideration is given to ensuring
linkages to delivering green infrastructure, protecting and enhancing biodiversity and
ecological networks and supporting objectives for mitigating and enhancing flooding
and water quality as these will all support and provide a context for delivering climate
change adaptations through new development proposals.
PO15. Green Infrastructure
Warwickshire Wildlife Trust welcomes the local authority's commitment to protect,
enhance and restore the district's strategic green infrastructure (GI) network. We
believe that the supplementary work to identify the network and the subsequent GI
projects that have informed the infrastructure delivery plan, provide a strong context
for securing mitigation and/or contributions towards GI enhancement within the new
local plan. Acknowledging the linkages with other themes such as Flooding and
Water, Climate Change and the Built Environment, GI should be considered an
integral part of good design and so we recommend that this is reflected in the wording
of an overarching green infrastructure policy. This has already been reflected in part
under the 'Development Proposals' paragraph in PO15 which would in turn create an
excellent starting point for the policy wording.
The Trust is pleased to note Warwick District's intention to adopt the sub-regional
green infrastructure SPD. This provides an excellent opportunity to secure strategic
improvements to priority ecological networks throughout Warwickshire, Coventry and
Solihull which will in turn strengthen and compliment existing district wide and local
networks. Maintaining the reference to each level of the strategic green infrastructure
network will ensure that contributions to achieve these aims can be secured; thus
demonstrating the district's commitment to planning positively for networks of green
infrastructure. However it may be necessary to clarify how and when improvements to
the different networks will be sought and the mechanism that will be used to balanced
how these contributions are distributed between the local, district and sub-regional
networks accordingly.
Our concern with the preferred option so far is the coupling of a green infrastructure
policy with the protection and enhancement of biodiversity. Whilst we agree that sites,
features and corridors of wildlife importance do form an integral part of local, strategic
and sub-regional GI networks, we believe that a GI policy cannot deliver the robust
and objective protection for biodiversity assets that could normally be set out within a
specific biodiversity policy. The NPPF set outs a good criteria based approach for
protecting statutory and non-statutory sites. It requires policies to differentiate
between sites of national and local importance so that their protection is
commensurate with their status and the contribution they make to wider ecological
networks. For local sites this criteria based protection is essential as it clearly defines
the level for which it remains robust when challenged by development interests.
Conversely, the multifunctional nature of GI makes it difficult to specify a criteria
based approach for its individual components and so blanket protection must be
applied to safeguard all assets. Whilst in principle, absolute protection is an ideal; the
Trust recognises this is likely to be less effective as it makes it much more vulnerable
to challenges from development interests. Subsequently, whilst maintenance and
enhancement of ecological networks should still be pursued through a green
infrastructure policy, we believe that a specific biodiversity policy is also needed to
ensure a sufficient level of protection for sites, features and habitats of biodiversity
importance. Our policy recommendations for biodiversity are discussed below.
POXX. Biodiversity
Warwickshire Wildlife Trust strongly recommends that the preferred option includes a
policy to specifically outlining the protection of the district's biodiversity assets.
Referring to our comments above, we do not believe that a green infrastructure policy
in isolation can provide an adequate level of protection for individual biodiversity
assets within the district. A biodiversity policy, founded on the criteria based approach
detailed in the NPPF, is considered to be a more effective approach as it:
- ensures that protection is commensurate with the site or feature's status and
contribution towards wider ecological networks,
- provides greater clarity as to how impacts on biodiversity assets will be judged
therefore proving to be more robust when challenged; and
- can specifically promote the preservation, restoration and re-creation of priority
habitats, ecological networks and the protection and recovery of priority species
populations in line with national and local targets.
Ensuring robust protection for biodiversity assets should be considered as a priority
when planning positively for ecological networks. Statutory and non-statutory sites,
particularly Local Sites, provide the fundamental building blocks for establishing
ecological networks. With these sites only constituting approximately 3% of the entire
district area, it will be essential that these core features are effectively secured.
However, important biodiversity assets are not simply confined to these areas and so
it will be necessary to ensure that the policy outlines a degree of protection for other
important biodiversity features that do not benefit from a statutory or non-statutory
designation, such as wildlife corridors, LBAP habitats and species and linear features
such as hedgerows and watercourses.
The Trust therefore believes that the strong protection of statutory and non-statutory
sites and other features of ecological importance should form an integral part of a
biodiversity policy within the local plan. In order for this policy to be effective, we
support the criteria based policy approach detailed in the NPPF as this clearly
outlines the relative weight given to each site, feature and habitat so that protection is
commensurate with its status and the to the contribution it makes to wider ecological
networks. However, as the criteria must differentiate between national and local
designations we believe that the policy should include separate policy clauses for
sites of International importance (SAC, SPA, Ramsar), national importance (SSSI),
county importance (LWS, LNR) and features of district/county importance (LBAP
habitats and species, wildlife corridors).
Where impacts on features of nature conservation importance are identified, it will be
necessary to outline how impacts can be resolved to prevent a net loss of
biodiversity. Paragraph 118 of the NPPF provides a useful hierarchy of how impacts
should be dealt with in this instance. It requires that all adverse impacts on
biodiversity should be avoided first, then if impacts cannot be avoided, and the
reasons for the development demonstratably outweigh the nature conservation
importance of the site or feature, mitigation should be secured. Compensation should
only be sought as a last resort. The Trust would advise that this categorical approach
to dealing with biodiversity impacts is adopted into a biodiversity policy for the local
plan. We also believe that a reference to Biodiversity offsetting should be included at
this stage of the policy (As opposed to including it in the green infrastructure policy)
so that if compensation is sought for a development, then the district can demonstrate
that it has an objective mechanism for ensuring that the proposal will not result in a
biodiversity loss. References to the sub-regional and district GI strategies, together
with the proposals for a Nature Improvement Area or the results of any Biodiversity
Opportunity Mapping, should be included here to outline how the biodiversity
offsetting process contributes towards delivering strategic gains for biodiversity.
However, biodiversity offsetting is a means to quantifying biodiversity impacts that
cannot addressed on site and so it should be clearly outlined that this process is a
last resort where adverse impacts cannot be avoided or mitigation for on site.
The Natural Environment White Paper has outlined that the UK needs more, bigger,
better and joined places for nature to reverse the continual loss and decline of
biodiversity and essential ecosystem services. This policy should therefore form the
basis for securing biodiversity gains through the planning system in order to
contribute towards the Government's ambitious target of halting the loss of
biodiversity by 2020. To transpose these targets and policies in to the District's local
plan, it will be necessary for the biodiversity policy to also include some provision for
enhancing biodiversity as well as protecting it. This could be achieved, for example,
by promoting habitat creation, restoration, re-creation and/ or management of existing
features within all new development proposals. Whilst a green infrastructure policy
goes some way towards this provision, it is non-specific to biodiversity and cannot
guarantee that improvements to the network deliver these crucial gains for
biodiversity. The Trust believes a policy clause could be included in the biodiversity
policy as means to securing these aims.
Warwickshire Wildlife Trust would welcome the opportunity to input into, or comment
on, any policy wording that is developed for a specific biodiversity policy in the new
local plan.
PO17 Tourism and Culture
The Trust believes that policies that support sustainable tourism should be
encouraged providing that they truly reflect the principles of sustainable development.
New sustainable tourism developments should therefore be able to detail how they
safeguard and contribute towards the enhancement of biodiversity assets, the water
environment and green infrastructure whilst demonstrating high quality and
sustainable design and construction throughout. The Trust would subsequently
welcome a clause within a sustainable tourism policy linking it to wider themes within
the local plan to clearly define what 'sustainable' tourism should be expected to
achieve.
PO18. Flooding and Water
The Trust are broadly supportive of the preferred option for flooding and the water
environment; however we believe that PO18 is lacking in detailed provisions for
safeguarding and enhancing water quality and optimising opportunities to reduce
flood risk by linking with themes such as green infrastructure, biodiversity and the
built development.
The need for stronger controls on protecting and enhancing water quality is outlined
in paragraphs 18.12 - 18.14 of the consultation document. It details that only 11% of
water bodies in the district are at 'Good' ecological status and so the district must
employ an ambitious approach to tackling water quality issues within the local plan if it
is to achieve the objectives of the Water Framework Directive by 2015. Development
can contribute to towards improving water quality though a number of means such as
SUDS, buffering watercourses and reconnecting them with their floodplains, creating
new wetland habitats and retrofitting measures that assist with attenuating and
filtering surface water before it is discharged into water bodies. The Trust therefore
recommends that such measures are strongly promoted in all new developments so
that provisions to safeguard water quality are also pursued in tandem with
opportunities to mitigate and enhance them. Policy wording that would support this
approach would be strongly welcomed by the Trust
The Trust recognises and supports the district's commitments for preventing new
development within flood risk zones in order to reduce future flood risk issues.
However, we believe that this approach should be the minimum requirement for
reducing flood risk as there is also a need to mitigate against existing flood risks and
adapt to the to changes in river levels that are likely to occur as a result of climate
change. The Local Authority should therefore be planning positively for addressing
flood risk, promoting opportunities not only to incorporate SUDS but to reconnect
rivers with their natural flood plains and support the creation of new wetland and
riparian habitats thoughout the district. The Trust acknowledges and welcomes the
district's strategic green infrastructure proposals adjacent to the River Leam which will
ensure that contributions for new development can be strategically placed; however
these principles should be embodied into policy wording so that wider opportunities to
reduce flood risk can be pursued. Where possible, opportunities to reduce and adapt
to food risk should be included in the scoring criteria in the SA for flooding as well as
determining whether or not the allocations is within the flood plain.
I hope these comments are useful to you as you progress the development plan
through to the next stages. Please do not hesitate to contact me if you seek further
clarification on any of the above points.
Yours sincerely
Richard Wheat
Planning and Biodiversity Officer
Warwickshire Wildlife Trust
Appendix 1: Summary of factors that should be considered when scoring site
allocations against Category 6 in the Sustainability Appraisal
Site Name Summary of ecological comments for the scoring
criteria described above
Woodside Farm
(South of Whitnash)
The small section of broad-leaf woodland and the mature
hedgerows and trees are the key features of this site. However
there are opportunities to retain these features and enhance
them through buffering or new habitat creation which should be
reflected in the score for this site.
Whitnash East
(South of Sydenham)
Whitnash brook, which forms the eastern boundary of the site, is
an important watercourse and wildlife corridor that supports a
good variety of semi-natural habitats and connects to the
adjacent Local Nature Reserve in the north. The development
area also supports hedgerows which connect the feature to the
Railway cutting to the east which is a pLWS. The presence of
protected species will also need to be considered and so overall
this site could score unfavourably on these grounds. Scoring
should take into account that impacts on the brook could be
avoided and mitigated through a substantial buffer and the
hedgerows could be retained to maintain connectivity to the
adjacent pLWS. There is also an opportunity to extend the
existing LNR boundary south along the eastern boundary of the
site by buffering the brook and delivering further habitat
enhancement, creation and restoration on site.
Fieldgate Lane
(Whitnash)
Species rich hedgerows and the adjacent railway pLWS are the
key ecological features for this site. The grassland habitat that
constitutes much of the site contains ridge and furrow, but is
species poor and offers opportunities for enhancement. The site
offers excellent potential to buffer the railway pLWS and retain
the hedgerows which are confined to the site boundaries. It also
provides opportunities for habitat restoration and creation on
site.
South of Gallows Hill/
West of Europa Way
The linear belt of habitats following the Tach Brook is an
important and sensitive feature of the site. Some of these
habitats also form part of Nursery Wood pLWS and connect well
with New Waters LWS and so the site should score
unfavourably on these grounds. Numerous hedgerows and trees
are also present throughout the site, providing opportunities for
protected species such as otter. This will need to be reflected in
the scoring for this site. The Tach brook corridor with associated
semi-natural habitats could and should be substantially buffered
and maintained in order to retain this important connective route
throughout the site. Buffering along the Nursery wood pLWS
boundary to the west could also be achieved as part of any
landscaping proposals to maintain linkages. Hedgerows and
mature trees could also be retained although there is likely to be
some loss to provide access across the site. The site offers
good potential to deliver habitat creation, restoration and
enhancement particularly around the Tach brook area and
improve connectivity to surrounding sites, features and habitats.
Myton Garden Suburb
(North of Gallows Hill)
The presence of a biodiverse watercourse, veteran trees,
mature hedgerows, ridge and furrow grassland and a good
likelihood of protected species are likely to score this site
unfavourably. However, there are opportunities to retain
important hedgerows and trees and buffer and enhance the
watercourse as well delivering new habitat creation or
restoration on site. The watercourse could provide linkages to a
strategic wildlife corridor in the form of the River Leam
Loes Farm
(North of Woodloes)
The Veteran Oaks, watercourse and old semi improved
grassland with yellow meadow ants are important and unique
ecological features that according to the WDC Habitat
Assessment are a significant constraint to the development at
this site. As much of the site constitutes the old meadow it would
be impossible to deliver even small amounts of development
without adversely affecting these key features and so the site
should score unfavourably on these grounds. If impacts can be
minimised, there may be opportunities to enhance the
watercourse and the plantation woodland on site and improve
the current botanical diversity of the grassland
Red House Farm
(East of Lillington)
The Hedgerows are perhaps the key feature of the site, together
with the opportunities they provide for protected species.
However there are opportunities to retain the hedgerows as well
as potential to deliver habitat creation and restoration throughout
the site.
Land North of Milverton The brook corridor which is a tributary of the River Avon LWS,
the area of semi-improved grassland to the southeast and the
species-rich mature hedgerows and trees are all key features for
the site. The layout of the hedgerows would likely make it
difficult to retain the vast majority of these features and so
should be scored unfavourably on these grounds. Removal of
these features and the any associated mature trees would also
likely disrupt habitat opportunities for protected and noteworthy
species such as farmland birds and bats. Otters may also be a
consideration. There are opportunities to maintain and buffer the
brook corridor in the northeast of the site enhancing linkages to
the River Avon which is a strategic green infrastructure asset.
There are also opportunities for new habitat creation, restoration
and enhancement throughout the site.
Thickthorn (Inc Land
north of Thickthorn)
The section of Thickthorn wood LWS within the site boundary,
the adjacent Glasshouse Spinney LWS, the mature hedgerows
and trees and an area of semi-improved grassland are all likely
to be constraints to development at this site. There are
opportunities to retain and buffer these key ecological features
but there is a risk that infill development in this area will further
isolate or restrict connectivity to and between these features.
Scoring should reflect this cumulative impact. Opportunities for
new habitat creation could help reduce these impacts by linking
up the woodlands as well as contributing towards wider
enhancements to the Arden Landscape area.
More information is needed about the habitats north of
Glasshouse Spinney to provide a more comprehensive
summary for this site.
Land at Blackdown Up-to-date ecological data required
Warwick Gates
Employment Land
Up-to-date ecological data required

Preferred Options.
Not should be located could be located.
Not should expect would expect

Part 1 Intro
Local Plan, key to help War Dist deliver its vision for next 15 yrs.
Produced with Police, fire and rescue and health and many others

Part2 our vision for district
To make Warwick district a great place to live, work and visit.
Council and partners trying through the Sustainable Community Strategy.

Try means fail. Do there best is what they mean. I make no comment on
how good this is.

This sets out 4 key priorities and 5 cross cutting themes.

Priorities

Safer Communities
Health and well Being
Housing
Economy, Skills and Employment

Cross Cutting Themes

Narrowing the Gaps
Embedding sustainability throughout.
Families at risk
Engaging and strengthening communities
Rurality

The Sustainable Community Strategy is central to improving life in the
District across all the themes. Supported by series of Delivery Plans
and Locality plans which set out approach to improve areas of the
District.

Local Plan a key element to deliver Sus Comm Strat
Preferred Options for Local Plan have been aligned with Strategy to
ensure it will address these priorities and themes.

Strategy for Future Sustainable Prosperity of District
to deliver vision, Council agreed key principles to develop Local Plan.

These include

Economy
Facilitating growth and development of local economy to support a
dynamic, flexible, low carbon, mixed economy
Agreement to pursue the potential for sub - regional employment
site at the Gateway. The need to provide new employment land in and
around the thee main towns to meet local needs encourage creation
of jobs.

the need are food, water, air etc. This is a want.
local needs. If this is the above ok, if not this is a want.

Commitment to maintain and promote thriving town centres

How does building out of town supermarkets achieve the above ?

Commitment to maintain current strengths in districts economy.
Promoting regeneration of more socially / environmentally deprived
areas and support rural economy

Providing for growth and population changes.
meeting housing of the existing / future population of District including
land for around 550 new homes per annum on new allocated sites
Providing for diversity, including affordable homes for elderly and
vulnerable. Sites for gypsies / travellers and other specialised needs.

If these are green sites Please quote the Green Party's Countryside
policy

Please see above

Providing for neighbourhoods that are well designed, distinctive and
based on principles of sustainable garden towns, suburbs and villages.
Providing home and neighbourhood designs that are sustainable,
low cost and carbon efficient.

Environment
Distributing development across District.
Avoiding coalescence
Ensuring developments based on principles of sustainable Garden Towns,
suburbs and Villages.
Protecting biodiversity, high quality landscapes, heritage assets and
other areas of significance

They have been reading the Green Party's Countryside Policy

Emphasis on infrastructure
Developing an effective / sustainable transport package
Ensuring parks, open spaces, countryside and areas for wildlife are maintained
and improved

They have definitely read the Green Party's Countryside Policy

Ensuring education is provided for in major new developments

Does this include gypsys and travellers

Ensuring community activities, health services and other key services
are provided for in new developments
Develop sustainable communities with strong local centres and / or
community hubs

Done so far
May 2011 Document of key issues and scenarios for growth published.
This was subject of consultation.
Substantial amount of evidence gathered, to help understand changes
locally and what we need to plan for.

Please see above

This information important in helping develop preferred options
December 20011 Council agreed Future and sustainable Prosperity
of Warwick District. This set out key criteria for Preferred Options
Range of options appraised lead to selection of a preferred option
for each aspect of plan
The Government has published National Planning Policy Framework
This underlines importance of well justified upto date local plans and
means local plans play vital role in shaping future of local areas.
Whilst options can be justified. Important to underline they are
suggestions and not proposals for L Plan. The Council also prepared

Infrastructure Plan to go with Preferred Options. This Plan outlines
transport, schools, health open spaces, which is needed to help new

Please see above

communities prosper. More needs to be done on this, but again,
the Council is keen to hear from all interested parties about
infrastructure requirements.

Please see above

For those interested infinding more why these options chosen see
chapter below or www.warwickdc.gov.uk

Following consideration by Executive consultation starts 1st June
to 27 July Council keen to hear from anyone. Consutation is number
of public meetings, exhibitions and roadshows, local press and website.
Following consultation, work undertaken to develop draft Local Plan
with detailed Infrastructure Delivery Plan and Community

infrastructure Levy scheme. Then, approval of Daft Local Plan and

investment strategy, delivery to Council late 2012 early 2013.
Publication of Plan Feb 2013. 6 week consultation March / April 2013
Submission to Secretary of state June 2013
Pre - hearing meeting July / August 2013
Examination Public Hearing October / November 2013
Inspector's report February / March 2014
Adoption Estimated March / April 214.

4 Spatial Portrait, Issues ansObjectives see map 1
Warwick District has a growing, ageing, urban, ethnically diverse
and highly skilled population.
90% of the 138,800 live in Kenilworth, Warwick, Whitnash Leamington
areas. 10% in small villages. Population grown from 124,000 in
2000 12% increacse, forcast to grow 15% in next 15 years.
Compared to other parts Warwickshire,a higher proportion of
working age. Highest rate expected over 65
District diverse population, high proportion non - white 15% compared
to rest of county.
Notwithstanding current economic downturn, district has strong local
economy with skilled population higher productivity, earnings
compared with reginal / national averages
significant proportion of is designated for environmental or
historic value. To protect and maintain the character of District
Local Plan will balance growth and protecting enhancement of
assets.
So it is supposed to be
Areas of historic and environmental importance include 81% 28,000
hectares of Green Belt. 7 sites scientific interest. 15 sites important to
Nature Conservation. 2145 Listed Buildings. 29 conservation areas
4% of District. 11 Registered Parks and Gardens 4% of District.
ISSUES
District faces a number of opportunities and issues, important Local Plan
addresses these. Council consulted on issues facing District during
spring 2011 and thought consultation on following issues identified
important: Effects of recent recession and not knowing economies
future
House prices limit local peoples ability to buy or rent in area, creating
need to provide more affordable housing in towns and villages in the
future.
Please see above
Threat to economic strength of town centres in Warwick,Leam and
Kenilworth from retail and leisure developments elsewhere.
Size and condition of existing community facilities and services
( particularly schools and health - care ) and whether they can
meet current and future needs. Peoples health and well - being
and the need for people ( particularly teenagers and young
people ) to have access to sport and cultural experiences
such as cinemas and community events.
Road congestion and air polution around main junctions along
A46 and M40, routes into towns and in town centres.
Threat of flooding to homes and businesses in some areas
particularly where surface water may flood towns and villages
and concern that flooding will increase beacause of climate
change.
Areas of poverty in Warwick and Leam
Presure for development threatening the high - quality built
and natural environmets in district, particularly historic
areas and the cost of maintaining historic buildings in the areas.
Crime and the fear of crime, paticularly in town centres and the
need to protect the community from harm.
Governments plan ned high speed 2 rail line and possible
effects on the area (government cosulting on this ).
During consutation in spring 2011, number of objectives
identified. These set out key aims Local Plan will seek to deliver.
Following consultation objectives have ammended to take
account of views received and more recent changes ( such as
publication of National Planning Policy framework ).
Objectives have been used to link Council's Stratergy see above.
Providing sustainable of levels of growth in district.
And balance with housing growth to maintain high levels of
employment and deal with unemployment in deprived areas.
Local Plan will identify and maintain flexible and varied supply of
accommodation and land for right businesses.
Support the growth of knowledge - intensive industries, energy
and the rural economy;
improve business growth to support organic growth of local
economy.
Provide a sustainable level of housing balanced with economic
groth to reduce homeless and in unsatisfactory accommodation
to meet needs and help deal with future need for affordable
housing. Local Plan will : identify and maintain


right type, right tenure and in right location.
Make sure that new developments will reduce car use.
this improves air quality and help address climate change
reducing road congestion and carbon emissions, encouraging
people to walk and cycle more. Make sure new developments
are designed and built so they use water more effeciently and
reduce demand for natural resources. Increase renewable
and low carbon sources to reduce emissions.
.Make sure new developments are located, designed and built
so they can deal with the expected effects of climate change
particularly flooding. Make sure new developments are
distributed across district,and located to maintain and improve
the quality of the build and natural environment, particularly
historic areas and wildlife habitats and buildings and
areas of high landscape value. New developments should
respect the integrity of existing settlements. Make sure
new developments are built to high standard in terms of
design and provide incluplacessive liverly and attractive
places where people feel safe and want to live, work and visit
Make sure new developments provide public and private open
spaces where there there is a choice of areas of shade, shelter
and recreation which will benefit people and wild life, provide
flood storage and carbon management.
Make sure , if buildings and spaces particularly in historic
areas need to be adapted to meet the changing needs

Please see above

Check with Police WHITNASH

of the economy a nd to deal with environmental isssues
in a sensitive way 4.12 Enabling infrastructure to
improve and support groth. Enable organisations such
as schools and health service and provide and
maintain improved facilities and services in locations
peopoe can get to and that can meet current and future
needs and support sustainable economic groth in deprived

THIS may be correct, dwellings are another need

Even those sleeping rough go to the Salvation Army
for tents.
areas. Enable energy, communications, water and waste
organisations to improve their infrastructure and services
so they can meet peoples needs. Protect the environment

ALL TOGETHER NOW. Please see above

and contribute towards dealing with causes and contribute
dealing with the causes and mitigating the effects of
climate change.
Enable transport providers to make improvements more
integrated public transport cycling and pedestrians
organisations to improve their infrastructure and services
transport network, support sustainable economic growth.
Enable improvements to be made to the built and natural
environments which will help maintain and improve
historic habitats and their connectivity, help the public
access and enjoy open spaces such as parks and
allotments, reduce the risk of flooding. Keep the effects
of climate change

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.

Thank you for the opportunity to comment on the consultation for the aforementioned document. As the market leader in the provision of sheltered housing for sale to the elderly, McCarthy and Stone Retirement Lifestyles Ltd considers that with its extensive experience in providing developments of this nature, it is well placed to provide informed comments on your 'Local Plan Preferred Options' insofar as it affects or relates to housing for the elderly.

McCarthy and Stone are satisfied that the Local Plan Preferred Option's report indicates that there is a 'need to provide more housing to meet people's needs in the future, particularly those of older people', and that this is clearly identified as an issue within the District. They are particularly pleased that the Local Plan aims to provide 'sustainable levels of growth in the district' by allowing 'providers to meet the special housing needs of the growing number of older people'. However, we are concerned with the distribution of housing, and would strongly encourage policy to express support for the re-development of urban brownfield land. My Client would stress that policy should give brownfield sites precedents over Greenfield sites / edge of settlements.

Furthermore, McCarthy and Stone commend the Local Plan's recognition of the 'need to provide more housing to ensure that the needs of current and future residents are addressed, particularly those of older people'; indicating that the 'the highest rate of projected population growth in the future is expected to amongst those aged 65 and over'. Furthermore, My Client is also pleased that the Local Plan quotes the SHMA's estimation 'that 18.7% of future need is likely to be for specialist housing'.

My client supports the proposed policy PO6: Mixed Communities & Wide Choice of Housing, which states that 'all strategic sites will include Extra Care Housing schemes located close to local facilities'; and that all 'proposals for Retirement Villages and Continuing Care Retirement Schemes will need to meet locational criteria and be accompanied by evidence that the homes/bed spaces meet the needs of the community'. However, McCarthy and Stone would stress that the policy should take into account general sheltered schemes, which will widen the housing choices available for older persons within Warwick District Council

The need for specialist housing for the elderly is expressed within the Strategic Housing Market Assessment (2011), which 'indicates that 9% of market demand (37 homes per annum) will be for specialist housing, particularly for older people'. Critically, the SHMA states that 'around three quarters of older person households are outright owners', and that older households are 'very likely to under occupy homes, with two-thirds living in homes with three or more bedrooms'. The SHMA also stipulates that 'there may be potential for policy to seek to reduce under-occupation by providing support and incentives to households to downsize. This may help to release larger housing for family households in priority need'. This is supported in the SHMA through a later statement that 'over the plan period to 2031 there should however be some potential to release supply of existing family housing by supporting downsizing of older households and providing specialist housing to meet their needs'. Additionally, the SHMA also states that 'the Council should consider inclusion of specific policies for specialist housing within the Local Plan on this basis. McCarthy and Stone would support this and encourage the Council to review and strengthen the policy for specialist housing for the elderly.

Despite the above, McCarthy and Stone is concerned that the draft Local Plan does not provide for the delivery of actual policies. There is clearly an existing and growing elderly population and a need for specialist housing. This is supported within the Local plan which states 'the SHMA estimates that 18.7% of future need [for market housing] is likely to be for specialist housing, of which 9.7% is likely to be for affordable specialist accommodation'.

It is therefore vitally important to address this need, as encouraged in the National Planning Policy Framework (NPPF). McCarthy and Stone would urge that a specific policy for elderly housing be introduced within your Local Plan.

McCarthy and Stone suggest that the following be introduced to positively support the delivery of specialised accommodation for older people including sheltered housing:

"Development proposals for accommodation designed specifically for the elderly will be encouraged provided that they are accessible by public transport or a reasonable walking distance to community facilities such as shops, medical services, places of worship and public open space."

The National Planning Policy Framework
It is necessary to consider the National Planning Policy Framework (NPPF) adopted on March 27th 2012. The NPPF states that at the heart of national policy is 'a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking'. The Ministerial foreword acknowledges the challenges the country faces in accommodating the growing elderly population, emphasising 'we must house a rising population, which is living longer and wants to make new choices', and 'development that is sustainable should go ahead, without delay - a presumption in favour of sustainable development that is the basis for every plan, and every decision'.
Within the 'three dimensions of sustainable development' (economic, social and environmental), the NPPF stipulates that the planning system should be 'supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations' [emphasis added]. The NPPF calls for local planning authorities to seek out opportunities 'to meet the development needs of their area', and emphasises that 'the Planning system should be pursing sustainable development through widening the choice of high quality homes'.
In addition to this, the Framework highlights the need to 'deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities. Local planning authorities should plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community...such as older people' [emphasis added].

To ensure that the Warwick Local Plan is delivered in line with the NPPF, it is important to acknowledge the NPFF's statement that 'local planning authorities should use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market'. Reviewing the evidence within the Local Plan Preferred Options report, there is a clear market need for specialist housing for the elderly within Warwick. The Framework advises that:

'local planning authorities should have a clear understanding of housing needs in their area', and that policy should 'identify the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which meets household and population projections, taking account of migration and demographic change and addresses the need for all types of housing...including housing for the elderly' [emphasis added].

Furthermore, the Framework stipulates that local policy should cater for 'housing demand and the scale of housing supply necessary to meet this demand'.

It is therefore considered that much needed housing for the elderly should be encouraged, and that appropriate planning policy should play a part in delivering specialist housing to meet an evident housing need.

Policy PO5: Affordable Housing

In response to Policy PO5: Affordable Housing, and the fact that the policy will apply to 'developments which contain self-contained units of accommodation including specialist homes for older people', my Client would highlight paragraph 7.56 within the Local Plan Preferred Options, which stipulates that '18.7% of future need is likely to be for specialist housing...This type of housing is most likely to be for older households'. Therefore, the Local Plan recognises the need for specialist accommodation for the elderly.

A recent report "Housing Markets and Independence in Old Age - Expanding the Opportunities", by Professor Michael Ball of the University of Reading, which was presented at a House Commons launch event in May 2011, should be reviewed. This report, suggests that private sheltered housing for the elderly could be given an enhanced planning status, similar to affordable housing, to encourage sufficient levels of delivery from the private sector to meet existing and future demand, stating that:

'to improve the supply and lower the price of owner occupied retirement housing (OORH), this type of housing should be redefined as the equivalent of affordable housing in terms of negotiations with builders over development charges. Treating all OORH as a form of affordable housing in planning terms, because of its significant personal and community benefits, would help reduce prices and increase availability. However, to impose price or quality caps on part or all of it would damage supply. Rather this proposal suggests that all OORH new build should be given enhanced planning status alongside low-cost home ownership for younger households, which is already treated as a form of affordable housing' (emphasis added).

PO12: Climate Change

McCarthy and Stone are concerned about the inclusion of Policy PO12, and the viability of specialist housing for the elderly if this is enforced. McCarthy and Stone are particularly concerned with the 'requirement that seeks a 20% reduction in carbon emissions from development to include a contribution from renewable and low carbon technologies'. This 20% reduction is not in line with Building Regulations and national policy, which suggest a 20% reduction is only achievable by 2020.

Conclusion
The provision of owner-occupied specialised housing for the elderly will widen the housing choices available for older persons within Warwick District Council. It will allow the local elderly population to move into accommodation that enables them to remain living independently within the community and out of institutions, and therefore continue to contribute to the community, whilst enjoying peace of mind and receiving the support that they need.

McCarthy and Stone stress the need to consider addressing the current and future housing needs of older people within your Local Authority, and for your 'Local Plan Preferred Options' to further acknowledge the role that owner-occupied sheltered housing play in meeting older person housing needs, as well as Extra Care schemes, and in providing housing choice for the wider community by freeing up valuable, under-occupied family homes in the local area.

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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6 Hampton Street, Warwick, CV34 6HS
* 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.