15. Green Infrastructure

Green infrastructure is a direct contradiction of proposals. Development seems driven by developers and willingness of local land owners such as Oken Trist to sell assets

Whilst supporting this proposal in general the JPC believes that there should be more emphasis on bio-connectivity, habitat corridors, tree & hedge planting and the importance of rivers, canals and railway land.

I hope the Council demonstrates its support by not building on the green belt. How can you allow the destruction of a green belt and claim to have green credentials.

The green belt maintains Norton Lindsey as a tolerable place in which to live and has allowed development on a controlled proportionate basis which limits damage to the environment.

Electronic attachment

Having read the Local Plan for North Leamington I would like to register my objections as follows:

* Areas selected for development are Green Belt Land
* According to the National Planning Policy Framework principles - Green Belt Land should only be used in exceptional circumstances
* There are no exceptional circumstances - previously identified non Green Belt land within the district is available, sufficient for future housing needs
* We need to protect our local countryside wherever possible to conserve an important amenity & avoid urban sprawl

Please confirm receipt of this objection,

Yours sincerely

Margaret Bold

Town's Position
Kenilworth is situated in close proximity to the boundary of Coventry and in places, the Green Belt is less than 600 metres wide. The protection of the Green Belt as a whole, and in particular on the Coventry border, has always been a matter of great importance to the Town Council and it has made this a priority over a number of previous Local Plan consultations.
The population of the Town has grown by 140% in the last 40 years and this has led to the whole of the available land within its boundaries being used for additional housing. This has included in recent years land zoned for employment, as the District had accepted that there was no demand for some of the existing employment land.
Given the tremendous increase in population and the lack of demand for employment land, it was the view of this Council on the previous (subsequently withdrawn) consultation on the preferred options, that there was a clear case for there being no further development within the Town. This was vitally important, as any development that was allowed had to be on the Green Belt surrounding the Town. Those arguments are, we believe, still valid, especially as it is apparent from the Options paper that there are areas of land within the District that are not within the Green Belt, but which it does not intend to zone for development.
The Preferred Options do include land available for development that is not within the Green Belt. It is the Council's view that this should be reflected by requiring the phasing of developments to ensure that non Green Belt land is developed first. In this way, the existence and benefits of the current Green Belt would be extended.
District Council Position
The Town Council does, however, recognise that the District has put forward arguments, supported by the SHLAA and SHMAA surveys, that the Town does require now, and in the next 20 years, a certain amount of housing and employment land, for it to remain sustainable and viable; these will inevitably be in the Green Belt. It further appreciates that, if such developments were to be allowed to proceed, then it is necessary and essential that these should be carried out in the right place and subject to regulation that would enhance the Town and not damage it.
It is further aware, and accepts that it is the view of the District Council and the surveys carried out, that this would mean the addition of some 700/800 houses and provision for employment land and that it proposes that this development should be in the Thickthorn area.
Town Preferences
So that it assimilates better into the Kenilworth community, it is the Town preference that development of such magnitude should be distributed instead of being concentrated on one site. Such an approach would also assist in alleviating the disruption to the town's infrastructure that the planned block development would create.
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With this in mind, we have considered a variety of sites within the Town and since the areas available are all within the Green Belt, have tested those sites on the basis that the following requirements should be met:
1. It must be capable of being protected from further extension by having clear and defendable boundaries.
2. There should be clear separation from any other urban areas so as to avoid ribbon development.
3. It should be capable of having easy access to the Town.
4. It should complement the local community and not form a separate entity.
We applied these tests to the sites we had identified. Overall, we concluded that they would suffer from the major problem, not only of incursion into the Green Belt, but also of lacking defendable boundaries for the future.
Preferred Option Land
We also considered the Thickthorn site on the same requirements basis as described above.
This site has for many years been in danger of exclusion from the Green Belt. On all previous occasions, development has been opposed by the Council because of the danger of opening up the whole of the area bounded by Kenilworth, the highway and Stoneleigh Road.
Our view in regard to this site was as follows:
1. The northern extremity of the proposed development area is shown as the northern boundary of the Wardens Cricket Club. This was felt to be too far in a northerly direction, whilst there was no clear and defensible boundary to protect the Green Belt from further incursion to the north.
2. It would result in the loss of the Cricket Club and Rugby Club and its four training pitches, with the need to relocate them in the Green Belt if they are not to be lost to the Town.
3. This would also effectively double the loss of Green Belt in the Town area if, as we would wish, they were relocated adjacent to the Town.
4. The roads serving this area are subject to considerable congestion now. The addition of perhaps 700/800 houses and business use would add considerably to an existing problem, especially at the Thickthorn Junction, which is a major access point to the Town and its main connection to the dual carriageway.
Whilst we would not wish this area to be developed, we appreciate that the District has this in mind and, if development is to take place in that area, then it would be essential that:
1. The development should terminate at Rockey Lane in order to have a clearly defensible boundary.
2. This would allow the Rugby Club to relocate its number one pitch and Club house to the Cowpatch (being the field to the north of Rockey Lane) and the Cricket Club to
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remain in its current location, which it is understood, would be the Cricket Club's preference. These two grounds within the Green Belt, together with Rockey Lane, would then serve as buffer to development, as well as providing for open space and retaining the very important sporting facilities they provide for the Town.
3. We are aware, however, that the Rugby Club would have difficulty in relocating all of its facilities onto the Cowpatch.
4. If, in those circumstances, it was felt that the inclusion of the Cowpatch should be allowed then the protection of the Green Belt required by the Town Council could be obtained by the dedication of a public open space adjacent to the Cricket Club's southern boundary. This would not only protect the Green Belt but also act as protection to the Cricket Club from being too close to housing.
5. The inevitable traffic congestion at the entrances to this area require very specific planning provisions and, without definitive assurances in the Plan not to increase vehicular movements along Glasshouse Lane West and Birches Lane, then the Town Council would object to the site as a whole
6. There would be a clear need for road improvements at both the Leamington Road and Dalehouse Lane junctions to ease traffic flows. These would need to include the widening of Leamington Road, certainly in the area of the junction, and perhaps the widening of the slip road into the junction, allowing for traffic from the new estate direct access to the highway. Likewise, careful attention would be required at the Dalehouse Lane junction in order to have the same effect and the provision of an island should be considered to ease traffic flows at that access point. Having regard to the importance of these matters, it should be a condition of any development that the road works are carried out in accordance with traffic surveys and a modelling of the effects of the development should be carried out in advance.
7. The internal roads and infrastructure of the area will be equally important. Having regard to the size of the proposals there is a real danger of it being developed piece meal and by different developers. This could lead, as elsewhere in the Town, to the overall theme being distorted. It should therefore be built into the Plan that there should be an overall planning brief agreed before any development is started and that this shall be carried through.
8. Any development on the site would need to meet the requirements of the Plan for Garden Town type layouts, together with the need for the provision of open space, and a road layout that complements these requirements.
9. We feel it will also be necessary to make provision for a Primary School. For the purposes of safety and sustainability, this should be within the site thus allowing children to walk to School where possible.
10. The Local Plan presents an opportunity to include an Inset Plan that takes into account all these requirements. The Planning Department of Warwick District Council should provide a brief on the basis of these requirements, which should form part of the Plan, to assist in the development of the site as part of the local community and a complement to it.
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Effects on the Local Community
These must be taken into account, as the presence of the Town and its facilities are the main reason for making this area so attractive for development and will have a huge effect on its value.
In these circumstances, it is essential for facilities to be expanded and improved to cater for the new development as well as easing the strain on those already existing. This requirement will not only benefit the existing community, but also conserve those facilities and make the Town more attractive.
With this in mind we would expect that funds arising from the development should be provided to help the aspirations of the Town for the expansion of the Civic Centre to include all facilities, including a Theatre.
Further the introduction of 700/800 houses, whilst making the Town Centre more viable, will increase the burden on the Town Centre car parks and would merit the construction of a car park similar to the Waitrose model, namely one and a half storeys.
It will also require the provision of addition medical services by way of at least one more Doctor accompanied by the nursing services that the Surgeries now provide. This will mean that both surgeries serving the Town will require some extension. There will also be further pressure on the Clinic, which will require enhancement to enable it to serve the additional population.
The Rugby Club
The Rugby Club is a very valuable asset to the Community and if it is to be relocated then it is essential to the community that this is adjacent to the Town. This could provide an opportunity for the District to make provision for it at Castle Farm. The opportunity for joint working with the Club could provide an enhanced sporting offer that not only includes Rugby and the current pursuits, but also an Athletics Track. There would be a need to increase the area of the sports centre and this would fall within the Green Belt. It would, however, be immediately adjacent and accessible and to some degree within the Town. The increase of this existing use within the Green Belt would complement the Town.
Open Spaces
There is a need to increase the area of accessible open space within the Town. This is a matter that must also be addressed within the Plan. Whilst the Abbey Fields and Castle Farm and the Common give an impression of the Town enjoying a great deal of open space, Kenilworth does not enjoy as much open space as the other Towns within the District. Even taking into account the Play Area at Burton Green and Crackley Woods, both of which are outside the Town, the area available per 1000 of the population is 4.42 hectares as against the District average of 5.46 hectares and the Proposed Minimum Standard in SPD of 5.66 hectares.
Allotments
The Town and its Community enjoys several allotment gardens that not only provide an ability to grow vegetables and fruit for home consumption, but also the opportunity to enjoy outdoor exercise and recreation, whilst at the same time providing an additional open space for the community.
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The allotments are invaluable to the town and extremely popular, confirmed by the waiting list of 200 applicants, despite additional plots being provided in the last few years. It is essential therefore that an allocation of allotment land be found within the plan to meet and encourage this demand, especially as it will provide the further benefit of further open space.
This problem must be addressed in the new development and for the Town as a whole in the Plan. The provision of additional open space at Castle Farm would be a very useful additional contribution.
The Mere
We are awaiting the results of the feasibility study for the renewal of the Mere adjoining the Castle. This exciting project, adjoining an internationally recognised heritage site, would bring increased economic benefit into the area, as it would make the Town a National Tourist attraction with its Castle and Mere. Further, the additional amenity would enhance the open space available to the community and visitors.
Abbey Fields
Overview. The Abbey Fields are and have been for many years an invaluable centre for peaceful, open-air recreation that is easily accessible from all parts of the Town. We would stress that any Plan affecting the Town should ensure that no encroachment should either be allowed or envisaged. It was, and always has been, used for recreation for the community and children and any intrusion will conflict with those uses. No vehicles or cycles should be allowed within its confines other than for the provision of essential services or maintenance.
Cycle Routes through Abbey Fields. The Town Council would object strongly to the provision of a cycle route through the Fields, as this is contrary to the use envisaged for the fields since they were dedicated to the Town. Furthermore, it would be contrary to the byelaws that currently protect them from such use and which were imposed for the sites protection. Any such intrusion would inevitably conflict with people using the paths and the many children seeking recreation in the Fields; it would be impossible to police from abuse.
The Abbey Fields Play Area. The Council would, however, see some elements of evolution of the current usage as being advantageous and in keeping with the original grants. The Children's Play Area is in need of renovation, as is accepted by the District. When this is able to proceed, it is suggested that this would be an ideal time to reposition it on the bowling green area, which has been redundant for many years. This would provide a secure area for the Play Area and the existing Pavilion could be used as a shelter for accompanying parents. A further benefit of the secure area thus provided would be the exclusion of dogs from the play area.
The Play Area released by this relocation would allow for the expansion of the picnic area adjoining and the provision of a more formal site for the periodic Band Concerts. This would provide a better facility for the community and its visitors and be a better use of the Fields without in any way damaging them or being contrary to the original gift and purpose. It would also enhance the setting of the Barn Museum and improve it as an attraction.
Abbey Fields Car Park. The Town Council has considered and approved the proposed resurfacing of the car park in the fields, subject to such work complying with the advice of English Heritage to protect the underlying monument, and work being included to protect the trees in the Lime Walk.
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The trees form an invaluable asset to the Fields. Relocating the boundary of the parking area away from them and releasing the compaction around their roots caused by parking will improve their life span, although this raises the issue of their age. During the currency of the plan, preparations must be made for their replacement and the preservation of this beautiful part of the Abbey Fields. This should form part of the Plan, as the future of the Walk must be assured for future generations.
The existence of the car park does, however, affect the drainage of the meadow below it and this must be addressed. The meadow below, a very important part of the fields, currently suffers from bad drainage and frequent flooding. This must be improved to increase the recreational use of the area.
Civic Centre
It has been the joint wish of the Town and the District Councils to develop a Civic Centre in Smalley Place. This has begun to take place over the last few years with the relocation of the One Stop Shop to the Library and, latterly, the Town Council, MP, and Town Centre Development Manager, as well as the local Safer Neighbourhood Police Office, to Jubilee House.
It is the clear desire of the local authorities that this process will continue, in the hope that all the services required by the Public shall be available from that site or at least accessible. Further, we would like to see the relocation of the Talisman Theatre to the same area on the basis that this would also provide a venue, not only for the theatre, but also perhaps for use as an occasional Cinema and Meeting Hall in the centre of Town. The relocation of the Theatre would also provide a site for further housing.
There would also be the opportunity for the relocation of the Clinic into Jubilee House. This would provide patients and staff with enhanced accommodation and at the same time release its current site for redevelopment in accordance with the overall plan for the centre. An arrangement of this type would be in keeping with the objective of providing all services to the Community on one site and at the same time would lead to cost savings for the public purse.
This plan would, in our view, be an ideal project to seek support from the monies arising from the developments envisaged in the Local Plan. These facilities will complement and improve the facilities that the Town already enjoys, but would also be available to the persons who relocate to the new areas of the town.
Fire Station
The provision of employment land at Thickthorn could perhaps provide an opportunity to relocate the Fire Station as its current situation is not ideal. Its relocation at Thickthorn would provide an opportunity to build a full-time Station that would be easily accessible to the whole District along the existing and adjacent routes. This would be an advantage to the public purse as this could easily serve the whole District and release the current sites for other purposes.
Schools
As mentioned previously, it will be necessary for a Primary School to be provided for the children of the 700/800 houses likely to be built on the site and this must be provided within the development.
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There will also be additional pressure on the Secondary School at Kenilworth School and it will be necessary for this to be enhanced for that purpose. Kenilworth School is presently housed on two sites, with the Sixth Form located in Rouncil Lane. This might, therefore, be an opportunity for the Sixth Form to be relocated to Leyes Lane and the other site utilized for housing, as it has access already on to local roads and much of the school site is not used. The income generated would provide an opportunity to reinvest and enhance our Secondary School.
Further, the release of this area for housing would compensate for the loss of the area from the Cricket Club from the Preferred Option Plan area.
Railway Station
Finally, Kenilworth has a population in the region of 25,000 and as such must be one, if not the only Town of this size in the country, which does not have the benefit of a Railway Station. Warwickshire County Council has prepared a strong business case for the reintroduction of a Station upon the former station site at the junction of Waverley Road and Priory Road. The additional population that will result from the new development proposals can only strengthen the case already made for a new Station; the Council feels strongly that the suggested site should be included in the Plan. Additionally, it should be shown as a major objective of the Plan and an essential part of its future sustainability.

Thank you for providing English Heritage with the opportunity to further comment on this evolving strategic plan for the District. This correspondence will regrettably reiterate certain points made in previous letters dated 9 April 2010 and 5 July 2011; both are therefore attached for your information.
As the government's adviser for the historic environment, English Heritage broadly welcomes the positive strategy set out in section 11, and in particular Objectives 7 and 14 of the Plan.
I note a recognition in the Plan of the pressure for new development threatens the "highquality
built and natural environments in the district, particularly historic areas"1 but however goes on to reassure that 10,800 new homes (to 2029) will be founded on "best evidence"2 and located in the most suitable locations3 to help ensure the historic environment is then protected and enhanced4.
The National Planning Policy Framework (NPPF) provides the context and justification for doing so, requiring Local Plans to be prepared with the objective of contributing to the achievement of sustainable development in accordance with the principles and policies for the historic environment.5
The following comments on a number of the proposed allocations unfortunately highlight an inconsistency with the above:
1 WLP PO Paragraph 4.8 point 6
2 WLP PO Paragraph 5.1
3 WLP PO Paragraph 7.6 "In addressing the important housing issues, the Local Plan will aim to...provide well-designed new developments in the most suitable location".
4 WLP PO Paragraph 4.6
"To protect and maintain the character of the District, the Local Plan will have to balance the growth of the District with the protection and enhancement of these assets".
5 NPPF Paragraph 151
2
Site D Land south of Gallows Hill, Warwick
Key assets affected - Warwick Castle Park Grade I Registered Park and Garden; Warwick
Castle Grade I Listed Building; Warwick Conservation Area
In comparison to all the nine sites assessed in the Landscape Character Assessment for
Land South of Warwick (Richard Morrish Associates, 2009 - Referred to herein as the LCA Report), the site to the south of Gallows Hill is described as being the area of highest relative value to the setting of Warwick. It is the only site that is considered to be unacceptable in principle.
"This is generally an area of well maintained agricultural land that is important to the setting of Castle Park and prominent in approaches to Warwick. We feel it should be safeguarded from development". Paragraph 5.4 LCA Report
"Warwick and Leamington Spa have highly-valued historic cores and Warwick Castle and the associated Castle Park have national heritage significance. Protecting the setting of these features must be considered a principal goal of future development planning in the locality".
Paragraph 5.1 LCA Report
It is needless to say any proposal which harms heritage assets of such national significance to such a degree is contrary to the NPPF6 and the principles of sustainable development.
The harm is not outweighed by the public benefit associated with this housing development.
It should be noted that the LCA Report does not refer to either the Historic Environment Record or the Warwick CA Appraisal; and it preceded the publication of the NPPF (March 2012);The Setting of Heritage Assets - English Heritage Guidance (October 2010); The Warwickshire Historic Landscape Characterisation (HLC) Report (WCC 2011)7; and the Conservation Plan for the park. If applied these are likely to reaffirm the sensitivity of the site and the unsuitability of the allocation.
Site WL5a Loes Farm, Warwick (Guy's Cliffe)
The draft local plan fails to have adequately considered the impact on designated and undesignated heritage assets to determine the suitability of the allocation. The proposal would appear likely to cause substantial harm to undesignated heritage assets of significant value, and harm to the setting of designated assets that contribute to that assets significance. This would be contrary to the NPPF and the great weight that should be afforded the conservation of heritage assets.
I refer to my letter dated 10 April 2010.
"You should ensure that thorough evidence is applied to determine whether the proposal would adversely affect the significance of the designated historic landscape and its setting including key views in and out. The direct and indirect impacts of major new development on the individual components that determine the relative value of Guy's Cliffe in total should be understood.
English Heritage considers that the well preserved areas of ridge and furrow should certainly be regarded as of national importance and preserved as a consequence, see:-
http://www.english-heritage.org.uk/upload/pdf/turning_plough.pdf?1267377944 "
The NPPF is clear that a draft local plan may be considered unsound if there has been no proper assessment of the significance of heritage assets in the area, including their settings,
6 NPPF paragraph 132
7 NPPF paragraph 170
3
and of the potential for finding new sites of archaeological or historic interest8, or, there has been no proper assessment to identify land where development would be inappropriate because of its historic significance.9
The Joint Green Belt Review recommends that to determine site suitability "finer grained, more detailed analysis" should be undertaken including the consideration of "Archaeological Constraints; Character, Setting; and Historic Landscape Character Analysis"10. This appears not to have been undertaken.
Site K5 south east Kenilworth
Previous correspondence highlighted the need to consider the evident significance of the adjacent Stoneleigh Abbey and designated Glasshouse Roman settlement, and the potential for further archaeology. Has this evidence been addressed?
Any future development would certainly need to protect the scheduled archaeology and its setting and that of the Grade II* registered Stoneleigh Abbey Park.
Coventry and Warwickshire Gateway - Baginton
The scale and form of any future development here is currently unclear. However it should be noted that the area includes designated and undesignated heritage assets of great importance. In accordance with the national policy expectations referred to above, a specific historic environment assessment must be undertaken to fully understand the landscape's special historic interest, the locations of particular historic significance and sensitivity. This can in turn inform the areas capacity, where development may best take place and what form
it might take.
Section 11. The Historic Environment
One of the twelve principal objectives for planning in the NPPF is the conservation of heritage assets for the quality of life they bring to this and future generations11.
Conservation means maintaining what is important about a place and improving it where this is desirable. This is not a passive exercise. Consequently we welcome the proactive approach you intend to take.
To compliment these measures might I suggest the Plan also address and target specific environmental improvements; the assets within the area on the heritage at risk register and the opportunity afforded by CIL/S106 agreements.
I note paragraph 5.1 of the LCR Report. "In addition and particularly as the towns are important tourist destinations, the quality of approaches to the town should be considered in all development planning. A combination of protection of landscape assets and enhancement or removal of landscape detractors should be considered in strategic planning".
Might the enhancement of the public realm be linked to creating an attractive environment for businesses and visitors? I refer to paragraph 14.18. How will the Local Plan compliment and help deliver the Warwickshire LTPs intention to "improve the quality of transport integration into streetscapes and the urban environment"?
Are there specific opportunities to demonstrate how CIL/S106 agreements could contribute towards the enhancement of individual assets or specific historic places, particular streets, spaces and the public realm?
8 NPPF paragraph 169
9 NPPF paragraph 157, seventh bullet-point.
10 Joint Green Belt Review paragraph 5.4.2/3
11 NPPF paragraph 17
4
Might the Plan address the particular issues identified during the development of the evidence base, including the ten monuments, four buildings and two parks on the national heritage at risk register?
Section 15 -Green Infrastructure appears to provide the 'bench mark' for a thorough and proactive strategy. I would be welcome the opportunity to help support a further refinement of Section 11 to achieve a similar comprehensive iteration.

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

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

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

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

2:2 - Why is the environment not listed as a key priority: without it, all manner of planning applications can be granted which are anti-environmental

Is leisure included in "Health and Wellbeing". If so, this should be made clear.

2:5 - As there is no way the economy can be predicted, there should be a commitment to responding to new opportunities and needs which arise

Can the areas mentioned as requiring regeneration be identified?

I am concerned about the second bullet point under Emphasis on infrastructure, as most areas of the countryside and of importance for wildlife need only a very light touch, if a touch at all. There should be a clear distinction between the approach to parks and managed open spaces, and to wilder areas (e.g. Welch's Meadow would be ruined by heavy handed management).

3:7 - there are elements referred to in this draft plan which need to be prioritised and policy made before March/April 2012; in particular a policy on the concentration of HMOs.

4:6 - the protection afforded to conservation areas should be strengthened, particularly as these cover apparently only 4% of the district

4:8, point 2 - It should be noted that one major contributory factor to the current lack of affordable properties relates to HMOs. The house next door to mine is an example of this. It was owned by an elderly lady who went into residential care. There was a large amount of interest in the property from people who wanted it as a family home, indeed so much interest that it was decided on sealed bids. Because the property needed some updating, and I met several potential purchasers who wanted to restore it to its former self, the highest bidder was, almost inevitably, a landlord who could easily find the finance and would easily recoup the investment by turning it into an HMO. I have seen this repeated time and again in my area of south Leamington where the gains from HMOs has pushed up prices beyond affordable for an individual or family: indeed a local couple I know has not been able to find an affordable small period house and, despite wanting to stay in Leamington, is having to move to Cheltenham to find such a property. In addition to the price problem, most often the conversion to HMO is the cheapest possible and degrades the period property.

4:10.2 - It is right to accommodate university students, but not at the expense of other "settled" residents. South Leamington is at a tipping point where the area could be completely dominated by students The advantages of a large student population tend to benefit the few - landlords and places selling cheap food and drink, whilst the cost and disadvantages are picked up by Council tax payers and local neighbours. It also means that businesses not directed at students tend to stay away. One south town resident recently pointed out that because Leamington is only a student dormitory town rather than a university town, we have generally ended up with all of the problems of a large student population and none of the advantages of the university culture which takes place on campus. I can see no reason why special consideration should be afforded to the University of Warwick in providing accommodation for its students.

4:11 - I agree with all these points, particularly endorsing numbers 7, 9 and 10. It is particularly important in any development not to let the developer be the tail which wags the dog, as the developer will inevitably want to take the easiest and cheapest route in contradiction to the area's best interests.

5-7 - Level of growth:
As forecasting population growth is a very inexact science, the Council should constantly monitor what is actually happening. If the expected population growth is not materialising, planned development should be scaled back accordingly. It makes sense therefore to insist on development of the brownfield sites before eating into Green Belt.

P04:D - Loss of green space should also be taken into account when assessing development of garden land. This space may not be directly accessible to the general public, but if it contributes to the overall feeling of green space which is enjoyed by the general public (e.g. with trees that can be seen from neighbouring streets), it is very important that it is maintained. It is also important for biodiversity and the environment, as gardens are now understood to be extremely important habitats for wildlife.

P06.D - It is most important to identify the locational criteria and to carry out a thorough survey of all HMOs and their residents, not just those which have previously had to get Council approval.

7.59 - We need this policy now!

P08 - We also need a firm policy now regarding the protection of existing employment buildings from change of use, as in my area I can think of several schemes either applyng for or already granted planning permission to change from commercial to residential use. The Plan already points out that f the area population is going to increase, then employment will need to increase as well and it is short-sighted to be allowing commercial property to disappear.

8:21 - Does the projection of additional job requirement take into account that the growth in the older population will automatically mean the release of the jobs these people were doing?

9: Retailing

It is a mistake to be led by the retail "experts" who push for constant retail development schemes in order to compete with neighbouring towns. There is a fine balance between having enough "High Street names" to serve shoppers and having so many that Leamington becomes indistinguishable from any other shopping centre - in which case, why would any non-residents want to come here? The success of the last major retail development - which seems dubious to me - (Parade to Regent Street) should be assessed before rushing into another similar development. Outside shoppers will travel to a shopping centre to find something different and it is this difference which needs to be identified and promoted. These major developments also seem to push up rents for retailers.

13: Inclusive, Safe and Healthy Communities

Developments should not be permitted which will downgrade and produce associated problems to an area, e.g. SEVs.

14: Transport

I suggest WDC promote a car sharing scheme.

P014: How can you plan a retail development in Chandos Street whilst aiming to maintain sufficient parking in town centres. Chandos Street is a much more popular car park than the multi-storeys.

15: Green Infrastructure

A relevant issue is that Network Rail is destroying, and has been for a long time, the natural environment and wildlife habitat along railway lines by felling all the trees and killing undergrowth every year with weed killer.

15:14 - Yes to urban tree planting; concern about messing with the River Leam borders unless already in a well-used managed area.

P017 - I agree with the continued support for the development of a cultural quarter

I believe that existing visitor accommodation should be protected from change of use.

18: Flooding

Planning permission should be sought by someone wanting to pave/concrete over a front garden, as I believe this trend has contributed to flooding problems.

Summary of major concerns

* Restrictions needed on HMOs
* Light-handed touch needed on non-parkland open spaces and riverside
* More creative study of retail demands and opportunities needed
* Although the Plan does seem to recognise this, the expansion of the district must avoid segregating areas into a single use, e.g. residential, employment, etc. Areas are much more interesting and attractive if they include a mix of residential, employment, cultural/leisure, etc. properties.

We wanted to provide some general feedback on the plethora of information available related to the New Local Plan Preferred Options Consultation. Having attended two meetings in Hampton Magna we are aware of some of the issues that residents are concerned about. We will aim to outline the main issues below and also include our own personal thoughts. However, these are not exhaustive and we should strongly encourage you to speak to your representatives, who attended all of your meetings, to get their feedback on issues that were raised.

Evidence base
We are extremely concerned that the available documents are not fully engaged in "evidence-based" consultation. Specifically, it is our concern that there are limitations in the methodology being used to develop this Local Plan Preferred Options Consultation. This is an important foundation to any research, report and future recommendations. The consultation documents lack transparency in terms of the employed methodology. For example, we strongly encourage you to document how you plan to utilise the information gathered at meetings across the district. This is a valuable opportunity to gather qualitative evidence on people's acceptability, satisfaction and attitudes towards the plans. There has been a lot of frustration voiced at meetings related to the apparent failure to consider, appreciate, and operationalize people's views. There is a need to inform people how their views are going to be considered and synthesised to inform your decisions. For example, large scale questionnaires have been undertaken with residents by local parishes (Hatton Park and Hampton Magna) which provide valuable information. People need to feel listened too. It is important you allow people to voice their opinions and acknowledge how they will be considered. You need to empower people. Your research will then be richer and more representative.

We are extremely concerned about the generalizability of your research to date. We strongly encourage you to work more closely with academic departments like Warwick Business School, Warwick Medical School and the Economics department at the University of Warwick. There are clear weaknesses in the rigour and robustness of your methodological approach and evidence base which need to be considered again. Collaborating with an academic department will help overcome some of these problems. They will help with economic modelling, operational research and mixed methodological approaches. How you synthesise the data you collect is crucial. If you have lots of meetings and don't report the views at these meetings then your data gathering is confounded. You may want to host smaller focus groups in different areas, recording information, and thematically analysing the common issues. This is rich qualitative evidence which appears not to have been considered.

Housing in smaller villages:
From a personal point of view we need to express our disapproval over expanding housing in smaller villages like Hampton Magna, Hatton Park and Shrewley. There is considerable worry and upset among residents who live in these areas about potential increased housing on these sites. This would significantly impact on their quality of life. These small communities are already overburden by through traffic and schools are at capacity. Please work closely with parishes and residents before considering any expansion in these areas. They have a good insight into the wealth of issues that you would need to factor into your financial plans to enable these smaller developments to take place.

If some growth does go ahead, the standard of this housing needs to be inkeeping with the housing already in place in these areas. Residents are extremely concerned about the impact this will have on the prices of their existing properties.

Schools and early year care:
More housing does seem to take president in the new consultation. There needs to be greater focus on how schools will be expanded. For example, as you are aware, Budbrooke Primary is at capacity and it takes children from Chase Meadow & Hatton Park. The Ferncumbe Primary School at Hatton is over capacity. How much expansion is needed? Please provide projected statistics of how much expansion will be required in the local schools to accommodate the foreseen housing growth.

Early-year care needs careful consideration at an affordable price. Already many nurseries are at capacity or in considerable demand. The costs are also unmanageable for many parents wanting to return to work after maternity leave.

Respecting our green spaces and green belts:
These need to be respected and the natural habitats for our wildlife maintained. Housing on green belts has resulted in considerable frustration and objection at meetings we have attended, in particular that around smaller villages. Consult with residents please. Muntjac deers, bats, birds of prey reside just outside my property and we are sure that we are not the only people to be fortunate to have this natural beauty around them. Protecting our natural flora and fauna is important.

Transport:
Expanding our road networks is going to be important to deal with the increasing cars on our roads. We also need to consider the impact this will have on noise and air pollution for residents already residing in places of growth. How will this impact on their quality of life? Consult with residents please.

Public Transport:
There needs to better public transport in areas of expansion. More regular bus services, in particular, to train stations and Universities are needed.

Parking:
More affordable parking in town centres and at train stations are urgently needed,

Drainage:
We are extremely concerned about how the current drainage system will cope with expansion. The costs this could involve should not be overlooked. For example, only a small expansion in villages could cause considerable problems (e.g. Hatton Park). Caution is needed and careful mapping of the current foundations is essential.

Employment:
Greater housing expansion requires more employment. Expansion in the health, retail and educational sector presents good opportunities.

Emergency services:
An increase in the population of the District will lead to an increased need for community policing and an increase in the number of local "incidents" to which the policing service will be required to respond. We need to make sure residents are protected from crime.

Healthcare:
Ensuring that GP surgeries and hospitals can cope with the housing expansion will be of upmost importance. GP surgeries are already struggling to cope.

With the exception of the smaller housing growth in the villages highlighted and the issues raised related to evidence base and research methodology, we feel the proposed plans are worthy of further consideration and community engagement.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Extra care housing and use class C2 and C3

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Heritage and Culture matters

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Rural accommodation

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Extra care housing and use class C2 and C3

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Heritage and Culture matters

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Rural accommodation

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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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6 Hampton Street, Warwick, CV34 6HS
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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6 Hampton Street, Warwick, CV34 6HS
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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6 Hampton Street, Warwick, CV34 6HS
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.

Thank you for your email of 1st June 2012 re the above subject. The Councillors of Baginton Parish Council
have considered the Preferred Options documentation. We have also attended the WRECF meeting of
28.6.12 and the WDC Proposed Development Forum of 2.7.12. We have debated these issues at various
meetings. We have also attended the Gateway Developers presentation at Baginton Village Hall of 19.6.12
where we gained written feedback from many concerned residents.
This letter sets out our opposition to the Gateway proposals, as presented to residents on 19.6.12, being
included in the Local Plan Preferred Options. It also puts forward our preferences regarding housing need for
the area based, on our current Parish Plan. Whilst the majority of the proposals are satisfactory, in our view,
we are alarmed and concerned by tentative proposals to include the "Gateway" in the proposals, as
illustrated in the Preferred Options documents. We write asking you to consider all our comments below
when making your judgement:-
1. BPC oppose Preferred Options 8.15, 8.18 and 8.42 abstracts of which are in Appendix 1 of this
letter. BPC opposes the inclusion of the Gateway shown in Map 3, an abstract of which is shown in
Appendix 2 of this letter. The Gateway proposals are not appropriate development and should not
be included, for reasons as set out below.
2. The NPPF calls for Protecting the Green Belt in section 9. See abstracts of section 9 in Appendix 3
of this letter. Baginton Parish borders with Coventry City. There is a vital need to prevent the
unrestricted sprawl of Coventry into Rural Warwickshire, safeguard the countryside from
encroachment and preserve the setting and special character of our village, with its Roman Fort,
Castle and Grade 1 listed church amongst other things. The gateway proposal is contrary to these
fundamental requirements of the NPPF. The development encroaches on previously undeveloped
Green Belt fields which provide a vital buffer between rural Warwickshire and Coventry City. It is
essential that this buffer remains. BPC believes that WDC have an ideal opportunity to prevent the
urban sprawl of urban Coventry into rural Warwickshire. WDC should not therefore support the
Gateway project, which must be removed from the Preferred Options and local plan. The
development is in the protected Green Belt with no very special circumstances to justify its
existence. The openness of this Green Belt land must be maintained.
3. The environmental effects of the Gateway proposal have not yet been considered and there are
many reasons why such a proposal is unsustainable development adversely affecting the
environment and contrary to the requirements of the NPPF. There is no need for such a
development, which should be omitted from the local plan.
4. The proposal significantly affects the nationally significant Highways Agency Tollbar improvement
scheme; the affects which need to be clearly annotated in the local plan.
5. The Gateway includes a "smart card" system for allowing Baginton residents access to Rowley
road, but with no details of how this would be run.
6. It is noted the large industrial units are envisaged to have 24/7 operations, yet the environmental
effects of 24/7 HGV operations on local rural and other communities has not been considered.
7. The proposals are unsustainable as they fail to comply with fundamental tests in the NPPF. The
proposals are to develop Green Belt land but with no very special circumstances to warrant such
development. It is both necessary and essential for WDC to consider all other developments with
extant planning permission in the wider area. There are many such developments in the locality and
which are suited to developments of this nature, e.g. (but not limited to) the huge sites at Ansty and
Ryton, both with infrastructure already in place. Preferred Options, section 8.42 (Section 8.33 of the
draft Local Plan) specially refers to the Coventry Gateway project, it specifically states 'To
demonstrate that there are not any other preferable and suitable sites'. The above clearly
shows that there are alternative sites available with extant planning permission within the subregion,
and further afield, which provide more than adequate development opportunity, so there is
no need for this development. It is essential that the Local plan includes a requirement to review all
existing developable land in the sub-region and further afield, to ensure the proposals are robust.
BPC demonstrates that there ARE other preferable and suitable sites, so the Gateway should be
excluded.
8. There is no need, either economic or otherwise, for the Gateway proposals to be included in the
local plan. There is no case for releasing land in the Green belt for the Gateway development.
9. The development to the north of the A45, in Coventry, can be developed without destroying the
Green Belt to the south of the A45, providing 4000 jobs for the benefit of the region. There is no
need for the Gateway development south of the A45.
10. The provision of "up to" 14000 jobs is inaccurate and misleading. Given that 4000 of the 14000 jobs
quoted are for development north of the A45, within boundary of Coventry, already with planning
permission granted to another developer (Whitley Business Park), it is wholly inaccurate for the
Local Plan to headline up to 14000 jobs. Of the remaining 10,000 jobs, it is highly likely that these
will not be newly created jobs, but in the main taking jobs form elsewhere in the sub region and
further afield. These jobs can and should be created using the vast acreage of sites in the sub
region, and nearby, which are already available, or have infrastructure already in place, or have
extant planning permission, or which are otherwise far more suitable to gain planning permission.
The local plan should quote a realistic level of job creation, within WDC only, accounting for all
other sites.
11. The closing of the Bubbenhall Road and Rowley Road to the general public will destroy the many
local rural businesses which thrive in Baginton Parish, e.g. Baginton Village Store, Hong Kong
House, Smiths Nurseries, Russell's Nurseries, Oak Farm, The Old Mill, The Oak Pub, British
Legion Club and many others. Each would be adversely affected and forced to close with the loss
of jobs, adversely affecting the local sustainable community, contrary to the NPPF. It is absolutely
essential that the Bubbenhall and Rowley Roads be maintained as a pubic right of way with the
present alignment between Baginton and Bubbenhall, to maintain the sustainability of local rural
businesses hence comply with a fundamental aspect of the NPPF.
12. BPC are also concerned that the provision of a new road west of the runway could be put into a
deep cutting which would pave the way for future runway expansion. It is absolutely essential that
the Bubbenhall Road be maintained as a pubic right of way with the present alignment between
Baginton and Bubbenhall, to prevent the Airport from runway expansion in the long term. See old
proposals from September 2002 in Appendix 4 of this letter. BPC acknowledges this is not part of
current proposals but BPC are most concerned that the proposed Bubbenhall Road alterations
could facilitate the opportunity to allow such development in the future. This must not be allowed to
be facilitated, by ensuring the Bubbenhall Road stays as it is and the proposed alterations shown
on the Preferred Options are omitted from the emerging Local Plan.
13. The documents presented do not adequately correlate the requirements of the NPPF with the
proposals for the Gateway. The proposals are not therefore robust in the view of BPC, so the
proposals should be omitted.
14. There is an excellent "Green Infrastructure" opportunity to maintain the undeveloped green belt
green fields which lie to the South of the A45 and which will be adversely affected by the Gateway
project. Instead of the Gateway WDC should give consideration to developing this area under the
Green infrastructure scheme. This will have the advantage of ensuring that the surrounding areas,
such as Baginton Parish, do not suffer from urban sprawl and maintain important opportunities for
Flora and Fauna to flourish. The planted buffer zone to the urban sprawl proposed for the Gateway
is insufficient compensation for the loss of the undeveloped green belt green fields which presently
act as a natural buffer between urban Coventry and rural Warwickshire. It is also far to close to the
Lunt Roman Fort. The Gateway should be omitted from the Local Plan.
15. BPC are very concerned that the Preferred Options summary leaflet makes no mention of the
Gateway development, only showing "highway improvements as per abstract from the summary in
Appendix 5 of this letter, which are as per Map 5 of the preferred options.... This is
misrepresentative of the developer's intentions. The public are not therefore being afforded the
opportunity to see the true extent of the proposals in the summary leaflet, so are not being afforded
the opportunity to comment. This must be rectified by modifying the summary document to include
the developer's true intentions. These are not highway improvements but will destroy public
highway rights of way which are essential for the prosperity of the many rural businesses which
thrive in this area and which will be destroyed by the Gateway development. These are not
improvements but will serve to develop a huge area of green belt land and create urban sprawl,
contrary to the principles in the NPPF. It is essential that these proposals be omitted from the
Local Plan
16. The 12.3.12 WDC map entitled "unrestricted natural and green corridor greater than 2Ha" doesn't
show the green space south of the A45 which forms a natural barrier between Coventry and
Warwickshire, and is undeveloped Greenfield Greenbelt land protecting Baginton from urban
sprawl. The map should be amended, the area recognised as such and the area not allowed to be
developed.
17. Councilors believe that the Gateway proposals, by a private developer who also owns the Airport
and who is also past and proposed Chairman of the Local Enterprise Partnership promoting the
development, are foisting an unwanted and unnecessary development on Baginton village which
will ruin this rural village community, destroy essential Green Belt and destroy its local amenities
and businesses. The quality of life of Baginton and Bubbenhall residents will be significantly
adversely affected by the Gateway proposals. The proposal is against resident's basic human rights
under the Human Rights Act, due to the traffic and operations noise from huge warehouse logistics
development which will run 24 hours per day, seven days per week, with especially adverse effects
at night and weekends. Cllrs anticipate significant HGV traffic movements all night which will be
particularly disturbing to residents.
18. The Gateway development in not sustainable compared with other nearby developments with
extant planning permission, which are sustainable.
19. The proposed smart card access system for local residents and businesses is impracticable and
unworkable, with no one willing to operate it, certainly not Baginton PC. It is understood alternatives
are under consideration but based on what BPC are aware of at this time these proposals are
damaging to the village and must not be allowed to proceed.
20. The proposals put into jeopardy the construction of the Highways Agency Tollbar Island proposals
due to commence early next year. The proposals will not facilitate major improvements to the road
network not already covered by the HA proposals, but will only add to the traffic in this area.. In
addition, the proposals will only add to the traffic in this area, so will not facilitate improvements
over and above what is already proposed by the HA, so the statement must be removed from Para
8.33 of the draft.
21. It is noted from the presentation on the Local Plan by WDC of 28.6.12, at Baginton Village Hall, that
there is 23 hectares of business development land proposed within WDC boundaries separate to
that of the Gateway. Noting that many commercial premises within the sub region, and slightly
further afield in Solihull, lie empty and unused at this time, the additional 23 hectares of business
development land is more than sufficient to satisfy the need for economic growth without the
Gateway project. There is no need for the Gateway project and this must be omitted from the
proposals
22. BPC believes it is entirely inappropriate for WDC to support the C&W Gateway proposals, which
are against the fundamental principles of the NPPF, adversely affects the environment, adversely
affects Parish residents human rights to peace and quiet, will destroy rural businesses based in
Warwickshire, will develop on high quality green field Green Belt with no very special
circumstances, will create urban sprawl and which will jeopardise industrial development elsewhere
in the local area which already has planning permission or has been previously developed and will
destroy the openness of the area, amongst other things. The Gateway should be removed from the
Local Plan
23. Councillors believe there is a clear conflict of interest between the LEP, which we understand is to
be once again chaired by the Owner of both development companies, Sir Peter Rigby, and the
broader requirements of the residents of WDC. BPC Cllrs reinforce the need for WDC to be
independent and not compromise its integrity through the forced will of a developer who is intent on
ruining our unspoiled corner of rural Warwickshire for financial gain. It is wrong therefore to refer to
the LEP within the Local Plan.
24. WDC should modify the proposals to state that its preferred option is to utilise to the maximum
capacity all sites in the sub region with extant planning permission prior to developing any further
site on Green Belt Land. WDC should review all existing developed land within the sub-region. It is
vital that WDC explores and justifies the case for releasing land within the Green Belt when existing
Brownfield and other sites with extant planning permission exist within the sub region remain underutilised
and unoccupied.
25. BPC observes that the Gateway proposals do not protect the character and scale of the village, nor
the openness of the rural countryside around the village, so should be omitted.
26. BPC has already gained written feedback from almost one hundred residents, all of whom believe
the Gateway proposal is damaging to Baginton and there is no justification for ruining the Green
Belt. All wish to see the Green Belt protected. It is essential that WDC takes account of the wishes
of all local residents and excludes this development from the local plan.
27. All the above demonstrates that the Gateway site, which is stated in 8.18 as being "identified as a
site of regional importance for employment to serve the regeneration needs of the Coventry and
Warwickshire sub region" is fundamentally incorrect, fundamentally unnecessary and fundamentally
against most requirements of the NPPF, so should be omitted from the local plan.
Regarding housing policy, Baginton has a Parish Plan and requests that the deliverables in this document be
accounted for by WDC in formulating the Local Plan. In particular please note the below comments:-
28. BPC supports modest sustainable increases to housing in accordance with our letter L075A to
WDC of 8.1.12, a copy of which is enclosed as Appendix 6. This is based on the output from the
Baginton Parish Plan. The Local Plan should include opportunity related to small scale sustainable
development of this nature, to retain the nature and character of the village and help to support the
many local rural businesses in the village. Please note in particular that in all cases any housing
shall be wholly in character with the village, be sympathetic to the amenity of existing
properties/people and shall not interfere with the Green Belt. BPC opposes the Gateway
development on the Green Belt to protect the rural nature of our village, to protect the openness of
the area and to protect the surrounding area from urban sprawl.
29. BPC objects to the classification of villages generally. The Local Plan must not dictate the type of
housing development to villages, but rather should take into account village desires under the
Localism act and in the case of Baginton, our Parish Plan. In this respect we again ask WDC to
account for our letter L075A as point Nr 28 above.
In conclusion, BPC consider that the proposed gateway is entirely inappropriate and ill considered
unsustainable development, contrary to fundamental requirements of the NPPF, with no need given the
significant size and number of underutilised employment creating developments which already exist with full
planning permission in the Coventry and Warwickshire sub region area and further afield. There are no very
special circumstances to develop on the Green Belt, rural businesses need to be protected, urban sprawl
must be prevented and the openness of this Green Belt land must be maintained.
BPC oppose all Gateway development south of the A45 and recommend that the Gateway be omitted from
the Preferred Options and excluded from the Local Plan, with any development limited only to that shown to
the north of the A45, which is within the boundary of Coventry City Council, utilising Ansty, Ryton and other
existing suitable sites for any economic development over and above the 23 hectares already allowed for
within the Preferred Options and emerging Local Plan. Housing policy should follow our recommendations in
Appendix 6 herein.
Please confirm you will consider all the above and confirm you will omit all aspects of the damaging and
unsustainable Gateway development from the emerging Local Plan, within the boundary of WDC.

See attached

As scanned.

Attached letter