PO3: Broad Location of Growth

In general I support the theory of spreading the location of growth across the District, but am not sure if this will happen in practice.

Baddesley Clinton Parish Council have considered the Preferred Option for PO3, set out in the Preferred Options booklet and agree and support the preferred option for the Broad Location of future growth within the district.

firstly, although these proposals plan to build on the edge of towns they are in fact also building on green belt in the Blackdown and Old Milverton areas. A factor which should negate the building on the edge of areas. Secondly it will allow areas to 'coallesce' as there is no natural boudary to these developments.
Why build on green belt when there are areas to the south of the city which do not fall in green belt areas?

43% outside of the green belt does not reflect a desire to 'focus development outside of the green belt'

there is a need to demonstrate exceptional circumstances to build on the green belt - this has not been demonstrated in north leamington

More focus should be placed on finding brown field sites & increasing the numbers of houses on existing new estates eg Chase Meadow, Hatton Park & Warwick Gates and increasing facilities eg providing schools rather than significantly increasing the size of the districts historic villages.

The distribution of new housing across the district is positive but some villages have been excluded from housing allocation. All communities require a small amount of housing allocation to ensure they are sustainable otherwise the population gradually ages, with limited options for young persons to stay living in the community they have grown up in.

The dispersal of proposed new housing across the district does not make sufficient regard for the proposed employment site near Coventry. With a the majority of new housing located to the south of Leamington and Warwick this will lead to additional pressure on the already overloaded town centre infrastructure

The principle of the majority of growth on the edge of existing conurbations makes sense as the infrastructure services are generally already there

Productive farmland should not be used for housing. This country will need every availble hectare of farmland to produce food for a growing population. We cannot depend on imports.

The level of groath proposed in the villages would change the character of them in a totaly unnacceptable way. This goes compleatly against the aim of protecting /encouraging"rurality"

other options such as the use of part of the RASC site where transport could be provided from the A46 could provide a new village option

This is a more complex area but the key factors to be considered relate partly to the above points concerning the inadequacies of the SAF i.e. how can we confident about the overall strategy if the link between individual choice of sites and the overall approach is not transparent? Consequently an objection is made to Policy P03: Broad Locations for Growth and the justification for this set out in paragraphs 7.8 to 7.22.

It is noted that paragraph 7.8 does not refer to the SAF. Does this mean that the individual sites have been tested within a Strategic Environmental Assessment that has informed their selection?

It is also noted that paragraph 7.8 does not make reference to the Landscape Character Assessment (LCA) for land south of Warwick and Leamington (February 2009) commissioned by WDC and prepared by Richard Morrish Associates Ltd. This report is referred to as being part of the Council's evidence base for the consideration of Landscape and Green Belt matters in Local Plan on the Council's website. It is included alongside the 2009 Green Belt Review.
The background section to the LCA states:
1.1 ........... The (Green Belt) study sought to identify land that contributed the least towards the Green Belt and was the least constrained in environmental and physical terms. The data gathered will inform each Council's emerging Core Strategy. Richard Morrish Associates Ltd (Chartered Landscape Architects, and a registered practice of the Landscape Institute) worked with Smith Stuart Reynolds to provide a preliminary landscape assessment of the study areas and to provide an evaluation of the extent to which they contributed towards the planning purposes of Green Belt as set out in PPG2 1.2 The West Midlands Green Belt only extends to areas located north and west of Warwick and Leamington and therefore land south of Warwick and Leamington was not considered in the joint authority Green Belt study.1.3 In December 2008 Richard Morrish Associates (RMA), were appointed to provide a preliminary landscape assessment of land to the south of Warwick and Leamington Spa. The objective was to assess the contribution that these study areas presently make to the existing urban structure of Warwick and Leamington and to evaluate which areas might be considered most important in preserving the character and appearance of the towns in the longer term.


It should be the case therefore that the choice of development locations in Warwick and Leamington has been influenced by the Joint Green Belt Study (January 2009) and the LCA for the Area south of Warwick and Leamington (February 2009), in addition to the other matters set out in paragraphs 7.8 and 7.24. If this is the case specific reference to the LCA should be included within paragraphs 7.8 and 7.24. It is noted that the sole reference to the LCA is at paragraph 10.18 in the context of built environment. If the LCA, has not been utilised for the purposes of identifying preferred locations for development - and hence has been purposefully excluded from paragraphs 7.8 and 7.24 of the Local Plan, then the Council should clarify this, and if necessary correct this oversight.

In terms of specific points in respect of P03: Broad Locations for Growth:

* Objection is made to paragraphs 7.8 to 7.22 for the reason outlined above. * Objection is made to the proposed phasing provision identified in paragraph 7.20. There is no evidence provided by the Council to justify a phasing policy. Indeed, on the one hand the Council express concerns about the ability of strategic sites to deliver with the plan period (paragraph 5.23) and then propose in paragraph 7.20 a phasing policy that is likely to artificially constrain strategic sites from being brought forward in a timely manner. Strategic sites require a significant lead-in time. Major infrastructure works are required involving substantial up-front costs to create developable plots. Schools, community centre, district centre facilities etc may also need to be built at an early stage of the development process. It is not appropriate to impose an arbitrary phasing restriction on their delivery which may simply serve to undermine the viability of a development. Reference to phasing should be deleted from the Local Plan.

* Objection is made to paragraph 7.15. It is considered that the Green Belt Study 2009, by itself, does not provide a sufficiently robust evidence base to demonstrate the very special circumstances that justify the scale of land proposed to be released from the Green Belt to the north of Warwick and Leamington. This objection is related in part to the lack of reference to the LCA in the draft Local Plan assessment of the broad locations for growth in Warwick and Leamington.

Assuming that it is necessary to provide the number of dwellings stated in the plan, we srongly support the policy of distributing them throughout the area. Few existing residents welcome growth of this sort and there is normally some penalty in terms of living standards. However, failure to provide for the increased demand will lead to acute problems for those who cannot find acceptable accomodation and we all therefore have to accept some changes to our lifestyle to accomodate the necessary expansion. However it is important that the pain is shared fairly amongst existing inhabitants and not concentrated on an unfortunate few. It would appear that the Plan recognises this and for that reason has our full support.

The Leamington Society is particularly concerned about the threat of coalescence and in particular the narrowing of the gap between Kenilworth and Leamington and between Warwick Gates and Bishops Tachbrook.

CRA is broadly supportive of development that is concentrated within and on the edge of existing urban areas.

Support dispersal of housing NEEDED by the locality, first by using much more brownfield than currently in the plan, then by small amounts over a larger number of settlements. Also support the avoidance of coalescence of settlements. BUT GET LEVEL of growth right first. 10,800 not needed only 5,336 is. The intrusions into greenbelt and rural areas is unnecessary.

I support the aim to distribute growth across a wider area of the district. In particular the need to prevent existing settlements merging.

Some growth on the edge of towns is necessary but agree that settlements should not merge

SUPPORT - but recommended re-wording of the policy.


The Europa Way Consortium and Warwickshire County Council (Physical Assets-Resources) support the District Council's decision to concentrate growth within, and on the edge of, the existing urban areas. However, in order to avoid any unnecessary confusion surrounding the spatial strategy we believe Policy PO3 (Broad Location of Growth) would benefit from some re-wording. Re-wording is considered necessary for the Council's 'Preferred Option' cannot be to both "concentrate growth" in one area and, at the same time, "distribute growth across the District"; that is unless at least one of these two statements is qualified.
We recommend that Policy PO3 is re-worded and re-ordered to read:
It is the Council's Preferred Option to:
* concentrate growth within, and on the edge of, existing urban areas
* allow for some limited growth across the rural area of the District, based on a hierarchy to include:
- a higher level of growth within and/or on the edge of named Category 1 and 2 villages i.e. those villages with a broad range of services and public transport to the town; and
- a lower level of growth in on brownfield land within named Category 3 villages in order to meet local need and help support existing services
* avoid development in locations which could potentially lead to the coalescence of the urban area with nearby settlements.

In response to consultation on different spatial options during preparation of the Core Strategy (no equivalent undertaken as part of the new Local Plan) respondents favoured concentrating development within and/or on the edge of the main urban areas within the District. A spatial strategy based on urban concentration also performed best under the sustainable appraisal. For this reason we consider that references to a decision that the Local Plan should "distribute development across the District" (para 7.13) should be suitably qualified.

In principle this seems a sensible suggestion, although my only concern about this proposal is the possible de-valuing of properties currently on the skirten of the countryside, many of whom would have paid premium prices for "countryside views" and surrounding areas. If these become views of housing estates opposite, is this not likely to firstly de-value their properties, and secondly force people to move and re-locate?

COMMENT

King Henry VIII Endowed Trust generally supports the District Council's decision to plan for a hierarchy of growth in the rural area however we believe that Policy PO3 would benefit from some re-wording, particularly to be clear regarding the scale of growth which will be appropriate for the Category 1, 2 and 3 villages defined in Policy PO4.

We therefore recommend that Policy PO3 is reworded to read:
It is the Council's Preferred Option to....
* allow for growth across the rural area of the District, based on a hierarchy include:
- a higher level of growth within and/or on the edge of named Category 1 and 2 villages i.e. those villages with a broad range of services and public transport to the towns, and
- a lower level of growth on brownfield land within named Category 3 villages in order to meet local need and help support existing services.

This re-wording will help to link policies PO3 and PO4.

Electronic attachment

I am e-mailing to object totally to the building on the Green belt land
in the proposed new plan.

better use of of existing brown field land for housing instead out of more out of town supermarkets.

More apartments in the style of the town architecture and not blanket modern housing
changing the style of this lovely spa town.

I am writing to object most strongly to your proposal to build on green belt land in North Leamington.
I understand the need for more housing to be built but the need to protect our natural green countryside as much as possible should be the highest priority when establishing where the homes should be.
I have heard people say the council want to 'spread the pain'of the impact of the building but when the infrastructure for this new housing already exists in South leamington and also there is non green belt land which could be used in the South of leamington it seems ridiculous to use green belt land in North Leamington Spa.

I have never objected to anything or taken a great deal of notice of council goings on as I hope the elected officials would do the best for the communities but I feel very strongly about this issue and would like to register it with you.

I would like to object to the proposed development on green belt lane. One of the beautiful aspects of this town is it's open surroundings on all sides. This will be ruined if development takes place around this attractive area rather than where there are spaces within it. I strongly object to the planning being proposed. Whilst I realise and accept a shortage of affordable housing the travelling must also be affordable. Please do not spoil our lovely town as no one benefits from a ruinous plan.

The reason for my inquiry is related to the traffic modelling (re.
> Strategic Traffic Assessment - Modelling Results in your plan). I
> noted that the input to the analysis (figures applied to all housing
> sites) was based on the housing distribution of the Cape Road
> development in Warwick. I'm concerned that the mix of housing types
> for this development does not reflect what would be found in
> out-of-town developments, specifically those at Gallows Hill. A quick
> calculation based on the figures given on page 7 of the report gives
> an average per-household trip rate of 0.39 (for both AMPeakHour &
> PMPeakHour) - based on the housing distribution of the Cape Road
> development. However, for the proposed housing distribution for
> Gallows Hill, based on your figure - and I'm assuming all housing and
> no apartments (you didn't mention any) - then the average
> per-household AMPeakHour trip rate rises to 0.69, and the PMPeakHour
> rate to 0.79. These figures are an increase of 62% and 100%
> respectively over the figures used for the modelling exercise. When
> you take into account that this discrepancy applies to the largest
> development in the area, which connects to roads that are already at a
> standstill at peak times, it questions the validity of the whole
> modelling exercise and I would say renders it meaningless. I'd like to
> hear what your view of this is.
>
> One thing I've not found in the whole traffic strategy is any sort of
> limit to the traffic on a road. The traffic modelling exercise seeks
> to minimise traffic queuing but places no limit on it. I see queue
> lengths of 50 to almost 100 in the modelling results, but what does
> this mean? There must be a point where the amount of traffic becomes
> unacceptable in terms of delay, quality of life etc, such that it
> would be irresponsible to put plans in place knowing that this limit
> would be exceeded. Can you tell me if such a limit exists, or is it
> assumed that new developments can generate new traffic in an
> unconstrained way?
>
> I appreciate that traffic is the responsibility of the County Council;
> however, you base your plans on their input so my points are relevant
> to this process.


You say that the difference between the figures used in the model and
those that should have been used according to the housing distribution
for Gallows Hill "is not as significant as you suggest". I'm
interested in why you think my figures are inaccurate, so let me
elaborate.

As I stated previously, my calculations are based on the values
published on page 7 of the report. The average peak hour trip rate per
dwelling will be (IN + OUT rate) x % population of that housing type,
summed across each housing type present. So for Private Housing the AM
figure will be (0.19 + 0.50) x 0.16, for Private Apartments this will
be (0.02 + 0.29) x 0.54 and so on. Thus the average AMPeakHour trip
rate used in the model is (0.19+0.50)x0.16 + (0.02+0.29)x0.54 +
(0.18+0.37)x0.15 + (0.08+0.12)x0.15, which gives a result of 0.39.
Similarly the PMPeakHour trip rate is (0.57+0.27)x0.16 +
(0.17+0.05)x0.54 + (0.40+0.32)x0.15 + (0.14+0.08)x0.15 is also 0.39.

Using a distribution of Private Housing 60%, Private Aparts. 0%,
Social Housing 40%, Social Aparts. 0%, the AMPeakHour trip rate is
(0.19+0.50)x0.6 + (0.02+0.29)x0 + (0.18+0.37)x0.4 + (0.08+0.12)x0
which gives 0.64, while the PMPeakHour trip rate is (0.57+0.27)x0.6 +
(0.17+0.05)x0 + (0.40+0.32)x0.4 + (0.14+0.08)x0 which gives 0.79.

0.64 compared with 0.39 is an increase of 64%
0.79 compared with 0.39 is an increase of 102%

Perhaps you can explain what you find wrong with these calculations.
I'm also very confused over the figures you say the County Council use
in their assumptions - these are different from those in the model.
Why on earth would the model commissioned by the County Council not be
using the Council's figures?

Even if we assume that the discrepancy between the figures that were
used in the modelling were closer to yours than mine, the complexity
of the model (which is modelling an already overloaded network) is
likely to be such that you just cannot predict the consequences. Only
remodelling could show this. The Gallows Hill site is the largest in
the area, so even a small change in traffic rates is likely to have a
dominant effect on traffic. I don't think this can be so easily
dismissed.

I'm also concerned that I see no estimation of accuracy in this
modelling. As someone who started life as a scientist and then spent a
lifetime in software development, I've often tried to persuade
colleagues, particularly management, to be cautious of output of
computer calculations. At University, experimental results would be
discarded by tutors if you were not able to provide accuracy
calculations. Business computing never seems to apply this discipline,
input and output accuracy is often unquantifiable but still there is a
wish to treat the results with an accuracy that is unwarranted.
Beautifully crafted computer output can be very compelling. We used to
say GIGO - Garbage In, Garbage Out, and all the sophistication of a
complex model doesn't change the fundamentals of this; the output may
be highly crafted, fantastically accurately calculated, but still
ultimately of little value.

I also don't really understand your point where you say "Despite the
trip rate difference, we are of the view that the study is still valid
as a number of other factors will balance against the difference".
Surely the factors that balance against the difference are
independent, and have nothing to do with the validity of the study.
These other factors do not make the study valid. Additionally, while
the factors made be true, you have no idea what they are balancing
against if the model is invalid. The actual weight of traffic may
completely swamp these mitigating factors, rendering them ineffective.

Lastly, as to traffic congestion, I agree this is subjective. I still
think it would be helpful - to you guys at least - to have some
threshold to be able to judge against. Something for the future
perhaps.

My thoughts are: -

Let's assume that central government want you to produce a plan, and your proposed number of houses are to be built in the area: -

1. We don't have the transport infrastructure to cope and the 'improvements' you suggest will be insufficient. We have the Rivers Avon and Leam moving east-west through the district with inadequate crossing points. Building off the Banbury Road Warwick will require more vehicles to cross the current and old bridge in the town centre. This would need replacing at6 great costs and inconvenience before any building can take place. The idea that each new development will have its own industry seems wonderful but in the real world people don't and can't move when they change jobs or can't afford to buy houses where they work. Some commute into Birmingham or to London but are unable to get to Warwick station by public transport so are forced to drive to Warwick Parkway where more land is to be lost to a tarmac car park. THE TRANSPORT STRUCTURE CANNOT COPE NOW. DO SOMETHING BEFORE THE BUILDING STARTS!

2. Building the housing estates that we have seen in UK over the last 50 years, invariably creates ghettos of soul-less and character-less housing in the same style. Such developments can be seen throughout the country where you, the planners, have failed to lead. Warwick should lead by allowing private individuals to buy plots of land and build their own houses within planning guidelines. This way we will not suffer from the uniformity of style that we face wherever we go. Look around the district to see what's considered good and what's considered bad - Kenilworth has lost its identity long ago by developments of similar properties that have no connection with the old. The High Street once the centre of the town is now dead! A good street is Northumberland Road with individual houses on a wide tree-lined road. SMALLER INTEGRATED BUILDING BY INDIVIDUALS OR SMALLER DEVELOPERS. CREATE SOMETHING THAT IS GOING TO BE PART OF WARWICK AND NOT AN UNSIGHTLY GHETTO THAT HAS NO CONNECTION WITH THE TOWN.

3. Warwick will get the bulk of the houses. The county town does not have a fire station, a police station, or a decent library. Planners have destroyed much of it over the years by taking part of Priory Park for WCC car parking. You now talk of Park & Ride schemes when these should have been set up years ago for WCC staff. PRESERVE WARWICK AND NOT LET IT GET TOTALLY LOST AS A SUBURB OF LEAMINGTON.

4. And i haven't mentioned the risk of flooding caused by more hard surfaces giving instant run off. Currently drains overflow as they have not been maintained. Nor mentioned the state of the roads - will increased road surfaces mean even worse maintenance and pot holes. Will WDC & WCC staff not report them and the road signs covered in moss that they MUST see as they drive to their free car parks when you require the public to pay.

General: The term "preferred options" implies that the decisions have already been made, and that there is little, if any chance of them being changed. This underlines the FACTS that the results of the previous "consultation" have been ignored, so leaving residents with the impression that this consultation will also have no effect.
PO1: 52% of the respondents to the previous consultation opted for the lower number of new houses to be built, on the grounds that this would meet the requirements of current residents and their families. It would not attract further influx of people seeking employment not available in the District, employment which they would only find outside it, further increasing the already unacceptable traffic problems. The Council decided to ignore this view and propose a much larger (100% larger) number of houses. We can only conclude that the Council is bowing to instructions /bribes from Westminster to allow more houses to be built by private developers, since there is no indication anywhere that the Council itself intends to carry out any of this housing growth.
PO2: The infrastructure levy is an essential feature of any increase in the number of houses built in the District. However, it must be levied and spent BEFORE the new housing is occupied. We have already experienced the problems which delaying this expenditure has created in Warwick.
PO3/PO4: There is clearly a preference for a high proportion (almost 50%) of the development to be located in Warwick. There seems very little proposed for the villages. Half the proposed housing development is on the south side of the district. Given that the bulk of the new employment opportunities will not be in the small area of the District, but in the larger employment proposals for Coventry, commuting through the towns will increase, not decrease.
PO5: The balance of the types of new housing should be very carefully scrutinised: too much of recent development has been of small properties and retirement flats, only suitable for short-term occupation by first-time buyers. More of the new housing must be for family use. The proposal that 40% of new housing should be "affordable" is essential, and must be maintained against developers' pressure for its reduction. A better definition of "affordable" is also required
PO6/PO7: Statements of the blindingly obvious.
PO8: The designated employment land must be maintained against the pressure which will be put on the Council by developers. We have already experienced in Tournament Fields the result of this pressure proving effective. There is no indication in the Plan of what percentage of the land will be designated as employment land.
PO9: We note that there will be "support for new retail investment on Leamington Town Centre". Why only Leamington? The other towns are equally deserving of support, though there is no indication that this proposal has any financial backing.
PO10: Forget the concept of "garden towns/suburbs". These were built in an era of weaker planning regulations and allowed a much larger area of land to be taken into use for housing. In the current climate, such land use is not acceptable to the general population. Planning law is about to be relaxed, and the Council must be vigilant in maintaining the quality of development.
PO11: This is a very weak section, "offering help and advice" is not very positive: more concrete proposals, including financial commitment is needed. This is repeated in PO17 where "support" and "seek contributions" are the key words.
PO14 (and un-numbered section following): The road improvements proposed would be of marginal value. The "improvements" to Europa Way and the junctions would be very expensive, and could use up a substantial proportion of the available infrastructure levy, to the detriment of more useful projects, such a schools, health centres and open areas.

I appreciate that new housing is required to meet the national and local requirements, but I must object to the proposed plans.
Greenbelt land is greenbelt land for a reason, and to build on greenbelt land when none greenbelt land is available for development makes a mockery of the greenbelt rules.
Please register my objections.