PO3: Broad Location of Growth

I am writing this letter to outline my thoughts with respect to the considered future development within Warwick District. I have read quite a bit of literature around the proposal, especially the Preferred Options Summary and the Preferred Options Executive Summary published by Warwick District Council in May 2012.

I accept the natural evolution of society and more pertinently my town, what I cannot reconcile myself to is what it is at the expense of and this is what I wish to outline in my letter to ensure the rich heritage and natural beauty of Leamington and its surrounding town's is preserved for future generations otherwise the proposed adjustments to the Green Belt zone becomes a slippery slope that will ultimately only end when all the land has gone.

Within the Executive Summary document it is noted that there is a requirement for 10,800 dwellings to be built by 2029. The document outlines it arguments stating the need to encroach upon the Green Belt because there is insufficient Brown Belt land for development. As the various sites and number of dwellings are stated there is reference to the new developments supporting housing, open spaces and employment opportunities.

Based upon the Council's projections there appears to be an over-provision of housing which appears to be out-of-kilter with other sources.

The Council's Executive Summary document suggests that 10,800 dwellings are required between 2011 - 2029 (600 houses per annum). However, the Office for National Statistics show that between 2011 - 2020 population growth is 0.81%; 2021 - 2030 population growth is 0.65%, so clearly over time the trend is for a slowing of population growth not rapid growth that the Council suggests. Over this 20 year period this is annual growth of 0.73%.

Applying the Council's figures that there was 12% increase in population in Kenilworth, Warwick, Whitnash and Leamington from 124,000 in 2000 to 138,800 and using the 0.73% annual growth rate, this would suggest that in 15 years time the population will have increased by 11% (or 16,000 residents). This works out to less than 1.5 persons per new build. Is this logical? This is also working on the premise that all of those 16,000 people are of an age whereby they can take out a mortgage to buy a property.

On the premise that not all of these people will be of such an age then using the Office of National Statistics figures, and taking the age range 15 - 59 years, 57.4% of the population would be old enough to buy a property. Therefore, of these 16,000 residents only 9,600 (using a 60% assumption) would be in a situation, due to their age, to buy a property. Suddenly, we have 0.9 persons per new build meaning that there is clearly an over-provision of houses in the Council's plans and forecasts!

Even accepting for natural population growth, the requirement for housing seems to be less than half of the proposed 10,800 properties as an assumption that most buildings will be multiple occupancy and not single occupancy. With this being the case then the new housing could be accommodated in non-Green Belt zones (that the Council has failed to recognise) without causing a shortage of housing and destroying the environment.

The growth assumptions used above are derived from national figures and are considerably more aggressive than the Office of National Statistics which forecast only 6% regional growth for the West Midlands by 2026.

Around Leamington and Warwick there is already a surplus of housing and this would increase this over-provision. Property is currently available at such places as:

1.Chase Meadow - only 50% of the Phase 1 housing has sold and this development has been in place for a few years
2.Portobello Riverside - another recent development which is far from occupied
3.new property is being developed opposite Leamington train station

With these developments currently remaining unoccupied why is there a requirement for further (excess) property at present? The current economic climate is not conducive to offering people certainty. These housing developments will not automatically lead to full employment or fully occupied housing; it will merely add to the increasingly empty premises to the detriment of the Green Belt.

The Council has previously identified areas to develop that were not detrimental to the Green Belt and these areas, should growth justify it, could cope with more realistic projections of what the District will look like in 20 years. This is a pragmatic solution as well because this identified land near Heathcote or Radford Semele is closer to the areas of employment such as Heathcote Industrial Estate, Tachbrook Park, Spa Park and Shires Retail Park. The infrastructure is already in place with the M40 and A46 very accessible. This would also facilitate further regeneration and gentrification of an ailing south Leamington.

A bigger picture view is that the issue is not the availability of housing in the District. It is only necessary to walk around to see the estate agent boards showing properties "To Let" and "For Sale". A search on the internet reveals available properties running in to hundreds. Occupying these would in some way go towards accommodating the population growth. The question is affordability insofar as people are not able to get mortgage applications approved. Building excess new housing is not going to circumvent the very real issues confronted today and get banks and building society's lending money which is one of the real issues. The reality is that people would rather have a job and job security, in one of the many unoccupied units, than have a property. One cannot happen without the other.

The current global recession impacts the District like it does everywhere else and a perspective needs to be taken and not viewed through rose-tinted glasses hoping things will improve. We are living in an economic environment which has been going on for over 4 years and showing no signs of abating. With several national and multinational industries located in the District we are as much at the mercy of market forces as anywhere - such as the Ford foundry. Therefore, is there really the confidence and demand for new houses? It does not appear so and therefore the Green Belt does not need to be developed to meet non-existent demand. Demand is further hampered by the cost of living as reflected in the creep in food and fuel prices. By developing Green Belt it removes the opportunities to utilise this arable land in the future to grow our own scarce resources, making us even more susceptible to the influence of global conditions because we will not have our own "bread basket".

There seems to be an obsession with building property, but why? To the local economy it may provide a short-term impetus with construction work but once the development is completed then what? Why are we not focussing on utilising what we have first? The Council should be taking a longer-term view and preserving what we have for the benefit of future generations. They are already going to be saddled with debts, at least they should be given some countryside to enjoy and escape to.

With several local and global factors suggesting the growth projections look unfounded and therefore the new housing could be accommodated in non-Green Belt zones without causing a shortage of housing and destroying the environment, the housing would be better located nearer to the employment opportunities such as Gallows Hill etc. It is a real fact that a large proportion of the employment opportunities are located in the south of Leamington (and Warwick). This would have several benefits as it would reduce commute times, have a smaller environmental impact because people could walk to work or take advantage of the established public transport links in that part of the District. This would sensibly utilise the good infrastructure that is already in place.

What the Council have also failed to demonstrate is how affordable housing is "retained as affordable housing in perpetuity". By the very nature of the society that we live in, market forces through supply and demand control the cost of goods, including housing. The Council is in no position to influence house prices, even of a local nature. Prices are determined by a multitude of factors not least what an individual is prepared to pay for a property.

The Council in its Summary document talks about protecting the historic environment, providing links to green areas and encouraging recycling. How does the development of the Green Belt protect the historic environment and beauty of the District when there is Brown Belt land available for these housing developments? If the Council wants to provide links to the green areas then as opposed to reducing the Green Belt, make them more accessible through the introduction of cycle networks not by building roads and houses. This is how the Council can maintain the qualities of the District that make it desirable, by keeping the natural features that currently make it what it is.

Hopefully this is not a paper exercise and the land has not already been sold to developers such as in the case of fields at the back of the new developments up in Sydenham near Asda whereby A.C.Lloyd already own land at the back of roads such as Withy Bank and that the reasoned arguments for preserving the Green Belt are listened to.

In short, Green Belt should not be developed (or certainly have wholesale development) in Leamington, or the District, when other suitable land is available such as Grove Farm and Radford Semele. As has already been demonstrated thus far, the provision of housing does not suggest a requirement - nor has the Council in their Summary documents shown how they intend to guarantee complete utilisation of any new development that would come at the expense of the Green Belt.

There are surely several purposes of including land in Green Belts:

1. to check the unrestricted sprawl of large built-up areas - the identified developments in the Summary documents seem to be encouraging urban sprawl;
2. to prevent neighbouring towns from merging into one another - development now is merely a stepping-stone for urban coalescence;
3. to assist in safeguarding the countryside from encroachment - clearly the development of 10,800 properties would not be consistent with Green Belt;
4. to preserve the setting and special character of historic towns - as a town we should be proud of our Royal and Spa heritage. Leamington is a place of immense beauty of which the countryside plays a significant part of this; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land - within the District there are many, many examples of not utilising the land to its capacity initially.

As the Green Belt in the District has been defined, the use of land in them has a positive role to play in:

1. providing opportunities for access to the open countryside for the urban population;
2. providing opportunities for outdoor sport and outdoor recreation near urban areas;
3. retaining attractive landscapes, and enhance landscapes, near to where people live;
4. securing nature conservation interest; and
5. retaining land in agricultural and related uses.
These opportunities for current and future generations would be lost through development on the Green Belt. The thousands of people that utilise the land toward Milverton and Blackdown every year will lose this recreational access. The Council claim that opportunities will be provided in the Garden Suburbs but these opportunities already exist in a state that is more naturally beautiful than what any construction company can come up with.

A Green Belt should be several miles wide, so as to ensure an appreciable open zone all round the built-up area concerned. Boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges. Well-defined long-term Green Belt boundaries help to ensure the future agricultural, recreational and amenity value of Green Belt land, whereas less secure boundaries would make it more difficult for farmers and other landowners to maintain and improve their land. These difficulties would become apparent under the new development proposals and actually would result in the loss of the Green Belt and redefined as a Green Wedge. The description amounts to semantics because the countryside will be lost - period.

The construction of new buildings inside a Green Belt is inappropriate unless it is for the following purposes:

1. agriculture and forestry;
2. essential facilities for outdoor sport and outdoor recreation, and for other uses of land which preserve the openness of the Green Belt and which do not conflict with the purposes of including land in it;
3. limited extension, alteration or replacement of existing dwellings;
4. limited infilling in existing villages

The Council has not demonstrated the essential or exceptional circumstances that require the development of the Green Belt near Milverton or Blackdown. For example, the land here adequately supports outdoor recreation which future development does not.

The Council has not adequately and beyond reasonable doubt identified the insufficiently suitable and available sites outside of the Green Belt, especially with the inflated growth projections. The land near Gallows Hill towards Bishops Tachbrook has not been included as identified growth despite its ready infrastructure and proximity to employment opportunities. The land near Gallows Hill (and Gallagher Business Park with its 700,000 square feet) and Chase Meadow (and Tournament Fields with its remaining 615,000 square feet) seem more logical options in terms of providing the land for housing developments and employment opportunities with the land already available. These are established communities whereby further development would conserve the Green Belt of other identified land.

As the Council takes positive green efforts in initiatives such as recycling, the proposed development seems to run contrary to being "green" as:

1. they seek to build on Green Belt land when sufficient land is already available in a part of District that is being ignored in the proposal. Is this political? Why not use Grove Farm?
2. they support the building and development of a main road through Old Milverton, a rural community within a stone's throw of the historical charm of the Saxon Mill and Guy's House. This would increase traffic and naturally pollution of noise, visual and environmental varieties;
3. they support this development at the expense of encouraging people to use public transport which would have much more of an environmental benefit; and
4. additional residential areas would create more traffic in the Green Belt zone through the endorsement of urban creep. It would not be unreasonable to assume that each dwelling will have at least one car, if not two, meaning anywhere between an additional 11,000 - 16,000 cars in the District and the environmental damage that comes with these using the Council's growth projections.

The Council in its Summary document talks about climate change and a requirement to reduce carbon omissions by 20%. Yet, through the development of the Green Belt this is counter-intuitive. Building houses on Green Belt would bring additional car usage as property will be developed at the furthest point in Leamington from where the major employment opportunities lie. This would increase the volume of traffic and journeys that would be undertaken leading to more pollution. By the Council's own admission the District's carbon dioxide emissions are higher than the national average. To help reduce this housing development would be best located near employment in the Heathcote and Radford Semele areas. This preserves the Green Belt and the Green Belt's ability to offset the carbon dioxide.

The Council also states on page 15 in its Summary document "the Green Belt covers a large part of Warwick District and seeks to stop urban sprawl that would harm the open nature and rural character of the open countryside around the towns and the urban areas of the West Midlands." This is the Council admitting that developing the Green Belt would harm the countryside and undermine the rural character of places like Old Milverton. So why develop on it when alternatives are available?

The Council further states on page 19 in its Summary document "providing and improving...walking networks, improving access to the countryside, improving biodiversity and looking after the District's unique landscape are all important in making Warwick District a great place." All these natural requirements are already in place. The District should be promoting them and allow the community the chance to continue to use them in the best state possible, their natural state. Green Belt development is not going to be in keeping with making the District a great place to visit if there is no countryside. Housing developments are not high on people's list of places to visit and appreciate.

In the Executive Summary the Council talks about Biodiversity Offsetting to avoid negative impacts on existing biodiversity. This is the Council's open acknowledgement that Green Belt development will have a negative impact. By reshaping nature, once it is altered by its very definition it is no longer natural. How is biodiversity offsetting going to help local communities if the sole aim is to ensure that developments secure net gains? What this amounts to is the destruction of the Green Belt on the indemonstrable hope that it will be offset somewhere, anywhere!!! This is not very helpful to local communities. How does the destruction of the Green Belt in Leamington benefit the community if the offset is in Kenilworth???

One of my main objections would be around the justification for using Green Belt land for employment opportunities. As I look around the District there is already sufficient land that is available for development that has not been developed or unit's that are available to be utilised. My feeling is that building additional housing and using employment opportunities as a screen will end up with further "white elephants" as buildings designed specifically for employment remain empty.

There are currently vacant premises and/or land at the following sites that would comfortably create employment opportunities:

1. Gallagher Business Park - 700,000 square feet for development
2. Tournament Fields - 700,000 square feet for development and only 85,000 square feet has been developed
3. Tachbrook Park - 20 acres for development
4. Shires Retail Park (former Focus unit)
5. Budbrooke Point (units For Sale)
6. Wedgnock Industrial Estate (several units up To Let)
7. Portobello Riverside (by the doctor's surgery)
8. Warwick Technology Park - I work in the Iceni building and over half it has been empty for the 18 months that I have been here
9. The Barford Exchange

This is not an exhaustive list either.

The Council should be focussing on filling these unit's as opposed to creating further surplus capacity that will also remain empty. This can be done by offering tax incentives or rent free periods to encourage employers to relocate (or with landlords to encourage such). There is no guarantee in the Summary documents that these employment opportunities will be filled or filled by local residents.

As these sites are already established they have good infrastructure links that make the M40 and A46 accessible. That is one of the significant advantages that the towns of Leamington, Warwick and Kenilworth enjoy; their proximity to these major transport arteries in the middle of the country. With the recent positive redevelopment of the Longbridge Island to alleviate congestion this has increased the accessibility of these sites. They are on the south side of the towns of Leamington and Warwick, we should be looking to take advantage of what is in place and improve on what we already have than trying to create additional opportunities all over the District. Financially, this would also make more sense because development would not be from scratch.

The proposed development in places like Milverton and Blackdown would necessitate material improvements to the infrastructure using valuable cash the Council does not have, especially as it will be several years before there is a return on such investment. With the current spare capacity at such places listed above it would be more economic, effective and efficient to target investment here so that further infrastructure development and disruption is kept to a minimum.

If employment opportunities are deemed to be on a scale like recent residential developments at Warwick Gates and Chase Meadow then this would appear to mean approx half-dozen retail outlets of various stripes, but generating employment for maybe no more than 30-40 people. This seems a disproportionate argument for permanently removing Green Belt land for the sake of creating such a small number of jobs.

What are not set out in the Summary documents are guarantees provided by the Council over employment being enduring in these newly developed residential areas. Why is there certainty that employment would be "full" and that units/buildings would continuously be occupied when there are multiple developments already unoccupied or waiting to be developed? Empty premises would soon fall in to a state of dilapidation to the detriment of the community they are supposed to enhance. The current economic state of the country (ne the world) does not support confidence that such targeted opportunities would come to fruition and persist.

One only needs to consider the Court Street Arches which are empty. This is a project that was supported and funded as a Business Enterprise Project by the Council. On the one hand I congratulate the Council for the significant aesthetic improvement as a consequence of this initiative; on the other, it has not served its primary objective of creating employment and thus paying back to the community the cost of this undertaking. Employment is not guaranteed in any situation.

The development of buildings for employment opportunity needs to be clearly demonstrated. If the presumption is the employment would be retail (similar to Warwick Gates and Chase Meadow) then what is to stop the buildings becoming another Regency Arcade? Planners and councillors should have strategies considering the welfare of the Districts a whole. When unsuccessful businesses fail, this can mean years of dereliction before new trades move in. This is evident in Old Town, Regency Arcade and at the bottom of The Parade. Brand new buildings that never have tenants are even more depressing and are likely to continue due the current economic climate combined with the permanent change in shopping habits.

So, when the Council talks about its vision and objectives that it wants to achieve in its Summary document i.e. support the growth of the local economy, why is this not being undertaken already and utilising the land already set aside for development, why does housing and employment opportunities have to come at the expense of the Green Belt? As has been demonstrated above, providing employment land close to new housing in Milverton & Blackdown is unnecessary as there is already abundant land set aside near Grove Farm and Chase Meadow with 1.4m square feet available for development. Setting aside further land on Green Belt is not necessary. This is not in keeping with the Council's stated objective of "maintaining and protects the vast majority of the District's Green Belt".

Clearly, the land proposed to the north of Leamington is already an important local amenity for exercise and recreation as there is very little publicly accessible open space in this area. Developing the Green Belt in to Green Wedges would not have a positive effect because it would erode the land available and impact upon pedestrian safety which is a natural by-product of residential areas and the increased traffic it would bring.

Within the current locality of where I live, the only public park is near Dragon Cottage on Guys Cliffe Avenue. Therefore, having the land from Milverton to Blackdown is the alternative local amenity and one which can be enjoyed in absolute safety and the pleasure the natural beauty of the local countryside brings. This does not necessitate having to drive to places like Newbold Comyn or St Nicholas Park and making those meaningless five minute car journeys which are the bane of society but symptomatic of the hectic world we live in. The countryside provides an outlet and release from this.

How ironic the Council is facing this issue at the very time when the Olympic torch has made its way through Leamington and Warwick. At a time when we should be revelling in hosting such an event, an event that encourages sport and activity amidst perpetual cries from politicians to get out there and compete and live healthier lives, the Council wishes to remove the Green Belt. In Milverton and Blackdown the countryside is popular with walkers, runners and cyclists; individuals and families alike. The irony and hypocrisy is not lost. How is the development of the Green Belt going to help overcome the challenges of motivating the Playstation Generation to go and appreciate the outdoors when there is none; or if they need to visit parks they have to drive. It seems self-defeating!

This appears to be an example of failing to appreciate the importance of the countryside to the public and recognition that once it's gone, it is gone. The visual amenities of the Green Belt should not be injured by proposals for development within the Green Belt which clearly the new buildings would be visually detrimental by reason of their siting (when places like Grove Farm and Radford Semele can be developed without eroding the Green Belt), materials and design.

In the Executive Summary it talks about "it will be important to maximise linkages and access to the wider countryside for recreational purposes for all". I would suggest that the people who wish to take advantage of the beautiful countryside in the locality do so already. People who also live in close proximity to the countryside probably do not use it so improving the linkages will not equate to more people using the land for recreational purposes. The Council also talk about "protect the quality of existing open spaces in the District and enhance the quantity and quality of open space". Building housing on Green Belt is definitely not protecting anything, let alone Green Belt. I am also curious as to how building houses on Green Belt is ever going to increase the quantity of open space!!! Surely the very essence of building something means that you will lose space, Green Built space at the expense of land which has previously been set aside at places like Grove Farm and Radford Semele, the very places which are closer to the employment opportunities and better infrastructure.

Development should not require additional expenditure by the public sector on the provision of infrastructure, nor should it overload local facilities such as schools and healthcare facilities. It does not appear as though the Council taken in to account any additional infrastructure requirements i.e. roads, which may have significant adverse effects on the Green Belt. Nor has it been outlined the adequate financial provisions that should be made for the future maintenance of landscaped areas.

Clearly, by diversifying the number of locations which are to support the new developments it is going to take considerable investment as well the utilisation of further land to provide for adequate infrastructure development, leading to further destruction of the countryside as Milverton and Blackdown is not geared up for this kind of development when places like Grove Farm are already set-up to cope with future development.

The proposal also talks about the North Leamington Relief Road (at a cost of approx £28m) which would destroy the very fabric and tranquillity of Old Milverton. Aside from its impact on this small rural community it is diverting resources away from other public services, services which are more pressing and more important to the council tax payers such as me. Additional houses would place a greater burden and stretch Council resources further.

The public have seen cut-backs in services such as the opening time of Princes Drive Recycling Centre. Would additional houses lead to further "reductions" as services would have to be spread more thinly as council's have to rationalise and reorganise like all other business. Conversely, would the council tax increase to pay for the additional services required to sustain more houses?

What has not been outlined is how the additional burden from an increasing population will be met, addressed or how they are expected to cope:

 on over-subscribed local schools such as Trinity, Brookhurst and Milverton. An incidental side affect on these schools would be the increase in traffic and the impact this would have on child safety as people would use the new infrastructure as a potential cut-through to the relief road; and
 on policing. Nationally there is going to be a 20% cut on policing by 2015. As part of the council tax is weighted towards paying the cost of policing are council tax bills going to go down which would seem only fair as the service is being cut?

I would suggest it is unlikely the Council will reduce the taxes I am expected to pay. I accept that I now get less "bang for my buck" such are the times we live in. But what I do expect from my Council is the application of common sense and applying a zero-based budgeting approach to wisely spend the funds in their coffers. Spending £28m on a road which actually has no proven tangible (economic) benefit would advisably be better channelled elsewhere, supporting the provision of public services or improving existing infrastructure in already established communities where new housing development is more sensibly undertaken.

Furthermore how does the development of a relief road fit in with the Council's preferred option, as stated in the Executive Summary, of "supporting a low carbon economy within the district"? By its very nature it is encouraging more traffic and commuting in to the area. Considering the District has carbon emissions above the national average this is not going to help tackle the environmental problem. If the District is committed to the employment opportunities it talks about then it should look to continue to support the infrastructure in the developed areas of the District which have the natural advantage of being close to the major arterial links of the M40 and A46 i.e. Grove Farm and south Leamington as a whole or looking at improving services through better and reliable provision of public transport. The Council should be doing this already as opposed to relying upon proposed infrastructure levies.

What this road and housing development on the Green Belt would do is lead to urban creep (or urban coalescence) because the Council would effectively be signalling that there is no land which is considered off-limits. It would tacitly be condoning the spreading of boundaries within Leamington, Kenilworth, and Old Milverton.

Old Milverton could very easily lose its identity, which is inextricably linked to the countryside, with the housing development of land in the Milverton and Blackdown area. This identity, of a tiny, picturesque rural community would further be destroyed by the encouragement of additional traffic as a consequence of a relief road. Each of our local communities has something that it's residents can be proud of and easily identify with, the growth of the District should ensure that Leamingtonians can still relate to their Royal Spa town, Warwickians and people for Kenilworth with the iconic castles etc, but the consistent theme should be that our countryside and Green Belt remains intact in the face of the human thirst for growth and money.

Spending valuable cash resource on building on Green Belt through the creation of a relief road would not tangibly impact many in the District. The public would much rather the Council spent funds on what really matters to them and where they will have a tangible benefit. A road through a rural community is not what the public consider value for money when every penny counts.

The Council in its Summary document talks about good infrastructure (schools, roads, health care, services and green spaces) but the irony is surely lost. How is developing the Green Belt in Milverton and Blackdown good infrastructure when land that can already be used for development in Heathcote and Radford Semele is ignored? How are the roads of the District good infrastructure when we are always facing road improvements which continuously causes disruption especially at the end of the financial year when there is panic to spend budget; surely improving the roads in south Leamington is advantageous because these are where the major employment opportunities and main road links are as opposed to developing new roads where none are needed? On page 17 in its Summary document the Council states that "new development will inevitably lead to extra pressure on the District's transport infrastructure" but why create this extra pressure by developing new areas when established communities with very good infrastructure are already in place?

IN SUMMARY:
There is, in my opinion, no need to build on the Green Belt to the north of Leamington:
 There is the land available to the south of Leamington especially on Grove Farm and the District Council's own evidence shows that. Alternatively, there is land directly to the east of Radford Semele which could accommodate housing and land directly to the south of Bishops Tachbrook that could take a similar number. Both areas are also outside the Green Belt. Both areas do not seem to have been considered by WDC;
 Nearly all the employment is on southern side of the Leamington / Warwick conurbation;
 The M40 is to the south of the Leamington / Warwick conurbation;
 The main supermarkets are on the southern fringes;
 Most importantly, if the Green Belt means anything it should mean that other areas are considered first and only if there is a compelling reason should Green Belt land be used.

The development of the Green Belt is not "enabling people to live healthy, safe and inclusive lives" as expressed in your Executive Summary, nor is it in keeping with "seeking to ensure that open spaces, access to the countryside and habitats are improved" as the said open spaces and countryside are proposed to be built upon.

Such measures as building in Milverton and Blackdown are not in keeping with the Council's preferred option of "protect, enhance and link the natural environment...to ensure physical access for all groups to the natural environment". Access can be granted through the development of cycle networks etc. This retains the natural landscape whilst being committed to preservation and protection; development of the land for housing does not constitute protection or enhancement. Better adjectives would be destruction.

What the Council is doing seems to be of a very political nature by developing the Green Belt when other sites such as Grove Farm, Radford Semele, and Warwick Chase can already be developed but have deliberately been chosen to be overlooked so that the Council can "spread the pain". By adopting a plan to remove villages from the Green Belt and draw new Green Belt boundaries around the settlements to allow for development is nothing short of gerrymandering and should not be allowed to happen even when all other options have been exhausted. Development of the Green Belt now means that the flood gates will have been opened and sends a message that nothing will be sacrosanct in the future.

This is not the future I envisage for the town I have resided in my entire life and paid my taxes to for the dwindling services I now see and receive. A stand should be made and preserve some of the final bastions that make this district one of the most beautiful in the county. Exceptional circumstances need to be demonstrated to develop Green Belt - these have clearly not been demonstrated and I would suggest the Council has bigger questions to answer over matters such as employment and utilising what we already have before setting aside further land which will go the same way.

The Council needs to be more economic, efficient and effective in the utilisation of its resources and the public's resources that it is entrusted to look after and utilise in the best possible way for the District. This does not extend to building a North Leamington Relief Road and building on Green Belt; it does mean the Council should look to improve further the existing employment and infrastructure in the south of Leamington and utilising this land for housing because local amenities are more geared towards catering for the additional demand. They should not be turning a deliberate blind eye to the natural advantages the south of Leamington possesses for the sake of politicking.

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

Delivering Growth (PO1 & PO3)

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

Affordable housing (PO5)

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

Mixed communities (PO6)

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

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

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

Economy (PO8)

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

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

Retailing and Town Centres (PO9)

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

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

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

Historic Environment (PO11)

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

Climate Change (PO12)

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

Transport (PO14)

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

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

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

Green Infrastructure (PO15)

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

Culture and Tourism (PO17)

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

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


ADDITION

Evening Economy

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

I am astonished and appalled that any district council in 'leafy Warwickshire' should consider, for one moment, building on our Green Belt. The Great Act of Parliament which gave us this protection has been in existence for most of my lifetime. It has prevented hideous ribbon development and enabled green 'lungs' for the benefit of most of the population. Building on precious Green Belt would be an act of vandalism, despite the undoubted profit to private developers, that deprives the citizens which you should be seving and to whom you owe a duty of protection.
We have great need of new council accomodatrion in the district of Warwick, but even necessary public housing on Green Belt would be a dreadful decision.

This building could eventually mean that Leamington and Kenilworth become joined and the existing roads, Rugby Road and Kenilworth Road could
not possibly cope with this kind of increase in traffic.

It would be very wrong for our district council to act in the service of private developers, who undoubtedly stand to make a great deal of money from destoying precious Green Belt and whom are probably lobbying hard,to the detriment of its citizens of whom I am just one.

Warwick Local Plan - Preferred Options:
Formal Representations - Land at Station Lane,
Lapworth.
We act on behalf of The Trustees of the F S Johnson 78NEL Settlement in respect of land at
Station Lane, Lapworth, and welcome the opportunity to make representations on the Warwick
Local Plan Preferred Options Development Plan Document (DPD). The extent of the land
ownership is shown on the attached plan, and I am pleased to set out our formal representations
below.
General Comments.
1. We support the principle for delivering 'Our Vision for the District' which proposes to meet
the housing needs of the existing and future population of the District, including the
identification of land for around 550 new homes per annum on new allocated sites, and
proposing to distribute development across the District.
Comments on Specific Policies.
PO3: Broad Location of Growth
2. We support the Council's Preferred Option to distribute growth across the District,
including within and / or on the edge of some villages, and to allow for a hierarchy of
growth in the rural area to include a higher level of growth in those villages with a broad
range of services and public transport to the towns.
2
PO4: Distribution of Sites for Housing
3. We welcome and support the identification of Lapworth as a Category 1 village in
recognition of the range of services and public transport links available within the
settlement. We also support the explicit recognition given in the policy to the need to
define the boundaries of village envelopes, and then to exclude land within those village
envelopes from the green belt to enable development to take place.
4. We support the proposal to allocate land for 100 dwellings within Lapworth to be built and
phased across the three phases of the Plan up to 2029.
5. The supporting text, in paragraph 7.36, confirms that in the case of category 1 and 2
villages which are currently 'washed over' within the green belt, it will be necessary to
identify areas with potential for limited development and include it within a village
envelope along with the built up area of the village. The boundary of the green belt would
be adjusted accordingly around the village envelope.
6. In the case of Lapworth, the current village envelope reflects the largely linear nature of
the settlement, and includes the development along the length of Station Lane and two
small consolidated areas of development along the Old Warwick Road to either side of
the railway bridge.
7. In our view, the opportunities to identify land that would be seen as a 'natural extension'
of the current village envelope are limited, being constrained by the clear physical
boundary provided by the railway line, the location of the Grand Union and Stratford
Canals, the land at risk of flooding, and by the presence of attractive natural features such
as wooded areas or trees.
8. However, our clients' land provides one of those limited opportunities where development
could take place to provide the additional new housing that is needed whilst being seen
as a natural extension of the village envelope.
9. The land is located within Station Lane, with a frontage to the eastern side of the road
between an existing ribbon of houses to the south, which are already included within the
village envelope, and a further ribbon of houses that are not currently within the envelope
boundary. On the opposite, western side of the road, there is an established line of
relatively closely packed houses, and the frontage is therefore seen within an urban
context such that its inclusion within the envelope would be seen to be entirely
appropriate.
10. The land is very close to the village railway station and therefore provides a highly
sustainable location for new residents who need not be dependent on the use of a private
car to access employment opportunities or the higher order level of services and facilities
available in town and city centres.
11. The land is unconstrained, being open and available to accommodate a range of
development options. Field boundary hedging could be retained as part of any scheme of
development if desired, and access could be provided along the Station Lane frontage
whilst retaining the two existing mature trees. Only the strip of land along the canal lies
within the flood area, but this part of the site would be excluded from consideration in any
event.
3
12. The land is within the central part of the village, as defined by the current village
envelope, rather than at the periphery and therefore the village school, post office and
shops and services are all within easy walking distance.
13. The existing field boundaries would provide clear physical boundaries which could be
utilised to define a robust and defensible boundary to the enlarged village envelope.
14. The land is one of only 3 gaps on the eastern side of Station Lane which lie outside the
current village envelope, which otherwise embraces the development along both sides of
the road. Whilst the land to the north of Meadow Lane is closest to the station, it is welltreed
and the removal of those trees as a consequence of development would result in
the loss of an attractive feature in the Lane. Of the two remaining gaps, our clients' land is
closer to the village centre than the land near Kingswood Close, enhancing its credentials
for selection as a first-choice allocated housing site.
15. The extent of the land available lends itself to a variety of development options, including
cul-de-sac development to mirror similar patterns of development elsewhere within the
village, including Station Lane, without looking in any way out of place or out of character
with the prevailing pattern and style of development within Station Lane, whilst providing
for the housing needs of the village.
16. In short, our clients' land constitutes the best opportunity available within the village to
achieve the housing requirement for Lapworth in a manner that meets the normal planning
objectives for site selection whilst minimising the impact on the village environment. It is a
'natural' infill opportunity within a Lane that is largely characterised by linear development
on both sides, and its development would be easily absorbed into the built fabric of the
village without appearing, in any way, to look out of place or out of character. On that basis,
and on behalf of our clients, we commend the merits of the site to the Council and request
that it be favourably considered as a formal housing land allocation in the next stage of the
plan preparation with the publication of the Draft Plan early in 2013.
17. We formally request that land forming part of our client's land holding at Station Lane be
allocated for housing development and included within an expanded village envelope for
Lapworth to accommodate the housing

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

See attached

Scanned Letter and Response Form

Scanned letter and Response Form

Warwick Local Plan - Preferred Options Consultation
Response on behalf of Taylor Wimpey's Land Interests in Barford
We act on behalf of Taylor Wimpey plc, who have a land interest in Barford. A copy of the site plan is appended to these representations. Below we set out a response to a number of draft policies contained in the Preferred Options document (May 2012).
PO3: Broad Location of Growth
Taylor Wimpey support the Council's Preferred Option as set out in draft Policy PO3 which includes the distribution of some housing growth across the District, including land within and/or on the edge of some villages. Furthermore support is given to the proposal for a hierarchy of growth in those villages with a broad range of services and public transport to the towns.
Taylor Wimpey have land interests in Barford, and consider that this could deliver upto 60 new homes in a location that is considered to be sustainable for this scale of development.
We consider that the Council's proposed approach to housing delivery, as set out in draft Policy PO3, accords with the requirements set out in paragraph 47 of the NPPF which encourages Local Planning Authorities to significantly boost the supply of housing through a number of means. The support for providing new homes through extensions to existing villages is also encouraged by the NPPF (paragraph 52).
PO4: Distribution of Sites for Housing
Taylor Wimpey supports the proposal for Category 1 villages, including Barford, to provide 100 dwellings. However, we consider, specifically in respect of Barford, that where sites, in addition to Taylor Wimpey's site at Land off Wellesbourne Road, are identified as being suitable and deliverable for residential development, within and/or on the edge of the village, then Barford may be able to accommodate growth in excess of 100 dwellings. On this basis, we suggest that a dwelling range should be provided which indicates the minimum and maximum number of units the Council considers to be broadly acceptable on sites which are deliverable and developable in Barford. Whilst we understand that the 100 dwelling figure is not a maximum, it would be helpful for development management purposes to establish a figure that was considered to be the upper limit. Furthermore, if some of the Category 1 and 2 villages are unable to meet the broad targets set then other villages may need to make up the shortfall. It is suggested that an assessment of likely housing capacity in each village is required to understand what the housing capacity parameter should be.
1 August 2012
TW Warwick PO Response Letter July 2012.docx
Development Policy Manager
Warwick District Council
Riverside House
Milverton Hill
Leamington Spa
CV32 5HZ
a
Page 2
PO6: Mixed Communities & a Wide Choice of Homes
A - General Market Housing
Taylor Wimpey broadly supports the requirement for housing developments to provide a mix of house sizes and types to meet the needs identified in the SHMA. However, not all sites will be in a location or be of a size to always fully reflect the SHMA requirements in full. Therefore, it is proposed that the words "seek to" are inserted in between the words "will ensure".
PO12 : Climate Change
Taylor Wimpey notes the Council's intention to adopt a requirement that "seeks a 20% reduction in carbon emissions from development to include a contribution from renewable and low carbon technologies". Whilst the policy implies that the carbon reduction is not restricted to these technologies, Taylor Wimpey request that the policy is amended to include reference to the following:
"Where development viability supports a 20% reduction in carbon emissions, contributions to this may include reductions through supply chain and construction methods, as well as contributions from renewable and low carbon technologies".
As part of the CIL viability work, it is requested that any costs associated with a 20% reduction in carbon emissions is taken into account with all other design requirements and planning obligations such as affordable housing.
PO12 : Transport
Preferred Option: Parking
Taylor Wimpey support the proposal to review Vehicle Parking Standards supplementary planning document (2007) and specifically the intention to ensure car parking is provided within new residential developments that allows for convenient and safe parking. Taylor Wimpey would welcome the opportunity to respond to any future supplementary planning document that is prepared.
We look forward to receiving confirmation of receipt of these representations.

See attachment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Scanned document

RESPONSE TO WARWICK DISTRICT COUNCIL LOCAL PLAN PREFERRED OPTIONS

PO1: Preferred level of growth
I support the preferred option based on an average 600 new homes per annum, as being realistic against current demographic trends and economic growth projections. However, should economic growth trends change in future years the council should seek to respond flexibly as required.

PO2: Community Infrastructure Levy
This new system of raising funding from new developments to support infrastructure developments offers important new opportunities but also presents major challenges. It requires a new set of relationships between district council, county council and other local partners, to not only draw up and agree CIL-funded infrastructure development plans for the district but to create a long-term stable framework for them to be implemented over many years.

PO3: Broad location of growth
I support the preferred option, and in particular that Kenilworth should have its fair share of new housing development (770 homes per Table 7.2) within the total district target. I disagree with the stated view of Kenilworth Town Council that there should be no further development in the town. A vibrant, sustainable community requires some headroom to expand and develop. There is a clear need for a better housing mix in Kenilworth, especially for more starter homes for young people and opportunities for older residents wanting to downsize to smaller properties.

PO4: Distribution of sites for housing
I support the preferred option that Kenilworth new housing development should be concentrated on the Thickthorn site. Kenilworth Town Council has stated a preference for 700/800 houses to be distributed across the town, but has admitted that this cannot be done while meeting their own criteria. These mixed messages only serve to confuse local residents.
Concentrating new housing development in one Kenilworth location provides the opportunity for the right level of infrastructure development to support this - roads, walking and cycling routes, school and other community facilities. Piecemeal small-scale developments across the town, even if there were suitable sites, would be difficult to support through improved infrastructure, so putting further pressure on existing facilities and resources.
I support strongly the proposed designation of the Thickthorn site for employment use as well as for housing. There has been a long-standing shortage of suitable employment land in Kenilworth. I would not support just an office park however. What is needed is a good mix of employment opportunities, to include for example research and development organisations and light industrial units.
I support the proposed designation of Burton Green as a 'Category 2' village, provided that the Parish Council is fully consulted and involved in decisions about target numbers, types and locations of new housing.

PO5: Affordable housing
I support the proposed option. The proposed policies seem to be soundly based.
It is interesting to note that the Strategic Housing Market Assessment (SHMA) estimates the requirement for 115 affordable houses per annum for Kenilworth alone. This reinforces my earlier statement under PO3 that there is a clear need for a better housing mix in the town. The SHMA estimated need is greater than the total new housing allocation for Kenilworth over the 15 year period of the plan. Consideration should therefore be given to achieving a much higher figure than the minimum 40% affordable housing on the Thickthorn site, and also seeking every opportunity for more affordable housing in any 'windfall' sites that come forward for development within the town.

PO6: Mixed communities and wide choice of housing
I support the proposed option.
Regarding the Thickthorn site, for the reasons stated previously I see the priority within the housing mix being for starter homes for young people, and smaller units for older residents wanting to downsize but to stay living within the town. There could also be an opportunity to cement further the links between Kenilworth and the University of Warwick by the building of new student accommodation - something completely missing at the moment.

PO9: Retailing and town centres
I support the proposed option, in particular promoting the vitality and viability of town centres, and strongly resisting further out-of-centre retail developments.

PO12: Climate change
I support the proposed option, in particular ensuring flood resistance and resilience in all new developments through sustainable urban drainage schemes (SUDS). Well-designed SUDS are not only functional, but can enhance the natural environment of open space areas associated with new developments.

PO13: Inclusive, safe and healthy communities
I support the proposed option, in particular the importance of access to high quality open spaces and sport/recreation facilities for all residents.
In para 13.10 (2nd bullet point), I would like to see the words "pedestrian and cycling" substituted for "pedestrian". Policies should do everything possible to encourage the greater use of bicycles by all sections of the local community, both for healthy exercise and as a sustainable/zero carbon means of transport within our district.

PO14: Transport
I support the proposed option, in particular the strong emphasis on promoting sustainable forms of transport.
The importance of the K2L cycling route between Kenilworth and Leamington cannot be overemphasised, together with provision for bus lanes and bus priority schemes on this important route. I see these as the priorities for highway improvements on this route rather than increased provision for private vehicles.
Within the town of Kenilworth, there is a massive task to be done to improve routes and facilities for pedestrians and cyclists, and this should be the priority for infrastructure investment to support new housing development. I disagree fundamentally with the view of the Town Council that a multi-storey car park is required in the town centre. Policies should be seeking to encourage residents to leave their cars behind for short-distance local trips whenever possible.
Map 5 shows a proposed cycle route through Abbey Fields to link up two elements of the National Cycle Network. This has been the subject of considerable negative comment by some residents, community organisations and the Town Council, which has been reflected in other responses to this consultation I understand.
The council has a duty to balance these strongly-expressed views, i.e. that no cycles should be permitted in or through the Abbey Fields, with the needs of the local community as a whole. I would highlight some of the comments in the Draft Green Space Strategy document, in particular section 4.1.7 on page 19 of that document:
"The value of green spaces can be greatly enhanced by linking them together into corridors and networks giving safe, attractive access for pedestrians and, in some cases, cyclists.
"... enable people living in urban areas to reach the countryside .... provide a green alternative for journeys to work or school."
"By-laws prohibiting cycling and horse-riding in some green spaces may need to be reviewed to achieve this."
Through the development of the Connect2 Kenilworth (C2K) route, the town has gained a valuable green corridor linking it to the countryside, and providing an important new travel alternative for people working at the university, Policies should be focussed on making it more accessible from all points of the town, and there is no doubt that a cycle route through Abbey Fields would become an important link between the west side of the town and C2K. Currently no other options have been proposed which would achieve the same result.
There is also the fact that the Abbey Fields are an important destination in themselves for many local residents, including families with young children wanting to access the playground area, and yet at the moment there is zero provision for any residents wishing to travel there by bicycle. Residents lucky enough to live nearby are able to walk, but others have no alternative but to drive there. With the Abbey Fields car park already at saturation point and due to reduce its capacity shortly, the council must consider how it can encourage more residents to access the Fields by bicycle.
In terms of transport infrastructure to support a new Thickthorn housing and employment development, for the reasons stated earlier a high priority should be given to sustainable transport options - i.e. walking, cycling and public transport. However, this site also offers the opportunity to create an important new link road between the traffic island over the A46 by-pass and the eastern side of Kenilworth (joining Glasshouse Lane at a point near Rocky Lane). As well as serving the new development and ensuring it is fully linked into the rest of the town, it would help to alleviate current traffic congestion around the St John's gyratory - something which piecemeal development of eastern Kenilworth over many years has failed to address.

PO15: Green infrastructure
I support strongly the proposal for the development of a peri-urban park north of Kenilworth. This would build on the success of the C2K Greenway route in opening up this important piece of our local countryside to all sections of the local community.
I do not support the arguments so far put forward for the restoration of the Kenilworth Mere. The outline feasibility study conducted by Warwick Business School MBA students showed that any viable scheme could have a massive impact on a large area of precious countryside adjacent to Kenilworth Castle, almost certainly involving commercial developments such as hotels, apartments etc.

PO16: Green belt
I support the re-drawing of green belt boundaries to the east of Kenilworth and around the village of Burton Green in order to permit the developments proposed in this Local Plan, and for no other reason.

PO18: Flooding and water
As stated previously, I support the requirement for SUDS schemes as part of all new developments.

See attached

Proposed housing on Green Belt land

Leamington residents are fortunate in having a swathe of lovely green on the north side but with very little of the same to the west and south. Even the countryside to the east is severely threatened by the fast rail link. So we think it is essential to retain the land which is designated as green belt, and should not therefore be subject to building developments,for the pleasure and delight both of local citizens but also as a draw for visitors who are essential for our economy. We object most strongly to the proposal.

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

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

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

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

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

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

See attached

As attached

See attached

Scanned form

Thank you for giving the NFU West Midlands Region the opportunity to comment on the Preferred Options Consultation. The NFU is a professional body which represents the interests of 75% of all farmers and growers. Our views are on behalf of the farming and land management sector in general and follow discussion with local members.

It would be appropriate by way of an introduction to offer a few general remarks on farming and the planning system. Clearly food security is a key concern. On a global level it is of absolute importance that the world is able to feed itself; but it is equally important that food is produced in Warwickshire in order to meet our own needs.

The challenge in the 21st century is to increase productivity, maximise output, minimise inputs, achieve environmental sustainability and adapt to a changing climate - all of these challenges are ones which British agriculture is very well placed to meet. It is therefore vital that the planning system helps to ensure that farms can evolve and utilise best environmental practice in order to improve efficiencies and reduce carbon emissions. Our detailed comments on the consultation paper are set out below.

PO3 Broad Location of Growth
The NFU is very supportive of the policy of distributing growth across the District as it will facilitate some growth in smaller rural settlements in order that they remain viable and sustainable. We also welcome the assessment of the Green Belt. It is important to review the situation as the pressures and priorities for development do change. Altering the boundaries and removing some areas could have a positive knock on impact on the agricultural businesses located in these areas. It will give them more opportunities to evolve their businesses in order to remain viable into the future. We would like to enquire why the land south of Harbury Lane, Bishops Tachbrook has been designated greenbelt, as this will constrain the farmers business.

PO4 Distribution of Sites for Housing
We have not made a detailed examination of all the locations outlined in PO4. However, where sites are allocated for development the proximity of the land to existing agricultural business must be examined. Sites should not be allocated for residential development if they are found to be in near proximity to for example an existing livestock unit. We are keen to ensure that development in the countryside does not result in conflict between new residents and existing farm businesses.

The NFU welcomes the support in PO4.D. for rural workers dwellings and the conversion of rural buildings on the edge of settlements. When new dwellings are constructed for farm businesses it is important to ensure that they are able to cope with a range of functions. For example they will almost certainly require adequate space for a farm office and boot room. It is important to note that farming families do not have the option of moving house if they should outgrow their home and this must be recognised when planning new accommodation.

The reuse of redundant rural buildings is a key concern for NFU members. Many of these buildings are no longer suitable for modern agricultural uses for a range of reasons. Having no economic use often means that they fall into disrepair. Therefore in our view it is important that they are given the opportunity of a secure future through redevelopment for residential uses.

PO5 Affordable Housing
The NFU welcomes section B which will facilitate the development of affordable housing in rural areas.

PO8 Economy
The NFU welcomes policy that enables growth of rural businesses and supports the diversification of the rural economy. The NPPF states that "To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century". Paragraph 28 of the NPPF contains a very specific reference to supporting a prosperous rural economy; "Planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development". It also states that plans should "promote the development and diversification of agricultural and other land-based rural businesses".

PO14 Transport
The NFU is supportive of the policies aim to provide affordable transport options in villages and rural areas. Unfortunately at the moment there is often no viable alternative to car transport for people who live in rural areas especially if they wish to take up employment.
When considering transport and infrastructure you should be aware that farms and rural businesses are totally reliant on HGV and car transport. Any decisions to target employment away from areas reliant on the road network may have a negative effect upon the rural economy and restrict farm diversification. Tourism also relies on access by private car and new tourism enterprises must not be limited to sites that are accessible by public transport routes.

PO15 Green Infrastructure
Farmers already undertake a range of conservation management measure in order to improve environment quality and enhance biodiversity. This on-going work must be taken into consideration when considering development on farms. Therefore concerns about Green Infrastructure and the creation of Green Wedges should not stifle rural and agricultural development. As we said in the introduction it is possible to increase agricultural productivity whilst continuing to reduce the industry's environmental impacts. By working with farmers and landowners even more can be achieved.
We are concerned by biodiversity offsetting where off site mitigation measures are required. We would welcome the opportunity to discuss how you envisage this working in Warwick District.

PO16 Green Belt
The NFU welcomes the support for farm diversification and rural affordable housing in Policy PO16. These businesses have an essential role in maintaining the local landscape by grazing livestock, maintaining hedgerows and participating in agri-environment schemes. Farms in Green belt areas may need to invest in new buildings or other infrastructure as animal welfare and environmental requirements change. They may also need to diversify their businesses, perhaps by supplying local produce through farm shops. We are also supportive of the flexibility demonstrated in this Green Belt policy as alterations in the boundary must be made in order to support rural development. These changes will help agricultural and rural businesses in the affected areas to develop and evolve in order to ensure their long term viability. However when considering boundary change it is important to safeguard productive agricultural land and it is usually preferable for grade 3 land to be identified for development.

PO18 Flooding and Water
The growth allocations outlined under PO4 will place additional demands on the natural resources of the county. Farmers have a particular interest in this issue as new development will impact upon the surrounding agricultural land. New development sites should have land earmarked for SUDs and green space so that runoff can be captured and managed. We therefore broadly welcome the policy but urge the council to thoroughly investigate these impacts to ensure that adequate water resources and drainage capacity is available to cope with the new demands placed on the District's natural infrastructure.

I hope that you find our contribution to the preferred Options Consultation useful. The NFU is keen to assist the council with the development of planning policy so if you require further information or clarification of any of the points raised in this response please do not hesitate to contact me at the West Midlands Regional Office.

Thank you for giving the NFU West Midlands Region the opportunity to comment on the Preferred Options Consultation. The NFU is a professional body which represents the interests of 75% of all farmers and growers. Our views are on behalf of the farming and land management sector in general and follow discussion with local members.

It would be appropriate by way of an introduction to offer a few general remarks on farming and the planning system. Clearly food security is a key concern. On a global level it is of absolute importance that the world is able to feed itself; but it is equally important that food is produced in Warwickshire in order to meet our own needs.

The challenge in the 21st century is to increase productivity, maximise output, minimise inputs, achieve environmental sustainability and adapt to a changing climate - all of these challenges are ones which British agriculture is very well placed to meet. It is therefore vital that the planning system helps to ensure that farms can evolve and utilise best environmental practice in order to improve efficiencies and reduce carbon emissions. Our detailed comments on the consultation paper are set out below.

PO3 Broad Location of Growth
The NFU is very supportive of the policy of distributing growth across the District as it will facilitate some growth in smaller rural settlements in order that they remain viable and sustainable. We also welcome the assessment of the Green Belt. It is important to review the situation as the pressures and priorities for development do change. Altering the boundaries and removing some areas could have a positive knock on impact on the agricultural businesses located in these areas. It will give them more opportunities to evolve their businesses in order to remain viable into the future. We would like to enquire why the land south of Harbury Lane, Bishops Tachbrook has been designated greenbelt, as this will constrain the farmers business.

PO4 Distribution of Sites for Housing
We have not made a detailed examination of all the locations outlined in PO4. However, where sites are allocated for development the proximity of the land to existing agricultural business must be examined. Sites should not be allocated for residential development if they are found to be in near proximity to for example an existing livestock unit. We are keen to ensure that development in the countryside does not result in conflict between new residents and existing farm businesses.

The NFU welcomes the support in PO4.D. for rural workers dwellings and the conversion of rural buildings on the edge of settlements. When new dwellings are constructed for farm businesses it is important to ensure that they are able to cope with a range of functions. For example they will almost certainly require adequate space for a farm office and boot room. It is important to note that farming families do not have the option of moving house if they should outgrow their home and this must be recognised when planning new accommodation.

The reuse of redundant rural buildings is a key concern for NFU members. Many of these buildings are no longer suitable for modern agricultural uses for a range of reasons. Having no economic use often means that they fall into disrepair. Therefore in our view it is important that they are given the opportunity of a secure future through redevelopment for residential uses.

PO5 Affordable Housing
The NFU welcomes section B which will facilitate the development of affordable housing in rural areas.

PO8 Economy
The NFU welcomes policy that enables growth of rural businesses and supports the diversification of the rural economy. The NPPF states that "To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century". Paragraph 28 of the NPPF contains a very specific reference to supporting a prosperous rural economy; "Planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development". It also states that plans should "promote the development and diversification of agricultural and other land-based rural businesses".

PO14 Transport
The NFU is supportive of the policies aim to provide affordable transport options in villages and rural areas. Unfortunately at the moment there is often no viable alternative to car transport for people who live in rural areas especially if they wish to take up employment.
When considering transport and infrastructure you should be aware that farms and rural businesses are totally reliant on HGV and car transport. Any decisions to target employment away from areas reliant on the road network may have a negative effect upon the rural economy and restrict farm diversification. Tourism also relies on access by private car and new tourism enterprises must not be limited to sites that are accessible by public transport routes.

PO15 Green Infrastructure
Farmers already undertake a range of conservation management measure in order to improve environment quality and enhance biodiversity. This on-going work must be taken into consideration when considering development on farms. Therefore concerns about Green Infrastructure and the creation of Green Wedges should not stifle rural and agricultural development. As we said in the introduction it is possible to increase agricultural productivity whilst continuing to reduce the industry's environmental impacts. By working with farmers and landowners even more can be achieved.
We are concerned by biodiversity offsetting where off site mitigation measures are required. We would welcome the opportunity to discuss how you envisage this working in Warwick District.

PO16 Green Belt
The NFU welcomes the support for farm diversification and rural affordable housing in Policy PO16. These businesses have an essential role in maintaining the local landscape by grazing livestock, maintaining hedgerows and participating in agri-environment schemes. Farms in Green belt areas may need to invest in new buildings or other infrastructure as animal welfare and environmental requirements change. They may also need to diversify their businesses, perhaps by supplying local produce through farm shops. We are also supportive of the flexibility demonstrated in this Green Belt policy as alterations in the boundary must be made in order to support rural development. These changes will help agricultural and rural businesses in the affected areas to develop and evolve in order to ensure their long term viability. However when considering boundary change it is important to safeguard productive agricultural land and it is usually preferable for grade 3 land to be identified for development.

PO18 Flooding and Water
The growth allocations outlined under PO4 will place additional demands on the natural resources of the county. Farmers have a particular interest in this issue as new development will impact upon the surrounding agricultural land. New development sites should have land earmarked for SUDs and green space so that runoff can be captured and managed. We therefore broadly welcome the policy but urge the council to thoroughly investigate these impacts to ensure that adequate water resources and drainage capacity is available to cope with the new demands placed on the District's natural infrastructure.

I hope that you find our contribution to the preferred Options Consultation useful. The NFU is keen to assist the council with the development of planning policy so if you require further information or clarification of any of the points raised in this response please do not hesitate to contact me at the West Midlands Regional Office.

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

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

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

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

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

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