Justification for Preferred Option for the Broad Location of Growth

The council still seems hell-bent on adding large amounts of building to areas such as Harbury Lane which suffered badly when Warwick Gates was built without regard to infrastructure. Building to the South of Leamington and Warwick still gives the problem that there are few bridging points over the river. Even if Europa way is dualled, there will still be inevitable traffic jams around the roundabouts and backing up from the river bridges. If the work is over the bridges (in the North) then that is where the bulk of the housing needs to be.

The National Planning Policy Framework makes clear that inappropriate development is harmful to the Green Belt and 'should not be approved except in very special circumstances'. It goes on to say that construction of new buildings should be regarded as inappropriate with a list of exceptions that do not include new housing!
The Council has not demonstrated 'very special circumstances'; indeed the authority's own documents show ample suitable land is available without the need to violate the Green Belt.

It seems that Green Belt land is only that until it is decided that it needs to be built on. There is certainly not enough justification for this to be the case.

I object to 7.15. The Green Belt was created to preserve open country between major settlements and to prevent them coalescing. It was not based on "the quality of land", whatever that means.

7.15 seems to be an incentive to landowners run down and neglect their property.

A significant proporation of the proposals in the Local Plan run counter to the guidance in the NPPF.
The majority of the mismatch lies in the Section 9 - The Green Belt. The following issues are relevant:
Para 80 bullet point 1 - green belt serves to check the unrestricted sprawl of large built up areas;
Para 80 bullet point 2 - green belt serves to assist ion safeguarding the countryside from encroachment;
Para 80 bullet point 4 - (especially relevant at the north side of Warwick) - green belt serves to preserve the special character of historic towns;
Para 83 - green belt should only be altered in exceptional circumstances. A model based on data which the WDC has accepted at public meetings should be revisited can not possibly result in 'exceptional circumstances';
Para 87 - Inappropriate development is by definition harmful.
The NPPF also gives guidelines that brown and white field sites should be used ahead of green belt land. Why has this not been done? I have attended 3 public meetings and have not yet been convinced by the reponses to this question.

Support the principle of distributing growth across the District including within and/or on the edge of some villages

Support a lower level of growth in some smaller villages to meet local need, on the basis that any proposed development is in accord with the Parish Plan and Parish Design Statement i.e. development based on local need only.

Designated Green Belt land should remain green belt and not be changed in status to suit a higher demand for housing

Distributing growth around the district, including within and adjacent to selected villages in sensible numbers, is an excellant idea. This surely will help provide sustainable growth to the villages and enable residents and councillors alike to plan how best to meet this requirement taking into account the uniquness of their particular village.
Totally support avoiding development in locations which could eventually lead to coalescence of settlements - of particular importance for villages where residents so greatly value their independent existence.

Under PO10, we explain why housing should be concentrated within existing urban areas.

The rivers passing through Warwick and Leamington must be a major consideration for planners. With most of the places of work, and all of the emergency services being situated on the North side of them there seems little logic in planning for so much housing development on the South side, unless more bridges are also in the plans. Traffic in the 2 towns is bad enough now and must surely be even worse with further development South of the rivers.

We broadly support the stated justification for Policy PO3, but consider that the Council should also recognise the importance of making best use of existing infrastructure (including social and community infrastructure) and taking this into consideration as a basis/ rational for choosing the most suitable and sustainable development locations, and to also in determining how development sites are phased over the plan period.

Being well integrated 'within' the existing urban area of Warwick and Leamington Spa, proposed development on land west of Europa Way ('Myton Garden Suburb') can take advantage of existing infrastructure including highway, bicycle and pedestrian infrastructure, existing local secondary school and utility services. New infrastructure will clearly be needed to help deliver the full scale of development proposed in this location, however, the presence of existing infrastructure means that development can be brought forward and delivered more quickly and, in line with principles set out in NPPF, is inherently more sustainable.

COMMENT on para 7.14

Sprawl is a pejorative word and its use to describe proposed new development around existing towns is not considered helpful and should be avoided. If the Council is referring to the need to avoid poorly designed urban extensions then it would, we consider, be preferable that this is stated in the plan instead.

We have been advised to write to you re new objections to the Core Strategy Plan. Having studied the documentation we wish to object to the overall plan to build a further 8100 new homes in the Warwick district area and in particular the 2700 planned in the south of Warwick (P04 Distribution for Sites for Housing: Location 2 and 3).

The whole basis for the homes is population growth nationally. Imposing massive growth on an area with little expansion of employment would create greater numbers of people who would have to commute to work, much to the detriment of the area and a poor location of people. Warwick District has already seen much development recently, much of it to accommodate those moving from the urban areas of Coventry and Birmingham into a less dense area. Many of those still commute into Birmingham or London and if people are prepared to work in London and commute from the Warwick district this will do nothing to help keep the prices affordable for the locals who want to continue living here.

Warwick District population has in fact increased by 12% since 2000, which is approximately 2x the rate of increase for Warwickshire; 2x the national average increase, and over 3x the increase for West Midlands. (PO1 Level of Growth).

Warwick has therefore already been subject to significant recent Urban Fringe development and population expansion, a large proportion of which is in South Warwick where the majority of further development is now proposed. (PO1 Level of Growth).

As it stands, we wish to object specifically about the development zone 2 in the area of restraint to the west of Europa Way. This area was identified as an area of restraint at the time of the agreement of planning for the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa, to prevent the two towns becoming one urban sprawl.

There is likely to be considerable job creation towards Coventry (PO3 Broad Location of Growth), including up to 14,000 new jobs at the Coventry Gateway scheme. Therefore several extra thousand people per day will want to drive through Warwick, morning and evening, which would lock up the highly congested Myton Road, Banbury Road and Europa Way at peak times and also the road layout of historic Warwick. (PO14: Transport).

The suggested improvement to the junction to the end of Myton Road and Banbury Road is redundant. The bottle neck of the narrow historic Avon Bridge, constrained road layout and traffic


calming in the Town centre, means such provision would not ease the current backlog along Myton Road at peak times. (PO14: Transport).

The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and onto the M40 will have the opposite effect at the eastern end of Myton Road with the addition of Morrisons and the proposed trading estate and Aldi supermarket all exiting out onto the double roundabout system.

Development of this particular site will have a profound impact on the area where the roads are already gridlocked for a considerable period every day during school term, not to mention the excessive pollution that would be caused. It is currently possible to queue from the M40 into Leamington and the length of Myton Road in both directions with queues heading down the Banbury Road and Gallows Hill. Narrow side roads off Myton Road, in particular Myton Crescent, are blocked by parking making it difficult to negotiate these roads as the schools come out.

There is no capacity on these roads for another 1,500-2,000 cars to exit from this triangle at peak times and join the current traffic load plus, extra traffic from other proposed developments needing to use these routes at peak times. The access to Warwick and Leamington from the site would be queued back even at a fraction of the proposed development.

There is no capacity for extra cars at the stations in either Leamington or Warwick town centres for commuters. This means additional traffic driving through Warwick at peak times to Warwick Parkway.

Furthermore, the land West of Europa Way is an area of rich agricultural land which has been under the careful stewardship of the Oken and Henry VIII Trusts. There are wide green hedges providing habitats for many species including woodpeckers, buzzards, bats, foxes, the occasional deer, as well as newts, hedgehogs etc. (PO11 Historic environment, PO15 Green Infrastructure).

This is the type of area that should be being protected for recreation and education and healthy food to have a positive impact on the quality of people's lives with the traditional land-based activities such as agriculture, new tourism, leisure and recreational opportunities that require a countryside location. By building dwellings on this land, we will have no countryside left in the urban areas to make use of to support healthy lifestyles through ensuring sufficient land is made available to all for play, sport and recreation without travelling out of the area.

Development on the area of restraint threatens the local houses with flooding. At present, during heavy rain, the runoff is slowed by the pasture and crops. It backs up by the Malins and is relieved into the Myton School playing fields. At these times both ends of Myton Crescent become flooded with the current drainage system being unable to cope.

Property in Myton Crescent was flooded when development was carried out on the Trinity School site. Developing the Myton side of the site would threaten all of the houses south of Myton Road. (PO18 Flooding and Water).

The most disturbing consequence of the proposed development of sites 2 and 3 is the danger to Public Health as a result of exposure to dangerously high Nitrogen Dioxide (N02) levels. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. In 2012, air quality remains in breach of these regulations, and will become toxically high with the increased traffic volume resulting from the Local Plan preferred options. Please see weblink: http://aqma.defra.gov.uk/action-plans/WDC%20AQAP%202008.pdf. (PO12 Climate Change; PO14 Transport).

It was pointed out at the public meeting in 2009 that the areas designated to phase 3 at that time may not be needed for development in the future so why is this area, the worst area for infrastructural needs and more importantly an area of restraint put into the first phase for building?

This should, with immediate effect, be designated as the last site to be developed so as to protect this area until a viable alternative is found.

The further urban fringe development of Warwick is unsustainable with respect to saturated infrastructure, constrained historic town layout, and the existing Public Health danger that exists today as a consequence of high traffic volume.

Current infrastructure including town centre rail stations, schools, GP surgeries, sewage, water, drainage are at capacity with the current population, and will not sustain the proposed increased numbers within the Myton proposed sites 2 and 3. (PO2 Community Infrastructure levy).

Numbers have reduced drastically in schools over the years with those such as Trinity and North Leamington moving to smaller sites and a number of primary schools having given over part of their accommodation for other uses whilst village schools have closed completely. This means that the schools in this area are oversubscribed, including Myton in whose catchment area the whole of that site would fall.

There are suggestions that schools would be expanded or new builds created but a new primary school was in the plans for Warwick Gates which never came into fruition.

The hospital is completely surrounded by housing and has no capacity for expansion so how will they cope with another 25,000 people based on the figures of 2007 with 71% in a traditional family set up with 1.8 children.

Why do district councils have to accommodate a certain amount of housing? Should the government not just be looking for appropriate sites for building? At that same meeting in 2009 the suggestion of a perfect site around Gaydon was mentioned for a new town but the response was "It's not in Warwick District". Not only would road improvement be possible where air quality is not already in breach of regulation but this site is perfect for links to the M40 and there is also a rail station already at Kings Sutton on the main Birmingham to London line so commuting traffic would not be funnelled through Warwick's congested urban centre. To build one whole new site would be more cost effective in the long run. There is also the possibility of more use being made of the land around Warwick Parkway, which is in Warwick District and again perfect for rail and road links to both Birmingham and London.

So what can be done to accommodate the Core Strategy?

How about looking at sites already within the towns and regeneration areas? The infrastructure is already in place and could take out a large number of the dwellings required. We know this would not be chosen as great big swathes are cheapest but not necessarily the best option.

Build student accommodation near Warwick University in Coventry and return the hundreds of dwellings (including Station House with over 200 student flats) in the South Town of Leamington to private affordable starter homes and family homes.

Villages could be given their communities back - expand them with affordable housing. Let those that grew up in the villages and wish to remain there, stay there. Let them support the village schools and shops, some of which have closed over the past few years due to lack of numbers or use.


The original Strategy stated that 90% of the population live in the urban areas and 10% in rural areas. The paper work shows that the whole of the 8,100 houses still required are to be built in the urban areas. This will take the figures to 95-96% living in urban areas compared to 3-4% in the rural areas as there appears to be no allocation of any of this building to take place in villages.

The 90% of the district's population currently living in the urban areas occupy 10% of the district's land whilst the other 10% of the area's population live within the remaining 90% of the land.

The Core Strategy stated that there should be limited development within and adjoining villages so that they can be protected and the character of the villages kept. This is also the case within the towns. It is not that long ago that Whitnash was a village but is now a town along with Leamington, Warwick and Kenilworth. These towns want to remain separate towns. They do not want to become joined and eventually become part of Coventry as the way Edgebaston, Hall Green, Moseley and Sparkhill are to Birmingham.

Although the Core Strategy points out that the development will be directed towards the south of the urban area to avoid incursion into the West Midlands Green Belt area and hence becoming part of Coventry it is encouraging the joining of the towns of Leamington, Warwick and Whitnash, making it one urban sprawl.

It has been said that Warwick District in 2026 will be renowned for being "A mix of historic towns and villages set within an attractive rural landscape of open farmland and parklands, that have developed and grown in a way which has protected their individual characteristics and identities, ..." If this building work is allowed to go ahead as it stands, it will be far from that.

We also urge Warwick District Council to consider the overwhelming number of objections received from Warwick residents at the last consultation 2-3 years ago.

An era of austerity dictates that profligacy can no longer be tolerated. Spending constraints are a
necessity with budgets at all levels. The following comments are submitted to address this particular
aspect.
Significant development opportunities have been neglected in favour of a financially wasteful
scheme. It has been nigh impossible to find the logic for the planning decisions made. Glossaries
and Source References in the published material appear to have been 'lost in translation'; and public
access to detailed Planning and Survey documents is limited.
No objective audit of Housing Need (quality and quantity), appears to have taken place. Equally
lacking is an audit of Existing Development Opportunity, including canvassing and incentives for
Windfall Sites offered up for consideration now or for release within the next 15 years. If demand
for these new houses is a fiction, then they will blight the area and depress market values generally
for the whole of the District. Added to which Employment Opportunities cannot be guaranteed for
the budgeted influx of additional people.
In South Leamington, we have the near perfect basis for a 'Transport Hub', based on the existing
Railway Station. Similarly, there is a 'Commercial Hub' already in existence immediately adjacent
to the 'Transport Hub' extending to the Warwick Gates development, just begging to be extended
and developed. So why have Planners shied away from exploiting these remarkable assets and
advantages ?
The selection and use of large areas of Greenbelt land for development is irresponsible, being
contrary to accepted National and Local policy. 'Very Exceptional Circumstances' have not been
demonstrated, nor can they. Once this land has been developed it is lost to all for ever, depriving
those living in the District, of a much loved green lung and offering opportunity for quiet, peaceful
recreation in an attractive environment close to Leamington Spa. This unacceptable sense of
impending loss is not confined to those living in the two parishes or those adjacent to them !
Large areas of the best local Agricultural Land, in a very sensitive area, have been selected for
development regardless of the ultimate consequences, they include :
a)
The loss of land devoted to Food Production.
b)
Irreparable damage to the local ecosystem, comprising the watershed to this loop of the Avon.
c)
Reduced separation between Leamington Spa & Kenilworth and the loss of separate identity.
d)
The present attractive gateway to North Leamington Spa will be significantly diminished.
The Social, Economic & Environmental losses incurred by developing this land far outweigh the
gains, particularly when it is perfectly clear that there are realistic and preferable alternative
development options, - but see later.
It is generally acknowledged that World demand for food fast approaches the tipping point, where
demand is set to exceed supply. This can only accelerate under the influence of Global Warming,
Climate change and the detrimental effect on Weather Systems. This in turn introduces the
circumstances leading to significant international conflict. It follows that UK food production must
be stepped up and be geared towards greater self-sufficiency. This is the only way to avoid serious
food shortages the like of which most cannot contemplate and which few UK residents, alive today,
have experienced.
At least one thriving Farming Business will be seriously damaged and its viability put at risk.
Further loss of Greenbelt land is threatened, as the planned development unfolds identifying sites
for the supporting commercial development, new road systems and infill. This is only hinted at in
the Local Plan, but it is an inevitable consequence. This further encroachment on Greenbelt land
could destroy as much Greenbelt land again.
Two road developments are contemplated, both of which are unnecessary and will achieve little.
The dual carriageway proposed for the A452, can only transfer congestion from one place to
another, slightly more quickly. The proposed new Northern relief road (additional to the A46 ), can
only realistically be used preferentially by those living in the houses comprising the proposed new
development in Blackdown and South of Old Milverton Lane.
Although the planners state the cost of this exercise will fall to the developers, an ambiguity is
apparent signifying there will be a cost over-and-above that met by the developers, which can only
fall ultimately on Rate Payers; this element has not been quantified. The allowance for the Northern
Relief road of £28m seems unduly small bearing in mind the problems faced in driving a road
through a large area prone to flooding, together with the construction of a new bridge over the
Avon and probably a new bridge over the Railway (or significant re-enforcement of the existing
bridge). The additional unknown costs will inevitably fall to Rate Payers.
The most important financial/economic consideration is that despite the recently established
comprehensive infrastructure South of Leamington; it is now proposed to develop North of
Leamington which will involve the construction of new roads and a whole new infrastructure to
cater specifically for the 1,980 houses intended. This is an extravagance which cannot be justified.
Infrastructure includes the major services, Water, Gas & Electricity, Sewers, Roads, Rail, Canal,
Recreational & Faith facilities, Schools, Supermarkets, Restaurants, Public Houses, etc. All are
successful and well established in South Leamington and in many cases lend themselves to
expansion and development. How can it be sensible to duplicate much of this North of the town,
only to exacerbate the existing traffic and parking congestion by encouraging unnecessary cross
town interaction ?
Access to major road and public transport networks seems to have been largely ignored in deciding
where to develop. Access to the M40 and Rail Network looms large in any sensible planning
decision. The Mainline Rail Stations and Coach Services have seemingly been ignored. Housing
and Workplaces (requiring large work forces) ought to have been considered for location within
walking/cycling distance of Leamington, Warwick, Warwick Parkway and Hatton Railway Stations.
All this emphasises the imperative to develop South, East and/or West of Leamington, even if solely
for the one consideration of access.
It will not have escaped notice that Windfall Development opportunities within the towns and
villages have been ignored. They appear to have been 'airbrushed' out of existence. There are
significant areas of Whitefield & Brownfield sites available. There are areas of prime redevelopment
opportunity constantly offered up. The old Fire Station, the old Ford Foundry,
redundant schools, the many empty shops constantly referred to in the local newspaper as a disgrace
and a blight on local communities. Past Planning decisions in this and other towns have resulted in
most town shopping centres becoming a ghost of a previous existence through the enabling of 'out
of town shopping centres'. So why not re-populate town centres, at basement, ground and above
ground level ? Flats over shops have long had an appeal for the young and those relying on public
transport. This way of living is accepted as 'normal' in London and other major towns and cities.
If it is seen as particularly desirable to have the major part of the new development largely in one
piece, for community identity, sharing infrastructure costs, services etc. The Prince Charles inspired
'Poundbury Development' urban extension to Dorchester offers a useful model. What is wrong with
building a 'Royal Poundbury' style extension' to Royal Leamington Spa ?
There are two natural sites for such a development. One to the East, between Radford Semele and
Cubbington; another to the West, between Warwick Parkway and Hatton Stations. Achieving this
requires the application of objective contemporary problem solving for planning decisions fit for the
longer term; and with the Environment, People & Communities, for once, given the consideration
they deserve, rather than pandering to the wishes of Developers, Architects, Planners and Politicians
who so rarely live in the houses they cause to be constructed for others to inhabit.

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.