The Location of New Housing

I don't believe that the necessity for this many new houses is justified.
There also seems to be a considerable amount of development on green belt at the edge of existing towns, rather than regeneration of disused town centre sites.

Makes sense

7.18 appears to point to an easy option of further expanding urban areas in favour of adding to rural areas in small manageable patches because it would make it "difficult to make the fullest use of public transport"

The location of houses on green belt is wrong. The exceptional circumstances that are required to change the existing green belt have not been demonstrated.

Brownfield sites and green field sites outside the green belt should be used in preference to green belt land, except in Kenilworth as the town is surrounded by green belt. The defunct Core Strategy planned to make more use of land in the Whitnash/Bishop's Tachbrook area for housing. If those sites were appropriate for development then, they are so now. One suspects they have been excluded from the Preferred Options because of political pressure.

Far too much of the proposed development is on precious green belt land. There are nowhere near good enough reasons or strong enough justications given here to make this proposal acceptable. The level of growth is too high, there is no proof that its required at all, and it is clearly against the wishes of local people (58% wanted a much lower level of growth than this from previous consultations). Listen to the views of local people and please please preserve the precious green belt. Once its gone, its gone for ever. Its a wonderful asset and gives so much rural character to our towns. It makes Warwickshire what it is - a beautiful county.

The preferred options do not give credence to the National Planning Policy Framework or established planning policy. This states that development in the green Belt is inappropriate (except for LIMITED infilling) and that using previously-developed (brownfield) land should be encouraged. This is not at all clear or followed in this Option and is therefore a serious flaw. There must be a clear sequential test that prioritises brownfield land and uses Green Belt as a very last resort, if at all.

The plan must show flexibility and the sequential test should be ongoing throughout the 15 years to ensure that as high a proportion as possible is developed on brownfield land.

Development has to be supported by infrastructure. Therefore I support more the creation of new large developments where the critical mass of development necessitates new items such as roads, drainage, schools, health and local amenities. These should be located on the edge of current urban areas to facilitate the use of sustainable transport methods. Piecemeal development that expands villages is not sustainable.

The earmarking of dozens of small sites in village locations is punitive when it is not likely to be necessary. Therefore these should not be included at this stage.

I support phasing. Phase 1 should be brownfield only including proactive regeneration, mainly in urban locations. Phase 2 should be the same.
If the target number of houses is reduced to match the requirement that the latest data shows to be necessary then only 292 homes need to be built in greenfield areas. This should be the last phase and only happen if the population numbers show that it is necessary.

COMMENT

A total of 10,800 new homes are proposed to be applied to three separate year periods that make up the 18 years of the plan (2011-2029); as the plan will not be implemented until its adoption in spring 2014 this effectively means that the overall housing provision is to be applied to three separate 5 year periods that make up the remaining 15 years of the plan following adoption.

Unfortunately no explanation is provided in the plan as to why the Council considers it appropriate to phase housing delivery and what the anticipated benefits would be in following such an approach. Having regard to the SHLAA (May 2012) and potential housing trajectory (Chart 7.1) it would appear that the sub-division of the plan period is an estimate, based on current data, of how long it may be expected for development momentum to pick-up and on the earliest practical delivery of the larger site allocations. We also recognise that phasing can have an important role to play in helping ensure that new development keeps pace with infrastructure delivery. Nonetheless, even if the above is the reasons for introducing phasing in the plan, we would like reassurance from the Council that it is not intended act as a cap and/or a break on housing delivery where infrastructure necessary to support the planned development is either already available or planned to be delivered in parallel with proposed new housing.

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.

Introduction

The Warwickshire Branch of the Campaign to Protect Rural England (CPRE) is a charity registered No 1092486 with over 700 members in Warwickshire. CPRE is very concerned about many aspects of the New Local Plan Preferred Options agreed by the Council on 21st May 2012 and now published for consultation.

Firstly we give our response to the main Preferred Options. We then examine key issues on the Vision, projected growth, population growth assumptions, the Green Belt, and the proposals for employment.


The Preferred Options (PO1 to PO18)


PO1 Level of Growth

We strongly oppose the level of growth of 555 houses/year that PO1 proposes. The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and much of this is by windfall development within the urban areas.

The proposals to impose 100 houses on each of five villages would damage their rural character and unbalance their structure.


PO3 Broad Location of Growth

The proposal is 'growth across the District' including on Green Belt, and in villages. No direction of growth or focus on particular broad locations is proposed. This is contrary to the policy of previous Structure and Local Plans. Those plans protected Green Belt and identifed key locations while ensuring that urban land was re-used, and villages were only asked to accept limited new housing.

No clear reason for the change from past Local Plans has been offered. As those have been successful, the policies and patterns of development that they provided for should be maintained in the new Local Plan.
The extent of windfall development and use of brownfield land in Warwick and Leamington has been high for many years. There is no reason to depart from the practice of encouraging these forms of development.


PO4 Distribution of Sites for Housing

PO4 proposes a large number of greenfield housing sites which are currently Green Belt or greenfield. Most of these would not have been considered at all acceptable in past Local Plans, and we strong oppose the following sites, because they would require release of land from the Green Belt or would affect historic landscapes (such as the approach to Warwick around the east side of the Castle Park).

Sites:

3. South of Gallows Hill, west of Europa Way : harms setting of Castle Park and approach to Warwick from the south
4. West of A452 Kenilworth Road, between Northumberland Road and Old Milverton Lane - Green Belt, and essential part of the open countryside separating Kenilworth and Leamington
5. Blackdown - open countryside, which if developed reduces the separation between Kenilworth and Leamington by a quarter
8. Red House Farm, Lillington - Green Belt, visible land facing southeast
9. Loes Farm, Warwick - extends Woodloes Estate into Green Belt, and undermines tight planning control on north side of Warwick
13. 100 houses in each of 5 villages - this is an arbitrary imposition. Individual villages should be able to determine how much development they wish to accept.
14. 350 houses in smaller villages - there is no basis for such a figure, and most smaller villages should only accept 5-10 dwellings over 15 years if their rural character is to be ensured.

We also believe that Site 6 South of Sydenham, is too large an allocation and only a smaller development should be considered; that Site 2, Myton / West of Europa Way, is high-grade farmland protected from development under past Local Plans for its agricultural value, and its loss would be the end of the remaining green wedge left when employment land was developed east of Europa Way; and the scale of Green Belt release for Site 7, Kenilworth (Thickthorn) needs to be reduced. If these sites are released, this should be only after brownfield sites have been developed and windfall potential within the urban areas has been assessed.


PO5 Affordable Housing

CPRE supports the policy of 40% affordable housing which is carried forward from the 2007 Local Plan. It is strongly opposed to the part of the policy which would allow private sector developments in villages to fund affordable housing. If affordable (rented) housing is permitted in villages, this must be only following a sound assessment of local need, and should not bring with it housing for sale simply to provide funds for the affordable houses.


PO7 Gypsies and Travellers

CPRE supports finding an official site for gypsies. The numbers to be accommodated need reassessment against new policies: some gypsies have property elsewhere, and do not need to live in caravans. CPRE would propose that the gyspy site at Siskin Drive, just inside Coventry, be enlarged or re-sited in the Middlemarch employment area, so that part at least meets the needs of Warwick District.

PO10 Economy

CPRE opposes the provision of employment land north of Leamington on Green Belt. There is no need for major new employment land identification in the District. Surplus employment land and buildings in the towns come on the market continuously and can generally be re-used without any need to allocatec new greenfield land.

There is no shortage of employment land in Warwick District. In a recession, with economic difficulties meaning that land for employment becomes surplus, loss of existing sites to housing is more of a problem than any lack of new greenfield sites.

North of Leamington, proposed in PO8, would be an unsustainable location for employment development. It would be outside the town centres where the focus of employment is supposed to be; it would generate much car traffic; and the main transport routes through the District are south not northof Leamington.

The proposal for the Coventry Gateway around Coventry Airport has no economic justification: it would not be relevant as an employment site for most who live in Warwick and Leamington, is not easy to reach from Warwick District's urban areas, and would compete with the Ansty and Ryton employment locations nearby which are in Rugby District.

Established and new small businesses rarely need any planning permissions for their commercial activities.

Our conclusion is that no development of new employment land in the Green Belt is justified.


PO11 The Historic Environment

The existing (2007) Local Plan contains clear policies to guide conservation and decisions on developments that affect a Conservation Areas. This set of Policies should be generally carried forward, without any simplication (which can cause ambiguity).

A Policy to make the lengths of the Grand Union Canal and Stratford Canal in Warwick District into Conservation Areas is needed. Other Districts with extensive lengths of canal have created linear conservation areas.


PO14 Transport

The proposed new road links and road widenings in the Preferred Options would be harmful to the Green Belt and tend to encourage more car traffic. That would create unsustainable patterns of movement and increased car depenency. By contrast the proposals for the bus network are thin. They focus on Park & Ride provision which is not of importance to residents of the towns.


PO16 Green Belt

The Preferred Options would require major removal of land from the Green Belt for urban development. It would also require the removal of 'washed-over' status of some smaller villages which are currently covered by Green Belt designation. The very special circumstances required to be demonstrated if Green Belt land is to be released for building have not been shown to be justified.




The Key Issues


1. Vision and Growth

1.1 The key aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This reflects a current focus in national government thinking and speeches by Ministers. It fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years.

1.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

1.3 CPRE believes that there should be a much more careful balance between development and the environment than the Preferred Options would achieve. The proposed scale of development would risk being unsustainable and contrary to the NPPF policy that supports sustainable development.

1.4 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

1.5 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.


2. Sustainability

2.1 The National Planning Policy Framework (NPPF) at para 49 sets out the principles of sustainable development. The NPPF says that Sustainability has three aspects, environmental, economic and social. The Preferred Options pay little attention to the environmental aspects of sustainability.

2.2 The term 'sustainable' is used about 120 times in the full Preferred Options report, but this is mostly in relation to economic aspects of sustainability.

2.3 We do not believe that large-scale destruction of open countryside is sustainable development - it is unsustainable. Once lost it will never become available for future generations.

2.4 We acknowledge that a few mentions of sustainability in the proposal do relate to the social aspects such as providing sufficient of the right kinds of housing and facilities.


3. The Projected Housing Requirement

3.1 CPRE is strongly opposed to the proposed level of housebuilding advocated in the Preferred Options.

3.2 The justification for this level of housebuilding is weak, for the following reasons.


1. The ONS projections for Warwick District are arbitrary and probably overstated. They do not yet take account of likely reductions in net migration to the UK or the potential effects of the recession. They assume in-migration at recent levels although this is now reducing rapidly.

2. Projections for individual local authorities are notoriously unreliable because they do not take into account the implications of planning and other policies. Already the 2011 Census (issued in summer 2012) shows that the growth of population in the last decade given at para 4.2 of the preferred Options is nearly 50% too high. Population growth 2001-2011 was not 14,800. It was 10,000 from 2001 to 2011 (126,000 to 136,000).

3. House building rates in Warwick have been very low over the past five years and are likely to pick up only slowly. The rate of housebuilding proposed by Warwick DC in the Preferred Options is well above the rate achieved in the last 10 years and on current economic trends is unachievable.

4. The work by G L Hearn / JGC at Appendix 2 of the SHLAA does not lead clearly to any particular level of population, household or employment growth. Their projections are highly volatile, depending on a range of key assumptions.

5. From statements in the Preferred Options, and made at public meetings during consultation, it seems that Warwick District Council has decided to seek a relatively high level of housing development in the mistaken belief that it will help to boost economic growth. There is no overriding need for major new employment development. If population grows rapidly, it is more likely to result in a change in the balance of commuting, with more Warwick residents working outside the district.

6. The consultants' work on translating population growth into household growth is inadequate. It assumes too high a vacancy rate for new housing stock and fails to consider sharing and institutional population.

3.3 We have other major concerns about the population projections.

3.4 In its commentary on the projections, the Office for National Statistics says - 'Projections are not forecasts and do not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. They provide an indication of the impact that changes in demographic patterns might have on the size and age structure of the population in the future.' Therefore the projections should not be taken literally.

3.5 There are particular questions over two of the assumptions made in the national projections:
* Net international migration, which makes up roughly half the projected population increase, is likely to reduce in future, reflecting a tightening of government policy on this issue. This change will not yet have been picked up by the projections;
* Although there is little sign of this yet, birth rates may fall as a result of the recession and the slow recovery from it.

3.6 The Preferred Options forecast that Warwick District's population will grow by 21,600 between 2010 and 2026, and from this a requirement for about 9,390 extra dwellings is produced. (The average household size would stay at 2.3 persons.) This produces a rate of building of 587 dwellings per annum, not achieved in any past year for some decades

3.7 The suggested rate of building, at 550 dwellings per year, has not been achieved in the District for some decades, if ever. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The Government predicts only a slow recovery from the recession, with a gradual increase in house building rates. Therefore it could be many years before the Preferred Option's desired rate of house building can be achieved, and the past record suggests that it will not be achieved.

3.8 In an earlier consultation in September 2009 Warwick District Council asked for public views on three scenarios for numbers of houses. These were 200 per year, 500 per year and 800 per year. 51% of the public chose 200 per year. Despite this result the Preferred Options propose that over 500 houses be built annually.

3.9 The net in-migration element in the forecast housing requirement is large - 57% of the population growth forecast by the Council's consultants (in the SHMA) would be the result of net in-migration. However in-migration has fallen fast in the last 2 years and there is no clear reason why it should be provided for. If more houses are built, given the location of the District on the M40 and Chiltern Railway route, more inward migration will take place. There is not an objective need to provide for or seek inward migration.

3.10 We consider that the Preferred Options housing figures should be reduced substantially; the 2011 Census results and latest migration data be taken into account, and an objective need recalculated instead of assuming that in-migration should be planned for.


4. Proposed Locations for Housing


4.1 CPRE believes that a number of the major new housing locations proposed would be harmful. See response to PO4, Distribution of sites for housing.

4.2 The NPPF at para 109 states that "the planning system should contribute to and enhance the natural and local environment". This militates against development in the countryside and favours protection of landscapes, animal and plant life, public footpaths and Scenic Views. Further research would identify valued landscapes, geological conservation sites, soils ecosystems, impacts on biodiversity and ecological networks.

4.3 NPPF para 112 states that Local Planning Authorities should take into account the economic and other benefits of the best and most versatile agricultural land and should seek to use areas of poorer quality land in preference to that of a higher quality. Much of the land around Leamington is 'best and most versatile' agricultural land. This places a presumption against its loss to development.

4.4 Clearly any use of green land will require destruction of hedges, ponds and other habitats of animals and plants. It is likely to destroy public footpaths. It will certainly affect the views of countryside which are currently available to visitors, walkers and residents at the edge of the existing built-up area.

4.5 The area of the district which is not in the Green Belt is generally to the south and east of the built up area. While there are constraints here, and location (3) is wholly unacceptable, there is scope for some development at the locations previously considered in the 2009 Core Strategy.

4.6 Three pipelines run to the south-east of Offchurch, Radford Semele and Bishops Tachbrook, but not through the area of land adjacent to Europa Way or between Whitnash and Bistops Tachbrook, so do not appear to be a significant constraint.

4.7 There is some scope for more housing at Hatton Park which has been a successful development that maintains a 'washed-over' Green Belt status.


5. The Green Belt.


5.1 In para 79 of the NPPF, it is stated that "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence."

5.2 Para 80 sets out five purposes of Green Belt. The West Midlands Green Belt to the north of Leamington and Warwick and the south of Kenilworth meets four of the five purposes:
* It prevents urban sprawl
* It prevents towns merging
* It is assisting in safeguarding the countryside from encroachment
* It assists urban regeneration by encouraging recycling of derelict and other urban land.

5.3 NPPF para 83 states that confirmed Green Belt boundaries should only be altered in exceptional circumstances. We are far from convinced by the arguments that the boundaries should be altered. The sole reason appears to be to spread the pain of development on greenfield sites across the District. This is not a planning justification which satisfies the need for exceptional circumstances.

5.4 NPPF 84 makes it clear that sustainable development to be channelled towards urban areas inside the Green Belt boundary and towards towns and villages inset within the Green Belt boundary or towards locations beyond the outer Green Belt boundary.

5.5 As in other parts of the report we see clear conflict with the Localism agenda of the coalition government. The Localism Act gives communities, including neighbourhoods, towns and villages, a procedure for determining for themselves what development should take place and where it should be located.

5.6 NPPF para 87 states "as with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances".

5.7 NPPF para 88 states that "local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations".

5.8 Taking extensive Green Belt land out of the Green Belt and proposing it for housing is the opposite of a sustainable development policy.



6. Employment Land Proposals

6.1 CPRE supports a low-carbon economy; but it has a very long timescale, and must be developed but we are concerned that the proposed Preferred Options will not enable this. In particular, we question the proposal to "distribute development across the district". Established towns (and nearby cities) offer critical mass where homes and jobs can be developed in a balanced way supported by infrastructure such as public transport.

6.2 Substantial development in the countryside, such as the proposed major employment at the Coventry Gateway site, would increase the need to travel with the vast majority by private car. The Preferred Options recognise the importance of the need to reduce travel (e.g. in section 8.30) but do not seem to apply this principle consistently.

6.3 Major development in the countryside would make the principle of "developing an effective and sustainable transport package" very difficult to achieve and undermine the agreed principle of regeneration of urban areas. We support the preferred option (in PO3) to concentrate growth within urban areas but we are concerned about significant development in villages and rural areas.

6.4 We recognise the need to provide land for employment to meet proven local needs but are concerned about the proposed principle to provide land to "encourage the creation of jobs". Sustainable jobs are critically dependent on factors such as people, skills and finance, not just buildings or land. Increasingly, attracting skilled people and knowledge-based businesses to an area is dependent on the quality of the environment: somewhere people want to live as well as work. The social and environmental strands recognised in the NPPF are as important as the economic strand.

6.5 It is essential to keep employment balanced with housing: over-statement of housing numbers leads to over-statement of the need for employment land. We object to the over-allocation of housing (proposed in Section 7.22) to support the proposed Coventry Gateway, which has not been justified.

6.6 We note (from sections 8.21 and 8.22) that the Preferred Options propose some 66 hectares of employment land in the period from 2011 to 2026 and that 43 hectares have already been identified. For the remaining 23 hectares, we agree with the urban-brownfield-first priority and agree with the approach of locating employment with housing where new housing developments are really justified.

6.7 Compared to the remainder of 23 hectares of employment land over 15 years, the Coventry Gateway proposal amounts to over 97 hectares in one rural location in the early years of the strategy period. Such a volume of over-allocation would be indefensible and should not be considered as part of a balanced plan.

There is already a regional investment site at Ansty Park. It has fully developed infrastructure and yet currently vast tracts of empty land off blocked-up site roads. Empty buses frequently serve the mostly-empty site; it has excellent access to major highways but too few occupiers. The duty for local planning authorities to cooperate should mean that this site is supported by WDC rather than undermined with a competitive development in the Green Belt just 8km away.

6.9 Recent planning studies and processes have concluded that there is no need for more employment land in Green Belt. The Inspector's Report for the Examination in Public of the Coventry City Council Core Strategy (April 2010) concluded "There is no current need to allocate any additional employment land outside the city boundary, over and above that available at Ryton, to meet the overall economic objectives of the CS".

6.10 The Warwick District Employment Land Review of April 2009 concluded that "there is an oversupply of land suitable for the development of general industry/distribution that is already committed/allocated in the current Local Plan to accommodate demand in these sectors". The Addendum dated January 2011 noted a continuing decline in demand for B2 and B8 floorspace. While the 2009 Employment Land Review did identify a potential deficit of land suitable for office development, it identified "the area around south west Warwick and Leamington as most attractive both in market and planning terms". The 2011 Addendum noted decreased demand overall but also decreased completions, recommending further study. The earlier preferred development directions remained unchanged.

6.11 These plans and studies confirm there is no need for development of Green Belt land for employment. The plan numbers are backed up by experience on the ground, where for example the ex-Peugeot site at Ryton-on-Dunsmore has been vacant for 6 years and Ansty Park has struggled to find occupiers. We recognise that the Ryton site is in Rugby Borough but paragraphs 178 to 181 of the NPPF make it clear that local authorities must cooperate when drawing up Local Plans. The NPPF confirms that the Government attaches great importance to Green Belts, supports 'brownfield first' and reasserts that inappropriate development should not be approved except in very special circumstances. Need for development has not been proven and there is no evidence of valid special circumstances that would justify development in the Green Belt.

6.12 The Preferred Options consultation document picks up the claim that the Gateway "has the potential to provide in the region of 14,000 jobs" (section 8.33) even though this number is not justified and falls partly within Coventry. There are many examples of large, speculative developments where job creation assumptions are inflated and over-optimistic. New developments can remain half-finished for many years because demand proves to be far lower than anticipated. That would be a particularly damaging outcome for a large development with a devastating impact on the Green Belt to the south of Coventry. The number of jobs 'created', put forward by developers, cannot be relied upon as a measure of sustained economic benefit.

6.13 There are better ways of achieving more and better-quality employment. This is to put the emphasis on technological advance and the proposed "Emphasis on infrastructure": investment in communications technologies for rural areas in order to support small businesses and home offices. Broadband for rural communities continues to fall behind urban areas so rural businesses are increasingly uncompetitive. A well-wired rural community would help achieve both the low-carbon economy and the rural economy objectives. It would also make the district a better place to live and work for knowledge workers.

6.14 Finally, all the evidence indicates that in Warwick District no new development of employment land in the Green Belt is justified.

1. Level of Development required.

The assumptions for the overall growth of the housing market in WDC was taken prior to the recent publication of the 2011 census results which showed a smaller than expected population for the area, This means the the growth for the period 2001 t0 2011 was less than expected. If this lower than expected growth continues then the demand for extra development in the area should be less than that in the Plan. To add weight to this the figure of 550 new homes per year has never been achieved in a single year let alone for 15 consecutive years. This whole section should be reviewed in the light of the new figures.

2. Sources of Development Land

The level of brownfield site allocation seems to be low. These sites have appeared more frequently in the past and the migration of industrial sites from town centres is by no means complete. We hope that this area could be reviewed.

3. Allocation of new Greenfield Development Land

The allocation of 10% of the development land to the rural areas seems suspiciously arbitrary and appears to be a political decision to "share the pain". Similarly the selection of 5 "larger" villages to absorb 100 new homes is decidedly arbitrary. Firstly, the 5 selected villages do not have any special characteristics over a number of other villages or rural conurbations. The exclusion of Cubbington, Leek Wootton, Bubbenhall and the Hatton Park/King Edwards conurbation seems perverse. Secondly, the choice of villages which are deemed to have the infrastructure to take the extra development puts extra strain on the existing overburdened infrastructure, especially traffic in these areas. An alternative route, to expand the areas with poorer infrastructure so as to improve the quality of life in these areas does nopt seem to have been considered. In the case of Hampton Magna and Hatton Park/Kings Meadow and the West Warwick (Chase Meadow) developments, Hampton Magna's facilities are used in great measure by the other two conurbations. An improvement in their local facilities would improve the quality of life in their communities and relieve the strain on the facilities in Hampton Magna, We use this example as we are well aware of our local situation and feel that there may be other areas that also have other communities that are acting as cuckoos in their nest. This strain on the infrastructure of existing communities could be lessened by improving the infrastructure in the satellite communities by the application of CIL money generated from a modest expansion there.

The New Local Plan has to be evidence-based. The arbitrary choice of the five villages, the arbitrary allocation of the same numbers in each of them and the the policy of adding to the already straining infrastructure of these villages rather than improving the infrastructure of those suffering from lack of amenities all show a lack of being based on any evidence at all . We hope that this whole section could be reviewed

4. The situation of Hampton Magna

Hampton Magna was built on a 1960s brownfield site to wit the Royal Warwickshire Barracks at Budbrooke. It was built in the late 60s/ ealrly 70s and so is in its fifth decade. As such it has well defined historical boundaries, ie the Barracks perimeter. There has been a little infill over the years and the Parish Council invited Warwickshire Rural Community Council to carry out a Housing Needs Survey which identified a need for 5 houses in the Parish. The need for further development is not locally required nor, according to the Parish Plan is it supported by the local residents who gave their views in a long questionnaire that formed the basis for the Plan.

The basic built infrastructure of Hampton Magna has changed very little from the the early 1970s when the building of the houses was completed. The village is served by C class roads that link us to the Warwick/Birmingham road and Warwick/Henley Road. The electricity supply is very similar to that supplying the barracks and the sewerage system was put in by builders during the period of "the lump". The school has bee extended, but is, in essence, still the standard 1960s/70s building that is seen all around the county.

The roads leading to and inside the village become very busy at the peak time, in the morning and evening. The locally generated traffic is increased by the use of the C roads as short cuts from the Birmingham Road to the Henley Road and the A46 and the M40 at junction 15, and by traffic going to and from Warwick Parkway Station. The A 4177 at Stanks roundabout which is the main exit/entry to the village is severely congested every morning and afternoon.

The electricity supply is frequently interrupted for a shorter or longer periods, showing the fragility of the current arrangements

The sewerage system was not adopted by Severn Trent Water Authority until privatisation, when the Authority agreed to adopt the system prior to flotation. The system has not been improved and one of the areas where the system was extended to accommodate a few new house frequently suffers from problems.

The school is very popular and has recently had its standard number increased. Whilst this has improved the viability of the school, it has also lead to a great deal of school time traffic congestion at the beginning and end of school.

The infrastructure of Hampton Magna in these areas is at the limit of its usefulness. There is little that can easily be done to improve the local traffic situation, because of the need to cross canal and railway lines. We are not aware of any plans to improve the electricity or sewerage system locally. The introduction of such a large number of house into this village would lead to a complete overload of these services. We hope that you will look again at the need to use this village as one of the villages for expansion and will take a more pragmatic approach, allowing infill in non village areas and improve the infrastructure in other areas.

5. Overall

The residents of Hampton Magna have long been strong supporters of the green belt, not just around Hampton Magna, but throughout the District. There is a deep suspicion of moving green belt boundaries and if any such changes do prove necessary anywhere in the District it should be done with clarity, leaving no area for doubt or future challenge.

My objections are on three main grounds. Firstly, that the preferred options are based on fallacious reasoning and hypothetical statistical models. Secondly, that they will result in irreversible damage to the Green belt. Thirdly that they are grossly undemocratic and not in keeping with the spirit of the Government`s National Policy Planning Framework.
Fallacious reasoning
1. They use a statistical model prepared by a commercial company, Cambridge Econometrics in conjunction with IER at Warwick University, which uses data given by the District Council, although the company themselves admit there are few official figures for measuring the factors they input. The public has not seen that data, and it is hard to see why the District Council expects there to be so many jobs suddenly appearing in this area. Is their reasoning that if you build houses, the jobs will follow?
2. In PO1they claim their preferred level of growth between 2011 and 2029 is 10,000 dwellings ie an average of 600 p/a. Even if we were to accept this figure then they would have an overprovision of houses by 3,710 if they develop all the sites they have proposed. (ref 5.18 the SHLAA "identifies potentially suitable sites within and on the edge of built up areas. Taken together, these sites would be able to accommodate an estimated 11,410 new homes. In addition, it is estimated that further windfall sites could accommodate around 2,300 new homes.")
3. There is a sudden jump from the scenarios which were presented to the public to an ad hoc rejection of the first scenario on the grounds that "This level of housing would lead to an overall reduction in the number of jobs in the district (or increases in out-commuting)" (ref 5.14) and Projection 3 Employment growth with continued commuting is rejected because it doesn`t allow for a balancing new homes and jobs. You cannot insist that employers only take on staff who live locally any more than you can insist that people only take the jobs that are available in their area! They make the same mistake when providing employment land among the Blackdown development on the grounds that there is a `deficit` there.
4. The lowest projection in Table 5.2 is trend based, but there is no particular reason to believe that the increase in net migration of recent years will continue. In fact if these proposals go ahead it is likely that the area will no longer be attractive to newcomers and many established residents will move away. The other projections are based on the hypothetical model -the West Midlands Integrated Policy Model already mentioned. Paragraph 5.22 admits that the model`s projection "is likely to be optimistic since it was carried out in 2010 and forecast an increase in employment from 2011. Bank of England GDP projections in August 2010 anticipated continued, albeit slow, growth from a low point in February 2009. However, ONS data has since revealed that the rate of increase of GDP has been falling since mid-2010 and has yet to show signs of recovery."
5. Point 5.23 says "housing would need to be met largely on strategic Greenfield sites on the edge of the built up areas. This would be necessary in order to deliver the required infrastructure." This seems an instance of lifting themselves up by their own bootstraps- such massive infrastructure changes would not be necessary with lower levels of growth.
Irreversible Damage to the Greenbelt
The NFPP in `Protecting the Green Belt` states (ref para 8.8) "When considering any planning application, Local Authorities should ensure that substantial weight is given to any harm to the Green Belt. `Very special circumstances` will not exist unless the potential harm to the Green Belt is clearly outweighed by other considerations."
Of the five purposes served by Green Belt outlined in the NFPP, the proposals to alter Green Belt boundaries will cover the first two, but not the last three.
1. The third principle - to assist in safeguarding the countryside from encroachment- will not be addressed. The Council claims there are clear boundaries but in the case of the Blackdown development, for instance, the boundaries would include the Westhill Rd and the Stoneleigh Rd. At the moment there is a clearer boundary- ie the A445, a major road from the M1 and Rugby into Leamington, yet if the building goes ahead this boundary will have proved insufficient to prevent encroachment onto the Green Belt, so it is unlikely that the minor roads will fare any better. That District Council have their eye on further encroachments of the Green Belt is also revealed in 8.33 in a discussion of Coventry Gateway, where they quibble about the proposed location and want to `explore the case for releasing land in the Green Belt.` The Coventry Gateway would be a huge industrial complex, yet they want to destroy Green Belt for it, presumably because they are competing with Coventry City council.

2. The changes also will not address the fourth principle- to preserve the setting and special character of the historic towns of Kenilworth, Leamington and Warwick. The new developments described as `garden suburbs` will be clones of those in other overdeveloped towns. How can they `ensure viability and deliverablity` (para 173 NPPF) and expect to provide 40% affordable housing but architecturally innovative buildings (as recommended in the NPPF) and at the same time `provide competitive returns to a willing landowner and willing developer`? In his ministerial foreword to the NPPF, Greg Clark says, "Our standards of design can be so much higher. We are a nation renowned worldwide for creative excellence, yet, at home, confidence in development itself has been eroded by the too frequent experience of mediocrity." The District Council`s plans for the Green Belt are set to repeat the experience of mediocrity again.

3. Nor will they address the fifth principle-to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Although the Council mentions brown field sites it does not mention any sites arising from Para 51 "local Authorities should identify and bring back into residential use empty housing and buildings and where appropriate acquire properties under compulsory purchase orders". Surely this should be adhered to in an island as small and densely populated as ours?

4. The Council`s justification for using Green Belt land 7.15 claims "the Joint Green Belt Study carried out an assessment of the Green Belt around the towns and on the edge of Coventry. The findings showed that there were variations in the quality of land in the Green Belt and therefore some areas around the towns may be considered for development and therefore, removed from the Green Belt". This is extremely misleading. The remit of the Joint Green Belt Study was to rank the areas, any ranking involves some areas ranking at the bottom, but this does not mean they are not good quality areas and it does not imply they are more suitable for development than areas outside the Green Belt. The NPPF states "Plans should allocate land with the least environmental or amenity value" not least value in competition with other areas in the Green Belt.

5. The Council`s rejection of other proposals (ref 7.18- dispersing development on small/medium sites) claims it `would be impractical in terms of the number of sites that would have to be identified` `Further, this pattern of development would make it difficult to make fullest use of public transport, walking and cycling`. These are allegations with no evidence to back them up.

6. Similarly 7.19, while admitting that `the sustainability appraisal of the options showed that the option for focusing development outside the Green Belt had clear advantages associated with the provision of sustainable transport and reducing the need to travel. However, there would be significant impacts on the historic and natural environment due to such a high concentration of development to the south of the towns due to increased cross-town traffic.` What is the evidence?

7. On the other hand the proposal to develop the North Leamington Relief Road from the A46 to the Sandy Lane A445 roundabout will funnel yet more traffic onto the Lillington Rd into town- a road which is very congested already. The `virtual P&R carpark` and non-bespoke 2- stage buses pay lip-service to looking for a solution, but looking at it realistically, most motorists are not going to get out of their comfortable cars, wait in the rain for buses that don`t go exactly where they work, at times that don`t suit them. There is already a very good bus service from the Blackdown area but the buses are virtually always empty.

8. Point 112 of the NPPF states that "Local Planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land." The fields proposed for development in Blackdown and Old Milverton are extremely fertile and yield excellent harvests year after year. The NPPF says that councils must also look at the bigger picture and future food shortages are one of the biggest.

9. Although the District Council have copied sections from the NPPF about the Green Infrastructure into their Local Plan, they show little environmental vision. For instance, there is no mention of developing renewable energy (para 17 Core Planning Principles NPPF).

Lack of democracy
In his ministerial foreword to the NPPF Greg Clark says,
"Planning must be a creative exercise in finding ways to enhance and improve the places in which we live our lives.
This should be a collective enterprise. Yet, in recent years, planning has tended to exclude, rather than include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them."
This is an apt description of what continues to happen in Warwick District. The consultative period is very brief, and hardly any of the people living in the Blackdown area had even heard about the proposals. It would have been simple to let everyone know, in the same way that we are kept informed about waste collection plans, yet the District Council chose not to do this.
In March 2011The District Council consulted the public in `Helping Shape the District`. They have rejected the growth levels wanted by 90% of those consulted and have set their sights on very much higher growth than the majority voted for. Point 69 of the NPPF says, "The planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Local planning authorities should create a shared vision with communities of the residential environment."
Yet in para7.14 the District Council says `The "Helping Shape the District" consultation exercise carried out last year highlighted much concern about the levels of development which might be required to meet the District's housing needs and the impact this would have on the character and setting of the towns. Many felt that increasing sprawl around the existing towns would damage the rural setting of the towns to the detriment of both their economies and their environment. The Council will require new development to follow the emerging garden suburbs principles in order to overcome this loss of rural characterand facilities they wish to see. ` The Council fails to see that the `garden suburbs` would not in the least overcome the problem.
Again, para 155 of the NPPF says, "Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged so that Local Plans, as far as possible, reflect a collective vision and set of agreed priorities."
It is time that the District Council took these principles onboard.

It was with great disappointment that I learned of Warwick District Council's proposed plans to develop green belt north of Laemington Spa.

I spent most of my childhood and early adulthood living, learning and working in Warwickshire. I have come to appreciate the inherent value in green belt, which has preserved the rural setting and individual character of countless towns, villages and hamlets throughout Warwickshire and Great Britain.

Green belt is of particular value where towns and villages are in close proximity. Leamington Spa, Warwick, Kenilworth and the surrounding villages are prime examples. Yet in reckless contravention to decades of successful green belt policy, Warwick District Council has proposed plans for wholesale development of parts of this very area.

Not only will this infuriate the electorate, it will substantially undermine the rigor to which green belt policy can be applied in the future.

I am against this proposal that would result in erosion of the rural aesthetic.
I am against this proposal that undermines decades of successful green belt policy.
I am against this proposal that does not have general local support within the electorate.

We wish to state that we strongly oppose the WDC preferred options for building on agricultural and Green Belt land in the areas of Old Milverton and Blackdown.

Your proposals go totally against the Governments National Planning Policy Framework for development in the Green Belt.

As we understand it: -

Proposed Old Milverton and Blackdown Housing Development

The Green Belt designation is there to preserve the rural character & aspect of the surrounding areas between Leamington Spa, Kenilworth and Cubbington.

To prevent the merging of currently developed areas and stop urban sprawl.

To retain areas that residents and visitors enjoy in the pursuit of walking, running, cycling and other outside activities.

To play a role in tackling climate change, in conjunction with the countryside beyond the Green Belt Boundary.

The GNPPF clearly states, there must be Very Special Circumstances for the Green Belt to be considered & put forward for development.

We do not believe that any of the criteria in the framework is met for Very Special Circumstances to be applied.

The development in both areas is inappropriate and will harm the green belt.

You have not shown or demonstrated how your reason to develop the Green Belt does not harm the Green Belt/the habitat of wildlife/ the rural aspect or state how it will be for the better of the current local residents of both areas.


What surveys have been carried out on the wildlife population and the impact of hedges, ditches and streams being removed and lost in both areas?

We as a nation are importing more and more food for ourselves and feedstuffs for our animals which just increases our carbon foot print.

We need to retain all agricultural land in Blackdown and Old Milverton.

This is good high quality agricultural land none of which is lying dormant or derelict.

You will be taking away our local Farmers' lively hoods.

You do not say how your current preferred option outweighs the proposals put forward in your previous 2009 Approved Core Plan. In that plan no Green Belt was incorporated.

Why is the already designated White Belt not incorporated in your 2012 proposals?
This is a vast area surely a large part of this should be used.

You state you wish to retain green spaces and green belt between existing Towns, villages and current developments. You do not apply this wish to the already developed Hamlet of Blackdown on the Stoneleigh Road.


New and Upgraded Roads

We are appalled that the option includes a new road linking Blackdown and Old Milverton to the A46 at Leek Wootton. We cannot even start to accept that this road will serve any good purpose.

The new road will again cut through precious green belt, agricultural land and wildlife
Habitat.

What are the consequences and cost of building on a natural flood plane?

This new main road to the A46 together with the proposed Leamington to Kenilworth Dual Carriageway upgrade and the Stoneleigh Road upgrade will bring all Leamington Spa bound traffic from the A46 and B4113 to merge at the Blackdown Island.

The existing single carriage road leading into Leamington Spa from the Blackdown Island will not be able to cope with this additional traffic even when upgraded.
You will create a massive grid lock on most mornings and evenings at the Blackdown Island.

This together with the proposed new housing in Blackdown and Old Milverton will only add to the enormous morning and evening current traffic problems by bringing more and more cars into an already congested area.

The Park & Ride system will not help this situation. People who own a car will use them and not wait for a bus.

Stoneleigh Park

We note you do not mention in your booklet the site on Stoneleigh Park that is designated by WDC as a Major Development Site.

When will we be informed about the development plans for this large area?
Should this not be part of your local plan 2012?

We understand that La Salle at Stoneleigh Park have plans for road improvements to give a better flow to the A46.

You should be joining forces with them to plan and develop a separate link to the A46.
This would ease the traffic problems at Stoneleigh Park, Stoneleigh, Blackdown and Chesford plus other local roads and areas.

Look at the route of the HS2, B4115 to A46. A parallel road could be built.

The cost would be substantially lower than the estimated 28M for the Northern Relief Road and not destroy additional land.

It would also mean that persons can travel to the A46 or M40 without coming through Blackdown, Old Milverton and Leamington.

Other Questions/statements

What surveys have been taken to identify derelict properties and areas within Leamington itself?

What steps are being taken to contact owners of properties that have been left empty for many years? Many of which are becoming an eyesore.
These properties should be brought back into use.

We have an office in Station Approach Leamington Spa and have just received a neighbour planning application for a permanent car park in Station Approach.

This land has been identified as building land on your May 2012 Local Plan.
The Car Park should retain temporary status.
We will be objecting to this application.

See attachments

See attachments

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Extra care housing and use class C2 and C3

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Heritage and Culture matters

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Rural accommodation

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you for consulting with the Home Builders Federation (HBF) on Warwick's local plan preferred option.

The HBF is the principle representative body of the housebuilding industry in England and Wales and our representations reflect the views of our membership of multinational PLCs, through regional developers to small, local builders. Our members account for over 80% of all new housing built in England and Wales in any one year including a large proportion of the new affordable housing stock.

We would like to submit the following representations on the draft Local Plan.

Plan period

It would be helpful if the local plan clearly stated the period of time over which it is intended to operate. This should be stated on the front cover and in the first paragraph of the introduction, as well as elsewhere in the document, including the section that addresses the housing need over the plan period. We assume that the plan period proposed is 2011 to 2029 although this is not altogether clear.

Section 5: Preferred Level of Growth

It is encouraging to see the Council taking the correct approach to establishing a housing requirement that is in conformity with the NPPF (hereafter referred to as the Framework). It is the function of the SHMA to assess the full housing needs of the district over the proposed plan period.

We note the three scenarios for setting a future housing requirement. Inevitably, given the uncertainties regarding the economy, relying on any one employment-based scenario as the basis for setting a housing requirement could prove too inflexible in the event that the district (or adjoining districts) experience higher levels of employment growth than projected by a particular scenario. We note that option 1 allows for 600 homes a year, while option 2 allows for 700 homes a year. Option 3 has been discounted because the projected increase in jobs would not be matched by the increase in homes (paragraph 5.19).

We do have some qualms about assuming that there is a direct relationship between new jobs in the district and the demand for new homes. The relationship may not be as strong as the Council thinks, and to some extent, the demand for housing in the district will come from people who work elsewhere, typically in the larger employment centres of Solihull, Coventry, Birmingham etc.

We note that the Council's preferred level of housing growth is for 10,800 homes over the plan (PO1: preferred level of growth). This is inadequate since it is lower than the most recent household projections and the evidence from the most recent SHMA (2012). It also fails to take into account the decisions of adjacent local authorities.

SHMA (2012)

The SHMA indicates that the annual need for affordable housing will be 698 homes per year (paragraph 7.50). This exceeds the proposed option, and, significantly, only addresses the affordable housing need, not the demand for market housing. The report does not appear to have assessed what the market need will be in the district in addition to this affordable need. As such, the SHMA does not satisfy the requirements of the Framework, paragraph 159.

It is unclear how the three modelled housing scenarios relate to the requirement of the Framework for the SHMA to identify the scale of housing needed over the range of tenures, including housing demand (paragraphs 47 and 159). It is unclear whether the figure of 698 affordable homes per year relates to the three scenarios since it exceeds two of them and is almost comparable to the third. The SHMA needs to set out what the quantity of need is for market housing and affordable housing over the plan period.

The Council has not explained in its Preferred Option why it is choosing to discount the evidence of need identified by the SHMA. It would appear that the Council is relying upon the argument that because the SHLAA can only identify land for 11,410 homes (paragraph 5.18). This, however, would be to pursue an capacity-based approach to determining the future housing requirement of the district, rather than using the new plan as an opportunity to review the efficacy of existing policies and constraints and consider the possibility of removing these in order to meet the level of housing need identified in the SHMA. A capacity-based approach would be contrary to the Framework, as the expectation is that the Council will do all it can to meet objectively assessed needs (see paragraphs 14, 17, 47, 179 and 182).

Household projections

The 2008 based household projections indicate an increase of 13,000 households over the period from 64,000 in 2013 to 77,000 in 2028 - a period that is approximately comparable to the proposed plan period of 2011 to 2029. This is a figure that approximates to option 2 - the projected employment rate scenario of 12,888 homes. The Council suggests that this employment projection is likely to be optimistic (paragraph 5.22) owing to the most recent ONS GDP forecasts. Nevertheless, the Council may be surprised, and economic growth, and consequently housing demand, may be stronger than it expects. If this is the case the plan will need to have the capacity to respond to rising demand. This would be in accordance with the Framework which expects local plans to meet objectively assessed needs and have sufficient flexibility to adapt to rapid change.

Furthermore, while we would not dispute the Council's current pessimistic economic prognosis, it is important to remember that housing demand is not solely related to employment. Warwick will continue to experience many more affluent households moving into the district who may work elsewhere and non-economically actives households will continue to consume housing in the more desirable locations. The Council will need to cater for these tastes, but also increase the overall level of supply in order that those on low to medium incomes are not priced out of the district by affluent incomers. Citing the recession as a reason to scale-back plans to accommodate more housing would also be contrary to the Government's new, more positive, planning agenda, as set out in the Ministerial Statement Planning for Growth which sees planning has playing a pivotal role in facilitating greater levels of growth.

Duty to cooperate

There is also the matter of the duty to cooperate to consider and how Warwick's plan will provide for its own unmet needs that cannot be addressed through the plan (paragraph 179 of the Framework) as well as potentially the unmet needs of adjoining councils (paragraph 182). If the council is unable to meet its objectively assessed housing need through its plan (once it has properly identified this, and once it has reviewed existing policy constraints) it will need to plan to ensure that these needs can be met elsewhere without the district. To do so, it will need to plan in concert with adjoining councils.

The draft plan appears to be silent on this question. We note that at least two of Warwick's neighbours - Solihull and Stratford Upon Avon - are advancing plans that will not meet their own 'objectively' assessed housing needs (although there is an issue with the soundness of their own SHMA assessments when judged against the NPPF). Solihull is proposing only 525 homes per year when its SHMA indicates a need for 904 affordable homes. Stratford is proposing a plan requirement of 7,500 homes yet its own housing requirements study recommends between 11 and 12,000 homes over the plan period. Clearly if Solihull and Stratford are not proposing to meet their own requirements then it is very unlikely that they will be willing to accommodate any of Warwick's unmet needs. This suggests that Warwick will need to fully accommodate it own housing requirement since it cannot rely on anyone else to pick up the tab.

The location of new housing

It is unclear why the Council feels it needs to phase the delivery of sites (paragraph 7.20). Surely, if all the sites have been assessed as being suitable for housing, and thus sustainable in terms of the Framework, it should be immaterial when these sites come forward for delivery.

PO5: Affordable housing

I am concerned that the Council is disregarding the evidence of its own viability study in setting an affordable housing target of 40% when the study would appear to indicate that a figure of 35% may be more appropriate. The Council maintains that it can ignore the evidence since it will be flexible in how it applies its policy to ensure viability. This would be contrary to the approach of the Framework which now requires that the cost of affordable housing policy and other policy requirements of the plan are deliverable and to ensure that these do not render developments unviable and thus the plan undeliverable.

This will require the Council to ensure that all its policies applied to be applied to sites, especially those earmarked to contribute in the first five years from the date of adoption of the plan are subject to a reasonable level of policy demands and planning obligations. The onus should not be placed on the developer to demonstrate viability but for the Council to ensure that the cumulative impact of all its policies and demands will ensure that the majority of sites, and especially all those earmarked for the first five years, are viable (see the footnote to paragraph 47 of the NPPF and pages 26 and 27 of the Viability Testing of Local Plans report).

We are also concerned that the study has not modelled-in properly the true costs of development, including those costs to be added to development by the proposed local plan. We note that the study has only factored-in the cost of building to Code 3 and Code 4, but building to the Part L Building Regulations (equivalent to Code 5) will be a requirement from 2016 onwards. This will represent a significant additional cost. The Council should refer to the most recent DCLG report: Cost of Building to the Code for Sustainable Homes: An update cost review, August 2011. This is a significant future but known cost that will impinge upon the viability of sites over the plan period but also in first five years, and must be factored into a new viability assessment (see page 26 of the Viability Testing of Local Plans report).

The viability assessment has also not taken into account the cost of building Lifetimes Homes which is a requirement of policy PO6. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of the requirement of policy PO12 for developments to provide on-site renewable energy plant to provide a 20% reduction in carbon emissions. A revised viability assessment will need to take account of the costs of doing so.

The viability assessment has not accounted for the cost of biodiversity offsetting which is a requirement of policy PO15. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of flood mitigation measures as stipulated by policy PO18. A revised viability assessment will need to take account of this.

The report uses BCIS costs, but this is based on Gross Internal Area and does not account for external and landscaping costs and local site works (see page 34 of the Viability Testing of Local Plans). A revised viability assessment will need to take account of this.

The figure for site acquisition costs is rather low at 5.75%. This is more likely to be between 6.5 to 7.5%. We would refer the Council to page 35 of the Viability Testing of Local Plans report.

The viability assessment also assumes a total planning gain package (S106 and/or CIL) of £6,650 per unit. This seems modest. I have commented previously on this in my letter to the council dated 20 September 2010 in which I recommended an average of £15k per dwelling is applied as a more realistic figure. Ideally the Council should prepare a CIL Charging Schedule alongside the Local Plan to ensure an integrated viability assessment and avoids the risk of the CIL setting an unrealistically high charge that has not been reflected in the viability assessment for the local plan. Under the current arrangement, if the plan was adopted, then the Council would need to ensure the levy of any CIL introduced after the plan, in combination with S106, exceeded no more than £6,650 per dwelling otherwise the plan would immediately be rendered undeliverable.

We are also unconvinced by the interpretation of the evidence. We do not feel that the council's conclusions are legitimate ones to reach since the evidence does not support the assertion that either 35% or 40% affordable housing is viable. However, this is really a matter of secondary importance compared to the need for the Council to undertake a Framework compliant viability assessment that takes into account the costs of development, local policies and plan requirements.

I HAVE RECENTLY READ THE LOCALPLAN PREFERRED OPTIONS SUMMARY MAY 2012 AND IF I WERE TO COMMENT ON EACH ITEM I AM SURE YOU WOULD NOT READ IT. BELOW I GIVE MY BRIEF FEELINGS OF YOUR PLANS FOR OUR FUTURE:

1. IF ALL THESE CHANGES BECOME A 'FAIT ACCOMPLI' WHICH I BELIEVE THAT IS WHAT THE COUNCIL WILL DO, IT WILL CHANGE THE WHOLE AREA AND NOT FOR THE BETTER.

2. THERE ARE SO MANY OTHER 'THINGS' THAT NEED ATTENTION TO SPEND OUR MONEY ON, AND I FEEL YOU ARE PERFECTLY AWARE OF THEM WITHOUT MY POINTING THEM OUT.

3. PUT THINGS RIGHT, REPAIR, ETC. ETC. EMPLOY SOME OUT OF WORK YOUNGSTERS TEACH THEM HOW TO PUT THINGS RIGHT. IT IS A MODERN FAULT WITH THE YOUNGER GENERATION, CHUCK IT OUT AND BUY NEW FOR ANYTHING THESE DAYS.

4. THIS IS A LOVELY COUNTY AND YOUR COUNCIL WILL SPOIL THIS AREA FOR ALWAYS IF YOU GO AHEAD WITH THESE PREFERRED OPTIONS.

I strongly object to the development proposed on green belt land north of Royal Leamington Spa for the following reasons.

National Planning Policy Framework requires "Very Special Circumstances"

* The fundamental aim of Greenbelt policy as set out in the Government's National Planning Policy Framework is to prevent urban sprawl by keeping land permanently open.

* The Government's National Planning Policy Framework requires there to be "very special circumstances" for development in the Green Belt. It also requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development. According to Warwick District Council the special circumstances are that there is nowhere else for the homes to be built.
* However, in the "2009 Core Strategy" (the previous plan adopted by Warwick District Council) land south of Leamington (not in Green Belt), was identified and is still available, for development. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure (roads etc) to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities South of Leamington as well as existing out of town shopping facilities and good access to the town centres.
* Therefore, the previous plan (the 2009 Core Strategy) is direct evidence that there are alternative areas for development other than the Green Belt and that the "special circumstances" put forward by Warwick District Council are wrong.
* Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt.

This email is to lodge my objection against the proposed new housing developments.
Having seen the vast areas land put forward for development across the local area, I am very dismayed how much Greenbelt land has been sacrificed.
I do not profess to be knowledgeable in the reasons why the council has chosen these areas, what I can see is that the green areas around our lovely towns will be disappearing at an alarming rate. I would be most interested to know why the meaning of Greenbelt does not mean anything anymore? At what point do we stop- when Warwick, Leamington Spa, Kenilworth and all the villages in between are one continual mass of brick,concrete and tarmac with a few trees planted on street corners, as a token gesture to a bit of greenery.
The NPPF clearly states the the purpose of Greenbelt protection is to prevent urban sprawl, but this proposal appears to positively encourage it. I do not believe that there are any exectional circumstances to warrant such large scale distruction of Greenbelt land.
Having seen the congestion recently by road works along the Cubbington Road and and the junction at Leicester Lane and Kenilworth road, I doubt if this area could sustain the increased traffic from a few thousand more vehicles.
At which point do we actually think of the bigger picture, not for now, but in the future. We need to take a step back, there must be alternatives, we can't put it back once we've taken all away

I am Leamington born and bred and at 68 years old it is not for my sake that I lodge my protest but for the children of the future and our town.

Over the years I have seen parts of our lovely old town taken away, once take they cannot be returned. Can we not learn from our mistakes?

Character is acquired over a period of many years. North Leamington is now developing into a unique part of the town. To remove the green belt from this area and replace it with housing and all the required facilities would take away the residence amenities for recreation and exercise, destroying a beautiful part of our town.

I appreciate we must build for the future. We have already developed a new area to the south which has all the facilities and infrastructure to accommodate new housing and required amenities without change to it's now established unique part of town.

You cannot have such a contrast of building in any one area. Character must be defined. Centre is Centre, Old Town is Old Town, North is North, We have Radford Road, Leam Terrace and Newbold, you cannot throw new into this mix. Europa way is new and this must be and continue to be New Leamington.

Leamington can expand and still remain a lovely town but please do not make the mistake of your predecessors and ruin parts of our lovely town.

Once again at my age I am still very concerned for the future of Royal Leamington Spa.

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.

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.

As scanned.

As scanned.

As scanned.

See attached

See attached