C. Development on Brownfield Land

Surely there are more villages than this. Even if they take 1 or 2 homes. This may help keep young people in villages with affordable housing.

All brownfield land should be fully exploited

If development of greenfield or greenbelt sites is as necessary as the plan suggests then it should be used to revitalise ebbing rural communities rather than isolate them further.

JPC supports this proposal

Use as much brownfield as possible

Yes - please use up as many brownfield sites and SAVE OUR PRECIOUS GREENBELT!

With regard to the structure of PO4, the relationship between points A (allocated sites) and C (development on Brownfield land) needs to be clarified, as it appears to suggest that the Council will be looking to introduce a policy that promotes the development of brownfield sites before the allocated sites. Paragraph 17 of the NPPF promotes the effective use of land by reusing land that has previously been developed, but does not go as far as suggesting that brownfield sites should be prioritised over the release of greenfield. Refer to representations attached.

yes build lots of houses on this land

Development of brown field land first is a no brainer - no matter what the developers may think. Also as they generally tend to be in existing conurbations these sites are ideal for a high proportion of affordable/retirement accommodation

brownfeild sited offer the best solution for increased urbanization

We strongly support the use of brownfield development and believe more should be done to increase its availability

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.

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.

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

See attached letter

Following a presentation of WDC's Local Plan in Bishop's Tachbrook, I have several objections and suggestions regarding the Housing Preferred Option and other matters.

Housing:
With reference to the map P04 Preferred Option sites for expanding housing include sites numbers 2,4,10, 11,12 & 6. These sites will provide land for a proposed 3800 homes. Extrapolating the number of people that will live in these new homes there will be an additional 14 to 15000 more people living South of Leamington and Warwick. These extra people will put a massive burden on the infrastructure such as roads/bridges to gain access to the Town Centres' and emergency services. The Bridge in Warwick and Leamington are already at maximum usage during rush hours and in my opinion would be overwhelmed by this massive increase in population. According to the Preferred option on transport infrastructure there is no provision to build more bridges over the Rivers Leam and Avon. What's more the entrance to Warwick from the south via the Banbury Road will be blighted by such a massive housing estate and will have detrimental effect on tourism.

Furthermore the development (Woodside Farm, Bishop's Tachbrook; area Number 11 on the Preferred Option map) would have a high adverse visual impact as it is prominent ridge and would impair the visual approach to Leamington.

The lack of infra structure provision was also a major objection to the last Preferred Option in the previous spatial framework housing plan. I agree there are now fewer houses envisaged 3800 as against 4500 but the same criticism applies Ie. the excessive strain on existing facilities.

Alongside new housing must be provision for upgraded infrastructure. When previous housing expansion took place, namely Warwick Gates, we in Bishop's Tachbrook, suffered lack of water pressure and problems with sewage because no pumping station was built for a number of years. Road infrastructure too was overlooked causing major problems at the
Tachbrook/Harbury Lane cross roads. Ditto the exit from Gallows Hill onto the Banbury Road. Improvements to these road junctions took many years after the houses and business park were built. Major expansion of the factories at Gaydon has created a huge traffic increase with consequent problems (and fatalities) by vehicles trying to exit Tachbrook on to the Banbury Road. In addition there is also a problem at rush hours caused by vehicles using Bishop's Tachbrook as a rat run.


The decision not to build a new infants school at Warwick Gates caused and still creates major problems with bus access to the school in Kingsley Road (Bishop's Tachbrook) because children have to be bussed here from Warwick Gates.
Infrastructure is either neglected all together or takes many years to implement; meanwhile existing residents have to live with the misery.

The new Preferred Option I believe will cause major problems owing to the bridge bottlenecks in Leamington and Warwick and lack of concrete plans to enhance infrastructure to cater for the increased population.

If more housing is required there must be adequate infrastructure built in parallel with housing construction. The proposed Developer Infrastructure Levy will certainly not pay for new bridges or better health provision etc. And waiting for the increased population tax revenues to pay for it will take far too long, leaving existing residents to suffer severe curtailment to the quality of their lives.

I would also question the need to build 555 houses per years from 2014 -2029. The ONS and economic projections based on historical growth rates do not take into account the envisaged stagnation in economic growth throughout the UK for the foreseeable future plus the negative growth effects of an ageing demographic. Apart from Jaguar Landrover at Gaydon most of the envisaged commercial expansion is planned for the Gateway area around Baginton/Ryton. This would entail commuting again from South of the Rivers to the North, further compounding traffic problems over the aforementioned bridges. Therefore it would be better to build more housing nearer the Gateway Area

Also there is a "Green" imperative that demands fewer commuting miles by car in order to reduce emissions etc.

In addition, building more houses attracts more people i.e. it is a self-fulfilling strategy, not based on projected growth grounds alone. As Leamington/Warwick is an attractive area more people will move here to take advantage of the new housing and the increase in population would in turn diminish the attractiveness that created the initial demand and further increase commuting miles out of the area to other centres of work.

If more housing is required (the number should be far less than the projected 555 per year) it would be best to maximize all available brownfield sites in the suburban areas. It was a great pity that yet another supermarket was granted permission to build a giant shed on the old Ford Foundry site when this entire area could have provided an admirable housing development.
Brownfield sites that would provide excellent housing are:
1. The old telephone exchange in Leamington
2. Garage opposite Covent Garden multi story (Leamington)
3. Quarry Street Dairy Milverton
4. Linen Street car park (Warwick)
5. Police station Warwick
6. Fire station (Leamington)



Housing continued...

Further sites
Land could be released for housing at Bubbenhall and Baddesley Clinton if they were classed as Category 1 or 2 villages


GREEN WEDGE
The proposed Green wedge stretching from Radford Semele, between Harbury Lane & Bishop's Tachbrook to Banbury Road should be extended Southwards to encompass Oakley and surrounding area.

In addition, I would like to reaffirm opposition to any plans to revive development between Harbury Lane and Bishop's Tachbrook as was proposed in the previous Preferred Option

We are writing to object to the proposal for 3,330 new houses in Warwick. In objecting we refer to the National Planning Policy Framework which "aims to strengthen local decision making and reinforce the importance of up-to-date plans".

Population Growth

The NPPF states that there should be a clear strategy "taking account of the needs of the residential and business communities".

Why has the number of 10,800 new homes (up to 25,000 more people) been proposed which is the same number as proposed in the Core Strategy and was strongly resisted by Warwick District Council at that time? The West Midlands Regional Office was vehemently criticised by WDC for producing these flawed and untenable figures. Your figures do not comply with WCC population figures and are therefore unreliable. A 40% increase in Warwick's population over 15 years is clearly unsustainable and will cause immense damage to the character of the County Town. Migration from other areas into Warwick's more attractive green environment has produced most of the population growth. The provision of more houses will encourage more migration and Warwick will no longer be an attractive area. The new Plan should cater for LOCAL needs not migration into the area. You have included figures to cover an increase in students but they should be housed near the Universities not in the District, especially in south Leamington. Increasingly high concentrations of students in certain areas is an issue of concern.

Regarding your assumptions on the demand for housing, given that more than 50% of national population growth has been from immigration over the last two decades, and the government has publicly stated it wishes to greatly reduce this future net immigration, why is Warwick District planning for an even greater level of growth over the next 15 years, than has been experienced in the recent past? Warwick District population has increased by 12% since 2000, which is approximately twice the rate of increase for Warwickshire, twice the national average increase, and over three times the increase for West Midlands. Warwick has had its fair share of development over the years with major estates at Warwick Gates and Chase Meadow (with further development allocated), Hatton Park, along the Myton Road and many other infillings. This is far greater than other areas in the District and history has shown that the necessary infrastructure has never been put in place. The NPPF (48) states that Local planning authorities may make an allowance for windfall sites in the five-year supply". 1,224 properties have planning permission or a planning brief at the moment and yet you do not appear to have taken these into consideration. This would equate to a two-year supply of houses. We do not believe our authority has identified and brought back into residential use the 300-400 empty houses and buildings (NPPF 51) to the extent they should have done.

We believe that the only motivation for WDC producing such figures for demand is the income that will benefit WDC in New Homes Bonus, rent, rates, council tax monies etc.

Brownfield Sites

The NPPF (111) states "Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land) provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land."

So why are we not making it a priority to develop brownfield sites first and regenerate poorer housing in urban areas? The Ford Foundry site is a prime example of revitalising an eyesore of a brownfield site to vastly improve the area and bring it back into good use. There are many more examples of brownfield sites in Warwick District which could be regenerated.

Gypsy Site

We suggest the land adjacent to Junction 15 of the M40 might be a suitable site. There is little nearby existing housing, but a public bus service and good road access

Green Belt

The NPPF (79) states "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."

An incredible 37% of the 11,000 homes proposed for Warwick District are to be built on the land south-east of Warwick, covering nearly all of the green space between the Banbury Road, Greys Mallory, Europa Way, Myton and the Technology Park. This would mean estates more than three times the size of Warwick Gates, Woodloes Park or Chase Meadow!

The NPPF (76) states "By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances". "Once established, Green Belt boundaries should only be altered in exceptional circumstances." (NPPF 83) Yet your reason for allocating development on Green Belt is that "there is nowhere else to build" (your quote at the Warwick Society Meeting).

NPPF (88) states "When considering any planning application, 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.." The exceptions given in NPPF 89 and 90 do not apply in your proposed Local Plan. Our Green Space is already designated.and we are objecting to this scale of development which will undoubtedly impact negatively on the character of Warwick and the quality of life of existing residents. Why are we facing urban sprawl rather than the housing being spread equitably around the District as you stated was your aim? The previous Core Strategy stated that 90% of the population live in the urban areas and 10% in rural areas. Yet in the new Plan less than 10% of housing is proposed for villages, some of which, such as Barford, would welcome more homes including low-cost housing to build up sustainable communities with schools and facilities and meet the need for affordable rural housing. Those that grew up in the villages and wish to remain there would then have the opportunity to do so. We would propose that at least another 1,000 could be spread around the villages and the number proposed for Warwick reduced.

The area to the west of Europa Way was identified as an area of restraint at the time of planning 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. The District has 85% green belt but 45% of this is to be built on, thus reducing the gap between conurbations. The green space threatened is valued rich agricultural land, essential for food self-sufficiency, environmentally precious landscape with many wildlife habitats and biodiversity including badger setts and also prevents coalescence which you declare is one of your aims. Our existing green space provides open space, sports and recreation and such land, including playing fields, should not be built on!

Alternative Sites

The previous Core Strategy identified several other sites with potential for housing. Local villages where there are good transport links and the potential to improve road access should be developed rather than the urban fringe development of Warwick. The Warwick Parkway area provides a first class rail link. Hatton has a station and easy access to the A46 and Barford has immediate access to the M40 and A46. Two other areas of potential for large scale housing provision are Radford Semele and Lapworth which already have infrastructure to cope with further development, with good public transport, roads and a railway station.

This in turn would mean much smaller developments around Milverton and Warwick would therefore be required. Although you state that there are three gas lines near Bishops Tachbrook. I can see from the map that there is an area to the west which could take some housing whilst avoiding the gas lines. There are other areas which were identified in the Core Strategy options which have not been considered this time, such as the A46 corridor and further development at Sydenham. The commercial units at Sydenham have mostly closed and been boarded up and would offer an ideal brownfield site for development.

Yet your reason for allocating development on Green Belt, against the National Planning Policy Framework is that "there is nowhere else to build". This argument is totally flawed and I would expect the Inspector to find this Plan unsound if only on this issue.

The NPPF (17) states that planning should be "empowering local people to shape their surroundings."

Why has this amount of housing been proposed for South Warwick when the previous consultation on the Core Strategy produced a 97% response in overwhelming opposition to housing here (700 objecting to the Europa Way, Gallows Hill and Banbury Road area.. Why were those results not heeded when you devised the new Plan? These plans do not reflect the aspirations of the community as the Government intended in the Localisation Act.

 
Flood Risk

The NPPF (94) states that "Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk". Also "Local Plans should take account of climate change over the longer term, including factors such as flood risk....." and (NPPF 99) "When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure." We already have existing green infrastructure to mitigate against water run-off and flood risk but you are proposing to build on it!

The NPPF (101) states "The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic Flood Risk Assessment will provide the basis for applying this test." There are other available sites as already stated. "A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall." (NPPF 102) You have not carried out a Strategic Flood Risk Assessment before allocating these sites for housing.

Europa Way and an area to the south of Gallows Hill are in flood zones and at significant risk of flooding, yet housing is proposed in Flood Zone 1, adjacent to Zones 2 and 3. Areas at risk of flooding have always been designated areas of restraint but you are dispensing with these. More concrete on green fields here which currently soak up heavy rainfall must increase water run-off and impact on the areas of Warwick which already suffer from flooding, especially around Myton Road and Bridge End. This is contrary to NPPF 100 "Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere." The previous Core Strategy decided that this area may not be needed for development in the future being an area of restraint and the worst area for infrastructural needs. Development is not necessary in these areas of flood risk and should be avoided, certainly not put into the first phase for building. Home-owners would also face being turned down for insurance in postcodes where there is flood risk. This problem will possibly increase next year when the agreement between the Government and the Insurance Association ends. The Portobello development, built on a flood plain, is a prime example where many of the apartments are still unsold. This area you have designated for building is vital for flood alleviation and should not be built on at all. At the very least it should be the last designated site.

Density

Garden Town suburbs sound admirable but naiïve when you look at the number of buildings proposed and the impact on the environment. This concept did not materialise in Warwick Gates or Chase Meadow and developers will build at high density for increased profit margins. 1,100 houses were first proposed for Chase Meadow and now it is to be 1,600. WDC has no budget for tree maintenance and developers cannot be relied upon to carry this out, as we have seen in other recent developments. After 14 years Chase Meadow still has unadopted roads, only just received its link road to the local school and the prospect of a community centre for sports provision and social interaction. Developers will not be persuaded to build at 30 units per hectare and there is no means of insisting on this. This is just a red herring in our opinion, as are green wedges since you admitted that where these are proposed, you will be reliant on private landowners to permit their development. Once again, funding for this would be dependent on developers' contributions and these monies, being in short supply, would be diverted for other more essential infrastructure.

Why are we allocating housing for the Coventry Gateway project? It should be up to Coventry Council to provide for this. They should also provide more dwellings for Warwick University students which would free up hundreds of dwellings (including Station House with over 200 student flats) in the South of Leamington to private affordable starter homes and family homes. WDC have recently been forced to change their planning policy because of the problematic increase in HMOS in the District.

Infrastructure

The NPPF (17) states that strategies should "deliver sufficient community and cultural facilities and services to meet Local needs". Also (NPPF 162) "Local planning authorities should work with other authorities and providers to:

* assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demands and

* take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."

Yet you confirm that infrastructure will not be put in place before building commences but that you hope that infrastructure will be provided from developers' contributions, whilst admitting that this may not raise enough to cover escalating costs of new roads, bridges, schools, extra health provision, policing, fire service, community centres etc. If left to developers, history has shown this may not happen. Infrastructure needs will then be prioritised and some areas may miss out. You have admitted that infrastructure proposals will be prioritised and there will be a cut-off point when the money runs out. We have seen no architects' proposed site plans showing each area with all the necessary infrastructure in place. You have provided no idea of potential costs at all. You have provided no results of studies at all. Warwick has already lost its police station and fire station, roads are completely congested at peak times, schools are drastically oversubscribed and have no places (particularly Myton which is the catchment area), the hospital is at breaking point and cannot cope with the load, having day surgeries and evening clinics to clear backlogs and lack of parking leads to innumerable late attendance for appointments, and the police haven't a clue how they can cope with more communities. Utilities such as water, sewers, electricity provision will have to be provided at escalating massive cost.

CIL

The NPPF (175) states "Where practical, Community Infrastructure Levy charges should be worked up and tested alongside the Local Plan. The Community Infrastructure Levy should support and incentivise new development, particularly by placing control over a meaningful proportion of the funds raised with the neighbourhoods where development takes place."

You have not provided information on these charges at all. We do not believe that there will be anywhere near the amount of funding available from CIL to cover the above extra infrastructure needs, especially new roads, bridges, schools and hospital.

 
Air Quality/Traffic

The NPPF (17) states that the Plan should "support the transition to a low carbon future" and contribute to "reducing pollution". Also "Local planning authorities should plan for new development in locations and ways which reduce greenhouse gas emissions." (NPPF 95)

The NPPF (17) states that policies should "recognise town centres as the heart of their communities and pursue policies to support their viability and vitality". (30) "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion". Also (NPPF 124) "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

The traffic congestion that Warwick already suffers will increase by a possible 6,000+ extra cars from extra South Warwick housing alone, let alone the increase from 10,800 new homes, bringing with it increased pollution in areas where air quality is already over the limit. 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. Air quality remains in breach of these regulations and will become toxically high with the 27% increase in traffic volume resulting from the Local Plan preferred options. There is no management plan to address these levels. The County Council admitted that air quality will suffer as carbon emissions will increase in surburban sprawl. You admitted that you did not know how the carbon emissions could be reduced by the 20% currently necessary. It therefore seems incredible that the large-scale housing developments on the edge of Warwick are suggested with a likely 40% increase in the town's population, over 15 years. This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?

The NPPF (34) states that "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised." "A key tool to facilitate this will be a Travel Plan" (NPPF 36). All developments which generate significant amounts of movement should be required to provide a Travel Plan". We have not seen such a Travel Plan.

Myton Road, Banbury Road and Europa Way are all highly congested with long queues or at a standstill at peak times including the Town centre and often emergency vehicles cannot negotiate a way through, even via the pavements. If the closed Warwick Fire Station were to be relocated at Queensway, their vehicles would experience increased problems and response times would be worsened. There is a suggestion that Europa Way could be widened but this would exacerbate bottlenecks when the traffic reaches the roundabouts. The County say they can mitigate but not contain the resulting increase in traffic and admit there are places where congestion will worsen.

Historic Environment

Pinch points at bridges cannot be alleviated and the 300-year old Castle Bridge already carries 20,000 vehicles per day and cannot sustain an increase in traffic without threat to its very structure. We should be trying to reduce this traffic to prevent the bridge collapsing, not increase it. The NPPF (112) states "As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional." The precious historic and listed buildings in Warwick are being damaged by traffic vibration and pollution and this problem will only worsen. Increased commuting traffic must not be funnelled through Warwick's congested urban centre. Danger to schoolchildren and others is currently problematic on our roads and will be exacerbated near schools such as at Woodloes and Aylesford/Newburgh.. We are given no concrete proposals for new roads, only ideas. A North Leamington relief road suggestion could cost £50million+ and the idea that the A452 could be routed to the Fosse - one of the most dangerous roads in the County is preposterous. The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and on to 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 on to the double roundabout system. The present Plan does not address these traffic problems sufficiently and should be "refused on transport grounds where the residual cumulative impacts of development are severe (NPPF 32).

Conclusion

You state that in 2026 Warwick District 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....." In our opinion this could not be farther from the truth.

The above comments demonstrate that this Plan is seriously flawed. It is not specific to the needs or the character of this area and the necessary infrastructure is not deliverable. We believe the Planning Inspector will declare it unsound. It cannot be justified as "the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence" and it is not "Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework." (NPPF 182)

This Plan should be completely revised taking account of the above, specifically reducing the numbers of housing proposed for Warwick.

I look forward to your response to the comments contained in this letter.