On the Edge of Warwick, Leamington Spa & Whitnash

I strongly object to the proposal to develop on the Blackdown and North of Milverton sites because it does not comply with the Government's National Planning Policy Framework for development in the Green Belt. In particular:
1) There are alternatives: the 2009 Core Plan catered for more homes than the current plan and did not involve development of the Green Belt between Leamington and Kenilworth.
2) It threatens the distinctive identities of Leamington, Kenilworth and Old Milverton by significantly reducing the green space between them.
3) It will destroy the lovely northern gateway to Leamington and Kenilworth - one of the things that make the towns desirable both to residents and visitors. Creating another Europa Way will threaten the vision the council has for the area.
4) The area has huge visual and physical amenity value. It is much used for walking, running, riding and cycling and significantly enhances people's quality of life - not just that of residents but also those who travel from around the area to enjoy it.
5) A new relief road through the development and bypassing Old Milverton would further encroach on this village and would simply encourage higher levels of car ownership and car journeys, at a time when we should be seeking to look at more public transport and cycling options. There is also the likelihood that it would simply provide a quick route for people to get onto the A46, to jobs and out of town shopping opportunities - contrary to the supposed vision of promoting thriving town centres. I am also shocked that this major proposal is given little, if any, mention in the Local Plan document itself.
6) It will violate an important nature corridor along the River Avon and involve construction on the flood plain at Leek Wootton.
7) Very importantly, it will result in the loss of a significant amount of high quality agricultural land. I have been dismayed at the lack of importance councillors at public meetings have placed on the value and importance of agricultural land. It may not be part of the definition of 'Green Belt', but this does not mean it should be disregarded or classed as 'unimportant'.

Sport England would not support any site which came forward for development where there would be a loss of playing fields unless it met the tests of paragraph 74 of the National Planning Policy Framework.

At a recent consultation meeting it was stated that houses were being built to support the new enterprise park to be located near Whitley, Coventry. If this is correct then why develop south of the river when you have to cross already conjested bridges? When asked if another bridge would be built we were told that it was too expensive, (developer funded). North of the river seems to be largely green belt yet south of the river land that could be developed. Do you not think you should review your total strategy as it seems somewhat flawed?

The numbers for Blackdown and Milverton seem out of proportion to the total; and no-one has as yet given the 'exceptional' reason for the Green belt to be used.

I am not totally opposed to some development in these areas but it will have to be properly justified and on a smaller scale than at presently planned.

In terms of the wider portfolio of sites identified for development in PO4, we note that over 60% of the housing required on the edge of Warwick, Leamington and Whitnash areas has been identified on just three sites. Whilst we have no specific objection to the inclusion of these sites, it does seem to us that there is an over-reliance on a small number of sites to meet the requisite number of homes over the plan period.

I object passionately at the complete disregard WDC has for the views of the residents of Whitnash. What was a really pleasant village, was developed into a town and it is now planned to become absorbed into the Leamington/Sydenham/Radford Semele conurbation which robs Whitnash residents of their identity.

The developments of past decades have continued to rob Whitnash not only of its green places but the wildlife also find their habitats increasingly threatened. There appears to be no stop to this urban sprawl in this area.

Furthermore, I note with disgust that only 11% of new development will take place on brown-field sites under this plan. This demonstrates that there is too little willingness on the part of the council and developers to change land use and make a contribution to the overall well-being of the district by removing these eye-sores and putting the land into good use. The development at the Tachbrook Road/Old Warwick Road junction shows what can be done.

I do not agree that more shops and commercial premises are required, there are already many standing empty; in some areas up to 20% of the stock. Why therefore is it not possible to restrict commercial development and place the emphasis where appropriate on residential dwellings, rather than the easy option of green field exploitation.

There are many areas of derelict land around Leamington, Warwick and Keniliworth that have remained in this state for years. Why has no attempt been made to change the use for social housing, for example. Whitnash has had more than its fair share of development. It is time to say no more!

Warwick is already being spread thinly, and all of these major development proposed are around the edges of the town. Warwick cannot support the amount of traffic and infrastructure requirements now, so this will simply make things worse, and close to complete breakdown. there is not enough infrastructure investment in the town now, and never looks likely that it will change. Already Warwick's name is so diluted, that soon it will just be known as Warwick district, without any clear definition of the county town. Warwick needs to grasp its identity and not just be a dormitory town of outlining housing areas that loose the definition of what it means to live in Warwick.

See attachments

Object to the new Proposed Development Plans in the Green Belt area of North Leamington.
It would be unforgivable and irresponsible of planners to damage this area of North Leamington, when with a little effort and thought they could find other more appropriate sites such as such as the former Ford foundry site which you have foolishly allowed to be developed into offices when there are existing office blocks already empty in the town.
The Council constantly preaches a greener more sustainable way of living yet chooses not to build new houses on sites such as this brown field site, which would have given the new residents easy access to Leamington train station, both Leamington and Warwick town centres, local already existing supermarkets and retail areas and on an existing bus route.
Instead you wish to decimate our beautiful green belts creating communities that are totally dependent on cars - how dare you purport to be a Council that supports green and sustainable policies.
Much is made, quite rightly, of conserving our historic buildings but it is now time to give our countryside the same protection - you risk ruining this natural treasure for us and future generations.
When I have discussed this issue with the many people I know all agree that it is vital that the greenbelt is preserved but many tell me we are wasting our time, that the Planners will put on a show of listening but will then do exactly as they want with no concern for the residents of Leamington wishes. They tell me that all that counts is money. Please prove them wrong and make the morally correct decision and save our greenbelt.
This is your chance to make good and wise decisions and show yourselves as a Council that really does care about the environment.

I wish to vigourously object to the building on green belt land in Blackdown and Old Milverton.

The Government's National Planning Policy Framework requires there to be "very special circumstances" for development in the Green Belt and for the harm created to the Green Belt to be outweighed by the benefit of the development. Those special circumstances are apparently that there is nowhere else for the homes to be built. In the "2009 Core Strategy" (the previous plan adopted by Wawick District Council) land South of Leamington was identified, and is still available, for development. This land is east of the A452 Europa Way and south of Heathcote towards Bishops Tachbrook. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure to support it. It is close to the M40 and there are existing employment opportunities South of Leamington.
* The previous plan is direct evidence that there are alternative areas for development other than the Green Belt. Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because the concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt. The policy of "spreading it around" again is not planning policy but a political one. Thus the legality of the councils desicion making process comes into serious question.
* The proposals ignore Warwick District Council's Green Belt Study of the land at Old Milverton and Black Down which concluded that these areas had high Green Belt value.

* Green Belt land is specifically set aside to prevent urban sprawl, stop towns merging together and protect the country side setting of historic towns. The proposals will reduce the" Green Lung" between Leamington and Kenilworth to less than 1 1/2 miles encouraging the merger of these two towns and their loss of independent identities.
* Turning the A452 between Leamington and Kenilworth in to dual carriage way will not help traffic flows. At peak times the delays on the A452 result from commuters wanting access to the Town centres.
* The proposals will have a detrimental effect on the picturesque northern gateways to Leamington and Kenilworth, it will change the character of Leamington for ever,.
* A "Northern Relief Road" (budgeted cost £28m) is not required. The traffic flows tend to be north; south rather than east; west. The road will serve no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns.
* A "Northern Relief Road" will form a natural barrier and encourage further development in the green belt up to this new road. It will need to be built across the flood plain (at considerable cost) and will violate an important nature corridor along the River Avon.
* The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area attractive places to live. Further "out of town" shopping will take trade away from the Towns.
* There will be a loss of a significant amount of high quality agricultural land in Black Down and Old Milverton
* The land at Old Milverton and Blackdown has substantial amenity value and is presently enjoyed by a great many walkers, runner, riders, and cyclists.
It provides a countryside environment close to the centres of Leamington and Warwick. Both the proposed building development and the "Northern Relief Road" would substantially reduce the amount of land that is available to enjoyed and have a detrimental impact on the ambience and hence the amenity value of the land. Turning some of it into a maintained park would detract from rather than enhance its value. There is no infrastructure problems to the previous chosen development sites in South Leamington.
* Warwick District Council has included a "buffer" of 1400 homes in the number of houses that it believes will be necessary between now and 2026. If this "buffer" is removed from the assumptions there is no need to include the land at Old Milverton and Black Down in the proposals. There has been in recent years an exceptional growth in Leamingtons population partly because of Europe. However this has now levelled of. There are not hundreds and thousands of homeless people sleeping in the streets of Leamington at night, so I seriously question the need for development of such a scale. The prime minister recently stated that people should no longer except free housing there friends and family should assist, by carrying out such a development the council is not working to the spirit of what the Prime Minister is saying, I for one will be writing to him to inform him of this. Further more there has been an extra approximately 500 student beds places created/about to be created in Leamington in purpose built buildings this year alone. This means talking to local agents that small houses are now not being rented by students and about an extra 100 5 bed homes are sitting empty this year, they are going to be either rented out to private tenants or DSS tenants or sold of private individuals or families, I feel the council has missed the point that about 500 extra beds spaces houses will be available this to the community, as student population is down by about 10% this year nationally, furthermore with the increase in fees this year, there is likely to be an even further decrease in the student population freeing up more housing.


To summarise I am objecting on the below grounds

1. Local amenity taking away our local open public space
2. Green belt, not adhering to policy when you have already suitable land for development.
3. Over provision of housing, as the sires previously declared suitable will inevitably be still developed, and student houses becoming available.
4. Coalescence of urban sprawl, towns will soon be close together losing their identities, which makes Leamington so special
5. Infrastructure. No need to spend £28 million on new road when there is infrastructure in place at the previous south Leamington sites declared suitable

I am writing to voice my strong objection to the proposals to build on green belt land in and around Leamington, Blackdown and old Milverton. I am bewildered at the reasons put forward and would like to know what the exceptional circumstances are that the council feel give them the excuse to build.

I am not against developments when they are appropriate and necessary and particularly when they are well thought through after extensive research and consideration of alternatives. This does not seem to have happened in this particular case. We currently have the development of the old North Leamington School site which will provide 100's of new homes, just up the road in Cubbington you have a brown field site where the Thwaites plant currently is with lots of derelict unused buildings, this whole site would remove the heavy plant using the old road, stop disturbing the residents and provide for 100's of more homes. The existing plant could be relocated to another industrial site. The south of the town affords additional brown belt land with Harbury Lane being a previous preferred site with developers ready to develop 100's if not 1000's of homes. These would be nearer the M40, train station and the major shopping retail park.

Also the proposal for further commercial properties further perplexes me as the constant empty shop faces we are seeing around Leamington shows that bringing in the 'large chain stores' is affecting the local businesses and subsequently the local communities that prefer to use them. I have previously worked for a long standing local business in Leamington town centre and saw how the shop struggled for customers with larger chains opening in the town centre and Shires Retail Park, surely further more of these will affect the local businesses in Leamington.

I have been a resident on Leicester Lane my whole life and I am disgusted that there are planning applications being made to build on our loved countryside destroying the beautiful land, creating a distinguish between the boundaries of Leamington and Kenilworth. Development here would merge the two towns together and will cause even more disruption to local residents by creating an even further back log of traffic. This would not be simply rectified by turning the Kenilworth road into a dual carriageway, as many people will continue to use Leicester lane and Bericote road as access to Leamington to avoid the Kenilworth road or driving through the centre of town.

I have seen firsthand the affect the Warwick gates development had on residents in Whitnash with many children in Whitnash now not falling into the catchment area for Myton school so being unable to attend the school with siblings, this would create additional stress to parents of children in this area as they may no longer be able to send their children to the local schools in this area having to travel further afield for this.

The green belt land is also home to many wildlife, birds, rabbits, foxes to name a few and also the horses on the paddock, development on Leicester lane and Blackdown will dramatically reduce this and again more children in this area could potentially grow up with the concrete jungle mentality. Leamington is a town NOT a city and over development of our green belt land could destroy the pull that Leamington has for out of Towner's to visit. I ask you to reconsider your plans which do appear to be profit driven and consider saving our 'Important' Greenbelt.

I hope you take my views and those of my fellow residents seriously before blindly agreeing for further detrimental development of our town and would appreciate acknowledgement of this email with a detailed response.

Scanned Representations

See attached

See attached letter

Scanned representation

See attached Response Forms

Scanned representation

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.