Loes Farm (North of Woodloes)
Object
Preferred Options
Representation ID: 50716
Received: 06/08/2012
Respondent: Friends of Guys Cliffe
Agent:
The proposed development would encroach into what is considered as a conservation area in respect of its close proximity to what is an historically significant area of Warwick.
There are concerns that it would set a precedent for development thereon, ultimately changing the unique character of the area. There are concerns regarding an increased level of traffic on already busy rotes in the locality.
Therefore we are very much opposed to this allocation
See attached.
Object
Preferred Options
Representation ID: 50721
Received: 20/02/2013
Respondent: Mr & Mrs M & A Hill
Objects to the loss of the Green Belt at Loes Farm, the land in question is Listed as a parkland of particular historic interest, furthermore there is a restrictive covenant on much of it. the farmland in question comprises of many unique features, some dating back to mediaeval times, the ridge and furrow drainage system being one example.
Como wood and the immediate area provide a beautiful backdrop to a main route into Warwick and should be preserved at all costs. The meadowland is species rich including protected species, and habitat valuable ancient hedgerows.
There is also a high water table at this location that will cause flooding if this area is developed. This development would be visually intrusive and would add to existing traffic related problems. Furthermore it is argued that there will not be enough employment opportunities locally to support the population expansion at this part of Warwick.
see attachment
Object
Preferred Options
Representation ID: 50788
Received: 31/07/2012
Respondent: Mr Graham Harvey
Here is a remnant of green belt that acts in many ways to prevent encroachment and to check the unrestricted sprawl of large built-up areas. There are no exceptional circumstances to suggest that this ought to be removed from the green belt.
It is a natural Green Wedge and meets the constraints to development which are set out in PO15 -Green Infrastructure.
Both of these factors are already present without the need for enhancement.
It is not clear whether the whole area up to the A46 would be removed from the green belt but to do so would potentially then allow for further development. It is doubtful whether the farming activity would be viable after the construction of 180 houses (removal of 28.54 acres).
The whole area is part of a major approach to the historic county town. The current arrangement screens the Woodloes Estate and together with the designated Garden Park / Garden of Special Historic Interest provides one of the last rural approaches to the town.
In previous documentation e.g The Strategic Land Housing Assessment June 2009, this has been access to this area has been recognised as 'constrained'
Amenity /landscape value:
The views from Woodloes Lane, across to Old Milverton, benefit from this elevated position. The trees, many of which are ancient, give a peerless framework to these views.
The lane is part of the designated 'Millennium Way' which is enjoyed by many visitors as well as locals who ride, cycle, walk and dog walk along its length.
The points in para 109 of the NPPF nearly all apply to Loes Farm.
In 2008 when the area was being considered for development a report was written examining many sites with regard to biodiversity:
"The sections of woodland are of high biodiversity value and should be protected from development...that the species rich hedgerow is retained with a buffer zone....The ponds should be retained with a buffer zone implemented to protect the biodiversity value of the ponds...The grassland within this parcel is significant due to the
presence of mature anthills and ridge and furrow. This grassland dominates the parcel and therefore the parcel is not favourable for development."
The findings are still valid and we have personal knowledge of the birds, butterflies, moths and other insects that are supported by this habitat and that it is a green corridor for many more.
Concerns have also been expressed locally about the potential of exacerbated local flooding problems to properties including Hinton's Nursery and adjacent properties as a result of development.
Access:
Clarity about the nature of access to this site has been hard to come by, but the suggestion has been that it would be from Primrose Hill, approximately where the 'speed trap' pad is sited. This is by definition therefore a hazardous area with traffic coming over the blind brow just before Hathaway Drive at excessive
speed. There are already problems with cars turning into Woodloes Avenue North and the proximity of two roads would, without serious mitigation, exacerbate this.
Safety for pedestrians or cyclists walking/cycling from the proposed site is also poor with little current access except for cutting through near Woodloes Avenue North and Elliott Close. It is highly unlikely given current preferences by parents to drive their children to school for safety and convenience reasons that
the walking/cycling options will be attractive from this more distant location.
The Coventry Road also has a bad track record especially with regard to the access to the Saxon Mill and it is assumed that this would be a wholly inappropriate access point.
Infrastructure
It is impossible to gauge whether there is sufficient capacity in schools, doctor's surgeries, without serious infrastructure costs. There are no proposals for local employment that relate to this add on to the Woodloes Park development.
The Coventry Road, and especially the island servicing Greville Road and Primrose Hill, already have capacity issues which have been recognised in Transport Plans as well as air quality issues. There addition of additional vehicles from such a development will exacerbate the situation especially as there will be an increase of traffic on the estate roads to the school and local shops.
Community Infrastructure Levy
There are considerable costs to a developer for this site not only for the road and pedestrian access but also to provide an extension of the sound barrier along the A46 to mitigate the very high levels of traffic noise.
Submission Attached.
Object
Preferred Options
Representation ID: 50832
Received: 26/07/2012
Respondent: Historic England
Impact on designated and undesignated heritage assets.
Substantial harm to undesignated assets contarary to NPPF.
Detailed analysis appears not to have been undertaken.
Thank you for providing English Heritage with the opportunity to further comment on this evolving strategic plan for the District. This correspondence will regrettably reiterate certain points made in previous letters dated 9 April 2010 and 5 July 2011; both are therefore attached for your information.
As the government's adviser for the historic environment, English Heritage broadly welcomes the positive strategy set out in section 11, and in particular Objectives 7 and 14 of the Plan.
I note a recognition in the Plan of the pressure for new development threatens the "highquality
built and natural environments in the district, particularly historic areas"1 but however goes on to reassure that 10,800 new homes (to 2029) will be founded on "best evidence"2 and located in the most suitable locations3 to help ensure the historic environment is then protected and enhanced4.
The National Planning Policy Framework (NPPF) provides the context and justification for doing so, requiring Local Plans to be prepared with the objective of contributing to the achievement of sustainable development in accordance with the principles and policies for the historic environment.5
The following comments on a number of the proposed allocations unfortunately highlight an inconsistency with the above:
1 WLP PO Paragraph 4.8 point 6
2 WLP PO Paragraph 5.1
3 WLP PO Paragraph 7.6 "In addressing the important housing issues, the Local Plan will aim to...provide well-designed new developments in the most suitable location".
4 WLP PO Paragraph 4.6
"To protect and maintain the character of the District, the Local Plan will have to balance the growth of the District with the protection and enhancement of these assets".
5 NPPF Paragraph 151
2
Site D Land south of Gallows Hill, Warwick
Key assets affected - Warwick Castle Park Grade I Registered Park and Garden; Warwick
Castle Grade I Listed Building; Warwick Conservation Area
In comparison to all the nine sites assessed in the Landscape Character Assessment for
Land South of Warwick (Richard Morrish Associates, 2009 - Referred to herein as the LCA Report), the site to the south of Gallows Hill is described as being the area of highest relative value to the setting of Warwick. It is the only site that is considered to be unacceptable in principle.
"This is generally an area of well maintained agricultural land that is important to the setting of Castle Park and prominent in approaches to Warwick. We feel it should be safeguarded from development". Paragraph 5.4 LCA Report
"Warwick and Leamington Spa have highly-valued historic cores and Warwick Castle and the associated Castle Park have national heritage significance. Protecting the setting of these features must be considered a principal goal of future development planning in the locality".
Paragraph 5.1 LCA Report
It is needless to say any proposal which harms heritage assets of such national significance to such a degree is contrary to the NPPF6 and the principles of sustainable development.
The harm is not outweighed by the public benefit associated with this housing development.
It should be noted that the LCA Report does not refer to either the Historic Environment Record or the Warwick CA Appraisal; and it preceded the publication of the NPPF (March 2012);The Setting of Heritage Assets - English Heritage Guidance (October 2010); The Warwickshire Historic Landscape Characterisation (HLC) Report (WCC 2011)7; and the Conservation Plan for the park. If applied these are likely to reaffirm the sensitivity of the site and the unsuitability of the allocation.
Site WL5a Loes Farm, Warwick (Guy's Cliffe)
The draft local plan fails to have adequately considered the impact on designated and undesignated heritage assets to determine the suitability of the allocation. The proposal would appear likely to cause substantial harm to undesignated heritage assets of significant value, and harm to the setting of designated assets that contribute to that assets significance. This would be contrary to the NPPF and the great weight that should be afforded the conservation of heritage assets.
I refer to my letter dated 10 April 2010.
"You should ensure that thorough evidence is applied to determine whether the proposal would adversely affect the significance of the designated historic landscape and its setting including key views in and out. The direct and indirect impacts of major new development on the individual components that determine the relative value of Guy's Cliffe in total should be understood.
English Heritage considers that the well preserved areas of ridge and furrow should certainly be regarded as of national importance and preserved as a consequence, see:-
http://www.english-heritage.org.uk/upload/pdf/turning_plough.pdf?1267377944 "
The NPPF is clear that a draft local plan may be considered unsound if there has been no proper assessment of the significance of heritage assets in the area, including their settings,
6 NPPF paragraph 132
7 NPPF paragraph 170
3
and of the potential for finding new sites of archaeological or historic interest8, or, there has been no proper assessment to identify land where development would be inappropriate because of its historic significance.9
The Joint Green Belt Review recommends that to determine site suitability "finer grained, more detailed analysis" should be undertaken including the consideration of "Archaeological Constraints; Character, Setting; and Historic Landscape Character Analysis"10. This appears not to have been undertaken.
Site K5 south east Kenilworth
Previous correspondence highlighted the need to consider the evident significance of the adjacent Stoneleigh Abbey and designated Glasshouse Roman settlement, and the potential for further archaeology. Has this evidence been addressed?
Any future development would certainly need to protect the scheduled archaeology and its setting and that of the Grade II* registered Stoneleigh Abbey Park.
Coventry and Warwickshire Gateway - Baginton
The scale and form of any future development here is currently unclear. However it should be noted that the area includes designated and undesignated heritage assets of great importance. In accordance with the national policy expectations referred to above, a specific historic environment assessment must be undertaken to fully understand the landscape's special historic interest, the locations of particular historic significance and sensitivity. This can in turn inform the areas capacity, where development may best take place and what form
it might take.
Section 11. The Historic Environment
One of the twelve principal objectives for planning in the NPPF is the conservation of heritage assets for the quality of life they bring to this and future generations11.
Conservation means maintaining what is important about a place and improving it where this is desirable. This is not a passive exercise. Consequently we welcome the proactive approach you intend to take.
To compliment these measures might I suggest the Plan also address and target specific environmental improvements; the assets within the area on the heritage at risk register and the opportunity afforded by CIL/S106 agreements.
I note paragraph 5.1 of the LCR Report. "In addition and particularly as the towns are important tourist destinations, the quality of approaches to the town should be considered in all development planning. A combination of protection of landscape assets and enhancement or removal of landscape detractors should be considered in strategic planning".
Might the enhancement of the public realm be linked to creating an attractive environment for businesses and visitors? I refer to paragraph 14.18. How will the Local Plan compliment and help deliver the Warwickshire LTPs intention to "improve the quality of transport integration into streetscapes and the urban environment"?
Are there specific opportunities to demonstrate how CIL/S106 agreements could contribute towards the enhancement of individual assets or specific historic places, particular streets, spaces and the public realm?
8 NPPF paragraph 169
9 NPPF paragraph 157, seventh bullet-point.
10 Joint Green Belt Review paragraph 5.4.2/3
11 NPPF paragraph 17
4
Might the Plan address the particular issues identified during the development of the evidence base, including the ten monuments, four buildings and two parks on the national heritage at risk register?
Section 15 -Green Infrastructure appears to provide the 'bench mark' for a thorough and proactive strategy. I would be welcome the opportunity to help support a further refinement of Section 11 to achieve a similar comprehensive iteration.