Thickthorn

See attached letter

As scanned.

At a recent Parish Council meeting, The Chairman and Councillors of Leek Wootton & Guy's Cliffe Parish Council discussed the Local Plan. Their views are below -

The Parish Council are particularly concerned with the following proposals in the draft Local Plan:

1) [PO16] We are opposed to any Village Envelope and Green belt boundary changes within Leek Wootton.
It is felt strongly that this creates a significant erosion of the boundary and development protections in our area, and it is contrary to the recently adopted Parish Plan.

2) [PO1] We believe that the basis upon which projections of future population and housing needs are not realistic or supported by proven evidence, and that the housing development plans for Warwick District should be much smaller than those proposed.

3) [PO4] The proposal for 30-80 new dwellings in Leek Wootton is contrary to our Parish Plan (fully backed by residents survey responses) which states that any large scale development is precluded and individual new property proposals possible only within the current building envelope.

4) [PO14/PO15] The proposed 'Leamington Northern Relief road' will unavoidably cause excessive environmental damage, having to cross a railway line, river and a flood plain.

5) [PO1/PO14] The large developments proposed in the surrounding area particularly Kenilworth will inevitably increase significantly the traffic through Leek Wootton unless these developments are kept to a more manageable size.

See attached.

Attached

PO1 Preferred Option: Level of growth
I consider that the proposed level of housing growth of 555 homes per year is not supported by all the evidence available. The mathematics of the calculations are not shown so they cannot be checked easily.
The baseline population on which the future need is apparently calculated is the ONS estimate of 138,670. Since those calculations the 2011 census has measured it at 136,000.
The initial stage of consultation gave a range of growth possibilities and the clear majority of respondents opted for the lower growth levels which would more reasonably reflect the inevitable organic growth in our population due to increased longevity, better health and changes in birth rates along with some inevitable inward migration.
Residents made a clear choice to accept lower infrastructure gains in return for limiting growth and specifically avoiding more growth in excess of local need.
Approximately 250 homes per year would appear to be more than adequate to meet these need if more adventurous use of brownfield urban sites was made..

PO2 Preferred Option: Community Infrastructure Levy
The current market conditions demonstrate that because developers are not confident in the ability of customers to buy, and sites that already have planning approvals are not proceeding.
CIL should be used on a local benefit to relieve effects of or immediately related to development proposal areas.


PO3 Preferred Option: Broad location of Growth
I supports the dispersal of additional housing that cannot be located on urban brownfield sites so there is a small effect on a number of places, rather than a large effect on a few. In general, this will reduce travel and demand for traffic improvements, use existing educational, health and other community facilities where there is available capacity to do so.
The NPPF para 54 requires that in rural areas, local authorities should be responsive to local circumstances, planning housing development to reflect local needs. In para 55, to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities.

PO4 Preferred Option: Distribution of sites for housing
Location 1 Sites within existing towns. This is the best option. If it were possible, all the housing required should be in existing towns and dispersed therein, to make the least demand on support infrastructure and reducing traffic movements.
Location 2 Myton Garden Suburb. No objection.
Location 3 South of Gallows Hill/West of Europa Way. This development must not take place. It is a criminal intrusion into the rural southern setting of both Warwick and Leamington with important implications for the setting of Warwick Castle and its parkland. It will create a natural infill area for later development until eventually all the area south of Warwick and Leamington id completely filled.
The additional traffic from the proposed 1600 homes plus employment on a road system that is already struggling will impose even greater stacking effects back through the village of Barford which already suffers enormous amounts of rat-running from commuters trying to avoid the daily J15/Banbury Spur commuter
The numbers show that it is not needed and the council needs to bold enough to decide to continue the Green Wedge through to Castle Park.
Location 4 Milverton Gardens. 810houses + community +employment + open space.
and
Location 5 Blackdown. 1170 houses+ employment +open space + community.
These two sites may well be cases where the Greenbelt policy could be relaxed with limited overall damage whilst providing essential housing land. There would be limited damage to the settlement separation intentions of the Greenbelt policy.


Location 6 Whitnash East/ South of Sydenham. 650 houses + open space and community facilities
No specific comment but is this really required?
Location 7 Thickthorn, Kenilworth 770 houses + employment +open space + community
Use of this as part of the policy for dispersal of the housing required is supported.
It is, better to use this site than land of rural, landscape and environmental value elsewhere in the district. It is the only contribution to the preferred option plan located in or near Kenilworth.
Location 8 Red House Farm, Lillington 200 houses + open space.
This would seem to be a reasonable site to utilise if numbers demand it.
Location 9 Loes Farm, Warwick 180 houses + open space
This would seem to be a reasonable site to utilise if numbers demand it.
Location 10 Warwick Gates Employment land 200 houses + open space.
No objection.
Location 11 Woodside Farm, Tachbrook Road 250 houses + open space
There seem to be merits in using this site as it extends previously developed land towards a natural boundary (Harbury Lane) and is hence self-limiting.

Location 12 Fieldgate Lane/Golf Lane, Whitnash 90 houses + open space
No objection.
Locations 13 &14 Category 1 & 2 villages Category 1, 5 villages at 100 and category 2, 7 villages at between 30 to 80 in each plus 8 category 3 villages within the existing village envelopes.
These are very significant increases for many of these villages! Do the category One villages really NEED to take 500 in total or 100 each. In Barford's case this will be an 18% increase in the number of dwellings, and that on top of a recent development of approximately 70 homes. I would suggest that the total Cat One numbers should be significantly reduced and that numbers should then be spread pro-rata over all the Cat one villages according to current house numbers of population number to give a more equitable spread and certainly to keep the increases at or below the district wide increase.
Considerable attention should be paid to the Sustainability Assessments included in the plan where it should be noted that Barford, a Category one village based on its facilities scores the THIRD WORST Sustainability score of all the villages assessed (Cat one, two and three) with only Rowington and Norton Lindsey scoring lower.

Furthermore despite having a very successful school there is considerable doubt about how such numbers could be accommodated and the amount of harm that would be inflicted on currently resident families and pupils of such increases.


PO5 Preferred Option: Affordable housing
I have considerable concerns that the 40% requirement is considerably in excess of the real need for "social housing" and as such will drive up the costs of market homes to such a degree that all homes will become significantly less affordable. It is perhaps appropriate to consider what is trying to be achieved and to review the way in which Affordable Housing need is actually measured - specifically it seems that those in need are counted before their need is actually validated whereafter the real need is actually considerably less and they are re-routed to more conventional housing sources.
PO6 Preferred Option: Mixed communities and a wide choice of homes
Regarding retirement housing of various sorts must be provided as part of a whole-life

PO7 Preferred Option: gypsies and travellers.
The Gypsies and travellers remain and always will be a problem. Most tax-payers are at a loss to understand why they must be treated differently to everyone else when they could acquire land and pursue the planning process just like everyone else.
The proposal to "provide sites" will bring out the worst elements of the NIMBY culture and blight certain areas.
It is my opinion that the problem needs solving by primary legislation not the current soft PC approach. This is a job for central government, no doubt through "Europe".

PO8 Preferred Option: Economy
Employment need only be provided/attracted to match our population. The previous stage of the consultation gave a clear indication that the majority were preferring to accept lower growth rates of housing, employment and infrastructure. That choice must be selected and a focus on consolidation rather than growth should be the watchword. We are a low unemployment area and any extra employment provision will bring with it a proportionate housing demand and inevitably more houses, which is not required.
The Gateway project may still materialise and this will make extra demands as some of the jobs will no doubt be attractive to our residents in addition to bringing in new workers. Provision should be made for housing local to that site and not for such workers to be subsumed into the wider WDC area.

PO9 Preferred options: Retailing and Town Centres
The support retailing and town centres is welcomed and should be vigorously pursued by both planning policy and fiscal incentives. There must be adequate town centre parking provision to support town centre businesses.

PO14 Preferred options: Transport

Access to services and facilities.
Clearly, it is essential to provide sufficient transport infrastructure to give access to services and facilities. The amount of work required is dependent on the level of growth selected. If the low growth scenario is chosen in preference to the current preferred option, then the infrastructure improvements will be much less and probably not much more than is currently necessary to resolve existing problems. This would be less costly and less inconvenient to the public than major infrastructure improvements.

Sustainable forms of transport.
The best way is to keep as much new housing provision as possible in existing urban locations because people are then more likely to walk, bus, bike to work, shops, school etc.


PO15 Preferred options: Green Infrastructure

The policies set out in PO15 are supported


PO16 Preferred options: Green Belt

The NPPF states that once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. I believe that it may be a proper time to review the Green belt to ensure that it is appropriate to the current situation and not merely being carried forward, just because it has always been so. Some relaxation within villages and on the edges of the major settlements would make massive contributions to the housing need whilst doing little harm to the concept of ensuring separation between settlements.

Removing Green Belt status from rural villages would allow currently unavailable infil land to make a significant contribution to housing numbers whilst improving the sustainability of those villages. Barford, not in the Green belt has had considerable infil in the past and as such is relatively sustainable whilst actually scoring poorly on the WDC conventional Sustainability Assessment scoring system.



PO17 Preferred options: Culture & Tourism

The preferred option of medium growth seems to be totally oblivious of the value of the approach road from the south to the Castle. It proposes to materially downgrade the approach past Castle Park by building housing along the length of the road from Greys Mallory to Warwick, a distance of about 2.5 km. The views across the rolling countryside to the east of the approach road are an essential part of the character of the district and county about which books have been written.

The low growth option makes that loss unnecessary.

PO18 Preferred options: Flooding & Water

Flooding: Development should take place where flooding is unlikely to occur. The low growth option would make it easier to select sites for development that do not carry this risk.

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1 INTRODUCTION
1.1 RPS Planning and Development (RPS) has been instructed by Lenco Investments (Lenco) to
prepare representations to the Warwick District Council New Local Plan Preferred Options
consultation document, in respect of their land interests at Baginton.
1.2 Warwick District Council (the Council) has proposed their Preferred Options in terms of housing
and economic growth and their vision for the district generally over the plan period to 2029.
These are currently being consulted upon until 27 July 2012.
1.3 RPS has made representations on behalf of Lenco to the previous stages of both the Warwick
Local Development Framework and the Coventry Core Strategy, to ensure a suitable approach is
taken to cross boundary development led growth.
1.4 Lenco's land interests at Baginton relate to a site which lies to the south of Baginton village
situated within the Green Belt, as shown at Appendix 1. It is important to note that Lenco has the
controlling interest in the majority of this land.
1.5 The site Lenco has interests in lies to the south of Baginton village, and. The site extends to
approximately 50ha and is in a sustainable location within easy access to Coventry City Centre,
close to the perimeter edge of the airport, with excellent cycle, pedestrian access to the
surrounding areas, and vehicular access to major transport links such as the A45 and A46.
1.6 Whilst the site falls within the local authority area of Warwick District it remains very close to
Coventry's administrative boundary, as well as the major sub regional employment base centred
on Coventry Airport. RPS is aware of the current proposals to expand Coventry Airport, and a housing development at Baginton would support these expansion plans.
1.7 The representations, therefore, address the need for housing growth within Warwick
administrative boundary and suggest that large-scale growth should be situated within close
proximity of employment development to ensure that people can live and work in close proximity.
Such proposals will support the Government's objectives to encourage economic growth in order
to revive the economy. Furthermore, these representations address the need for cross-boundary
growth and for full and proper cross-boundary working to be established between, Warwick,
Coventry and Nuneaton and Bedworth Boroughs as required by the Localism Act and NPPF.
1.8 The following chapter provides details about the site at Baginton, and our comments in response
to the Preferred Options document are provided in Chapter 3 and are set out in the same format
as the Council's response forms.
1.9 RPS are willing to meet with Planning Officers from Warwick District Council again concerning
Lenco's land interests and the New Local Plan process to discuss the potential of the site in
meeting local housing needs.
2 LAND SOUTH OF BAGINTON
2.1 The site Lenco has interests in extends to approximately 50ha and lies to the south of Bagington
village. The site is in a sustainable location close to Coventry City's boundary and the urban
area, and within easy access to the City Centre, and major transport links such as the A45 and
A46. The site, being close to the perimeter edge of the airport, with excellent cycle, pedestrian
and vehicular access, provides an exceptional opportunity for the provision of balanced housing
growth in the most sustainable manner.
Planning Policy
2.2 The Local Plan Preferred Options promotes 10,800 new dwellings within Warwick District for the
plan period up to 2029, at an annual delivery rate of 600 dwellings a year.
2.3 Evidence advanced by the West Midlands regional assembly for the West Midlands RSS
Examination in July 2009 from the Cambridge Centre for Housing and Planning Research,
based on 2006 ONS Household Projections and allowing for the economic downturn, concluded
that Warwick District's housing requirement between 2006 and 2026 was 18,200 dwellings at a
rate of 910 dwellings/year. Whilst the RSS is not longer in place, the evidence base is still to be
taken into account by Local Planning Authorities in preparing development plan documents.
2.4 The 2012 Strategic Housing Market Assessment indicates a requirement of 698 dwellings a year
to meet the affordable housing needs of the District in addition to market housing needs, which
is significantly higher than the level of housing currently being proposed by the Council.
2.5 The 2008 ONS Household Projections predicted an increase of 17,000 households between
2008 and 2028, at a rate of 850 dwellings a year. This represents an additional 150 dwellings a
year than is currently proposed through the Local Plan, which clearly will not meet the District's
identified need for new homes.
2.6 RPS is also aware that the 2012 SHLAA indicates that the District has a supply of deliverable
sites to provide 13,385 dwellings between 2014 and 2029, excluding windfalls, which is greater
than the numbers proposed within the Local Plan. Therefore the Council has identified the
ability to deliver housing sites at a higher annual rate than is currently proposed through the
Preferred Option.
2.7 RPS, on behalf of Lenco, therefore believes that the proposed figure of 10,800 new dwellings is
insufficient and that a higher level of growth would better reflect the projected population
increase and ensure that identified housing needs can be met, as suggested within the evidence
base. The Council cannot meet a higher target without locating housing on greenfield of Green
Belt land, and therefore should consider sustainable locations outside of the urban areas to
ensure housing needs can be appropriately met.
Cross-boundary Growth
2.8 The NPPF states that Local Planning Authorities have a 'duty to co-operate' on cross-boundary
planning issues, in particular for strategic priorities including housing, to meet development
needs which cannot be met solely within their own administrative boundaries.
6 rpsgroup.com
2.9 It has been recognised in Coventry's SHLAA assessment that the Council cannot meet their
housing targets on land within their administrative boundary alone. It is considered, therefore,
that Green Belt locations on the periphery of the urban area should be recognised as
appropriate locations for accommodating future growth.
2.10 The Green Belt south of Coventry was recognised through the Warwick Core Strategy process as
being an appropriate location for accommodating future growth of the City. Although the site is
within Warwick District it lies close to Coventry's administrative boundary, as well as the major
sub regional employment base centred on Coventry Airport.
Coventry Airport
2.11 Whilst both Coventry Airport's major sub regional employment base and Baginton village are
located outside of Coventry's local authority boundary, they are socially and economically
associated and physically adjoin the Coventry urban area. Residential development in this
location at Baginton could balance the existing significant employment base on the southern
side of Coventry, such as those around the airport at Stonebridge Trading Estate and
Middlemarch Business Park, both of which are within a very short distance of the site, as well as
the air freight and terminal employment opportunities.
2.12 RPS is also aware of the current Coventry and Warwickshire Gateway Scheme proposals
(Appendix 2) to expand Coventry Airport, and a housing development at Baginton would support
these expansion plans. RPS recommends that housing supply is focused in those areas where
there are important benefits to be gained where future economic growth is planned.
Site at Baginton
2.13 A residential-led mixed use development at Baginton could contribute sustainably to crossboundary
growth as required by the NPPF, and to meeting both Warwick District and Coventry
City's housing needs by delivering approximately 1,000 new homes either in isolation or as part
of the wider regeneration proposals for the area. The location of the site in relation to the
Gateway proposals is shown at Appendix 3.
2.14 Development at this location would also allow for new facilities and services to be provided,
making the best use of existing and proposed infrastructure. The site can be appropriately
phased over the Local Plan period to develop an available, suitable and deliverable urban
extension proposal.
2.15 The promotional document 'Land south of Baginton: A Sustainable Urban Extension' prepared in
2008 has previously been submitted to the Council and provides further details of how the site
could be sustainably developed.
2.16 In addition to this, extensive technical surveys in relation to flood risk, noise, ecology,
conservation and heritage, landscape, and highways have been undertaken of the site and
submitted to the Council, to demonstrate the site's suitability for a significant residential-led
development either in isolation or in connection with proposals for the wider area. An Air Quality
Assessment will also be undertaken to demonstrate the site's suitability for development.
2.17 RPS, therefore, considers that to help deliver greater sustainable development opportunities, it is
important that sufficient housing land comes forward in areas of proven market demand, such as on this Green Belt site to the south of Baginton, to contribute towards delivery of additional
dwellings and higher levels of growth to meet the needs of both Councils.
2.18 Responses to individual policies and topics within the Preferred Options consultation document
are included in the following chapter

See attachment.

Dear Sir,
My preferred option plan consultation feedback:
GREEN BELT - National Planning Policy Framew9rk requires "very special circumstances"
The Green Belt covers only 13% of the area of England. This preferred plan is for 10,800 dwellings
and 43% of land used will be green belt. How can this be justified when there is still plenty of white
field land available south of Leamington? Presumably the "very special circumstances" come into
effect when the 57% development on white fields has been used. This growth is scheduled to take
15 years at a constant annual rate of 555 houses per year. 57% of 15 is 8.55. So it will be eight and a
half years before these "very special circumstances" (ie. white field sites are filled and green belt is
needed) comes into effect. By then another plan will have been made!
I disagree strongly with any relaxation of the green belt which is there to stop conurbations merging.
This plan will leave less than 1 Y, miles between ~Kenilworth and Leamington.
Why does Kenilworth need to expand? It has always been in the past a much smaller town than
Leamington and Warwick and mushroomed massively in the 1960s, and also in the 1980s when
Knights Meadow and the Lindisfarne Drive estates were built. Why should we let this happen again
to keep pace with the other towns? Councillors tell me that the Green Belt is strangling Kenilworth.
This is precisely its purpose. We should be grateful that our town has these safeguards in place to
protect it.
770 dwellings equates to about 1770 people which is almost a 10% increase in Kenilworth's
population in an area which is quite detached from Kenilworth and is not likely to make its
inhabitants feel a part of the community. The town centre should be in the middle of the town. Far
too much development is on the east side and it should now be the turn of the west, if the Green
Belt has to be sacrificed, where there is no risk of it merging with other towns and which would be ~
short walk to the centre of town without cars needing to be used.
THICKTHORN.
How was the Thickthorn site chosen?
Surely not because it abuts the A46 which is noisy both day and night. Was a site visit made to see
just how noisy it will be for all the inhabitants? Were decibel readings taken at various points up the
hill to ascertain the suitability of this site? The noise is particularly bad on a hot sunny day with the
prevailing south-west wind. What about HS2 whose boom will be heard at Thickthorn as it passes 18
times per hour in both directions on the EAST side? This estate will be on the flight path of Coventry
*
International Airport where there is no restriction on night flights and jets scream right over the
proposed development land and at a very low level on their way to Baginton as they have to avoid
the Birmingham flight path, (which is also noisy) as this is the crossover point of the two flightpaths.
It would be a very selfish decision to commit people to a life of misery with all this noise even
through double glazing. This is not the same scenario as the Woodloes where houses abut the road,
which at that point is 4 lanes instead of 6, where there the A46 is the other side of the natural sound
barrier of Primrose Hill. At Thickthorn noise is impossible to stop owing to the contours of the land
which is a basin causing the noise to be trapped and sweep up the hill towards dwellings. The noise
is incessant both day and night. It is an ideal location for the sports fields which are already there,
where people can go away at the end and not have to endure it 24 hours a day. Office buildings
along it will not dissipate the sound.
TRAFFIC
Having 1200 cars discharging from the estate each morning will be a nightmare and cause even
longer queues up Birches Lane and into Glasshouse Lane. It will be a worse effect than the horse fair
there every day of the year. Updating St Johns gyratory presumably means traffic lights which will
cause long tailbacks into the town centre as they have priority under the give-way scheme.
I cannot understand how a dual carriageway between Kenilworth and Leamington will help as all the
traffic will have to funnel in at either end and will just result in 4 lanes of slow moving traffic instead
of 2. Creation of bus lanes will in any case limit traffic flow to one lane in each direction to speed up
a bus every 10 minutes if you're lucky, and nothing will be gained in terms of traffic build up.
There are no points wide enough along Glasshouse Lane for the junction of a spine road, as the
corner with Rocky Lane is on a dangerous bend. In any case, Glasshouse Lane is a unique and
attractive feature of 1930s period landscaping, a Kenilworth gem, which should be preserved and
which junctions along its length will destroy.
NUMBERS
Where do these figures come from for 10,800 houses?
It is in the interest of the District Council to have as many new houses as possible, as they receive 6
times the Council Tax from the New Homes Bonus Scheme for every new dwelling completed and
more than that if they are affordable housing.
This plan is not led by suitability but the interest of landowners to sell off their land for housing.
These are not sufficient grounds for this massive increase in population concentrated in a small area
as the plans make little use of rural area development. Lots of villages need regenerating. Radford
Semele has had no growth since the 1960s and has a school in place already. It has good transport
links to the M40, Fosse Way and Leamington Station and IT IS IN A WHITE FIELD ZONE. If such a large
number are needed, they should be put in the South Leamington area on white field sites as
Leamington already has all the amenities (parks, department stores, nightclubs, cinemas) jobs to
support it. This is a Warwick District Council plan not a Kenilworth plan and there are plenty of other
places where housing could be built.
WHAT ARE YOU, OUR TOWN COUNCIL, DOING?
Old Milverton and Blackdown Parish Council are sending a formal objection on behalf of the area.
Where is the formal OBJECTION from our town council on behalf of its 23,000 residents? Our town
should be protected from losing its identity.
Offices are not needed -lots are available to rent. St Johns next to Jet garage, old Pottertons site.
Industrial land is not needed as Archery Fields is empty with fountains and wasteful landscaping at
the entrance.
You cannot make people live and work in the same place. These ideas don't work. Kenilworth is not
an industrial town and should not strive to be such.
THE A46 WAS PLACED WHERE IT IS TO KEEP IT AWAY FROM THE POPULATION.
Why were these ideas devised secretly without asking the people who voted for you their opinions
before consulting the district planners?
CONCLUSION
Population figures should be challenged.
Green belt should be protected.
Consideration of the effect on the HEALTH of people living alongside a motorway with NOISE and
POOR AIR QUALITY owing to constant fumes and directly under a flight path with NOISE due to very
low flying aircraft should be made.

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
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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.